Revised duties on aluminum, steel, and copper imports — plain-language guide for importers as of April 2026.
| Key revision: All Section 232 duties now apply to the full entered customs value of the product — not just the metal content portion. This change applies across all annexes. |
STEP 1 — Determine your product’s annex
Everything flows from which annex your product is classified under. Work through the annexes below in order. Once you find your classification, follow the rules for that annex only.
Annex I-A — Core metal articles (aluminum, steel, copper)
Products made entirely or almost entirely of aluminum, steel, or copper — e.g., steel coils, aluminum sheet, copper rod. Duty applies to the full customs value regardless of metal content percentage.
| Standard rate (all countries) 50% Default — full customs value | UK rate 25% Per trade agreement | U.S.-origin metal content 10% Made entirely with U.S. metal |
| Russia exception: Russian-origin Annex I-A products remain at 200%. Unchanged. |
Annex I-B — Derivative products
Products substantially made of steel, aluminum, or copper, but not pure metal articles — e.g., fabricated components and assemblies. Duty applies to the full entered customs value.
| Standard rate (all countries) 25% Default — full customs value | UK rate 15% Per trade agreement | U.S.-origin metal content 10% Made entirely with U.S. metal |
Exemptions — no duty imposed if either condition is met:
| Condition A | The product contains no steel, aluminum, or copper. |
| Condition B | The product is not classified under HTS chapters 72, 73, 74, or 76 and contains less than 15% steel, aluminum, or copper by content (see Annex IV threshold, below). |
Annex II — Exempt products
Products listed in Annex II are no longer subject to Section 232 steel or aluminum duties. If your product appears on this list, no further analysis is needed — it is out of scope entirely.
| Confirm your HTS classification matches an Annex II listing and you are done. |
Annex III — Trading partner items (transitional through January 2028)
Certain metal-intensive industrial and electrical grid equipment receive a reduced transitional rate through January 2028, intended to accelerate the U.S. industrial buildout.
| Trading partner rate 15% Total, inclusive of Column 1 duty | U.S.-origin metal content 10% Total including Column 1 duty | Non-trading-partner country 25% Falls back to Annex I-B rate |
Column 1 duty interaction
The 15% trading partner rate is a ceiling inclusive of the normal Column 1 MFN rate. If the Column 1 rate already exceeds 15%, no additional 232 duty is added — 232 simply does not apply.
| Example: Column 1 duty = 18% → no 232 stacks on top. Column 1 duty = 5% → 232 tops it up to 15% total. |
Revocation risk
The President can revoke trading partner status — and this preferential rate — at any time for any individual country. If revoked, the product immediately reverts to the standard Annex I-B rate of 25%.
| Planning note: Do not build supply chain assumptions around this rate being permanent. Model conservatively at 25% and treat the 15% as upside. |
Expiration — January 2028
The Annex III transitional rate automatically sunsets in January 2028. After that date, the product reverts to the standard Annex I-B 25% rate — even if trading partner status was never revoked. The same Annex IV metal content exemption rules apply here as for Annex I-B products.
Annex IV — The 15% metal content threshold
Annex IV does not list products. It establishes the threshold test used to determine whether a derivative product (Annex I-B or III) is metal-intensive enough to be subject to 232 at all. Apply this two-step test:
| Step A | Is the product classified under HTS chapters 72, 73, 74, or 76? If YES — 232 applies. The Annex IV threshold does not help you. Return to your annex for the applicable rate. If NO — proceed to Step B. |
| Step B | Does the product contain more than 15% steel, aluminum, or copper? If YES (above 15%) — 232 duty applies. Check your annex for the rate. If NO (15% or less) — no 232 duty. The product is not metal-intensive enough to be subject to Section 232. |
| In short: Annex IV establishes the 15% floor. Products that don’t clear it — i.e., they contain little metal — are no longer swept into 232 simply because they contain some metal. |
Rules that apply across all annexes
No stacking
A product subject to 232 is hit only once — even if it contains multiple covered metals (aluminum, steel, and copper). Duty is not layered per metal.
Existing trade agreements intact
This action does not alter previous trade agreement terms with the UK, EU, Japan, or South Korea.
Foreign Trade Zones
FTZ privileged foreign status is maintained. No change to existing FTZ treatment.
Manufacturing drawback
Manufacturing drawback is permitted. General drawback is not — no other drawback applies outside of manufacturing.
Russia
Russian-origin products remain subject to 200% duty across all annexes. No change.
Copper — smelt and cast
Country of smelt and cast requirements are forthcoming for copper. Currently in effect for steel and aluminum. Monitor for updates.
Key takeaways at a glance
| Pure metal articles (Annex I-A) Flat 50% on full customs value. Examples: steel coils, aluminum sheet, copper rod. | Substantial derivatives (Annex I-B) Flat 25% on full entered customs value. |
| Industrial equipment (Annex III) 15% through January 2028 — revocable at any time. Reverts to 25% on expiry or revocation. | U.S. metal content Products made abroad entirely with American steel, aluminum, or copper: 10%. |
| Low metal content Products with 15% or less steel, aluminum, or copper: no Section 232 duty. | Russia 200% across the board. Unchanged. |
This guide is a plain-language summary prepared for informational purposes. It does not constitute legal or customs advice. Confirm HTS classifications and applicable rates with a licensed customs broker or trade counsel before making import decisions.
