What Every Multinational Should Know About … The New Rules for Section 232 Tariffs on Steel, Aluminum, and Copper Derivatives

The U.S. government has fundamentally changed how Section 232 tariffs apply to steel, aluminum, and certain derivative products, replacing a content-based tariff methodology with a far broader entered-value approach that could significantly increase duty exposure for many importers.

Beginning June 2025, importers of certain steel and aluminum derivative products were required to calculate Section 232 duties based on the value of the “steel content” or “aluminum content” contained in the imported article. While conceptually straightforward, importers faced substantial uncertainty regarding how to calculate content values, allocate mixed-material costs, document sourcing information, and defend those calculations to U.S. Customs and Border Protection (CBP).

The Trump administration now has replaced that methodology with a new Section 232 metals tariff framework. Section 232 duties now generally apply to the full entered value of the imported product, with the applicable tariff rate determined by the product’s HTS classification and the corresponding Section 232 tariff category assigned to that product. To approximate the metal content, different HTS numbers subject to the Section 232 duties have differing tiered tariff rates.

This shift has significant implications for multinational companies. Although the revised methodology simplifies administration, it often materially increases Section 232 duty liability because lowered Section tariff rates can be more than offset by the fact that the Section 232 tariffs now generally apply to the entire entered value of the imported article rather than only its underlying metal content. The new framework also places even greater importance on accurate tariff classification, product scoping, landed-cost modeling, supplier documentation, and broader Customs compliance processes.

This article examines the revised Section 232 framework, explains how the new tariff structure operates in practice, and highlights the key compliance and risk-management considerations multinational companies should be evaluating now to cope with the new Section 232 metal tariff rules.

How We Got Here

The current revisions to the Section 232 framework are best understood against the backdrop of the government’s broader effort to expand steel and aluminum tariffs into downstream products. When Section 232 tariffs were first imposed, they focused on primary forms of steel and aluminum, gradually expanding to cover a growing list of derivative products that contain substantial amounts of metal content.

When many of these steel and aluminum derivative products were added in June and August of 2025, the Section 232 duties applied only to the steel or aluminum portion of the imported good. Conceptually, the approach aligned with the national security rationale underlying Section 232 by focusing on the steel or aluminum content. In practice, however, the methodology proved difficult to administer, partially because CBP provided only limited formal direction but mostly because the approach was unworkable. Although CBP stated in a Section 232 FAQ that importers should rely on “the invoice paid by the buyer of the steel or aluminum content,” this information often was not available to the importer of record and potentially not even known to foreign manufacturers, which often purchase steel inventory from a variety of sources.

As a result, importers were left with difficult judgment calls regarding which data sources to rely upon, including mill invoices, supplier invoices, transfer-pricing information, cost-accounting records, or other internal allocation methodologies. At the same time, importers were attempting to reconcile these approaches with existing Customs valuation principles and ensure consistency across products, suppliers, and entry filings. This increased compliance burden required extensive coordination among procurement, finance, logistics, engineering, and trade compliance personnel to identify, calculate, document, and support declared metal-content values. The combination of ambiguity, administrative complexity, and heightened enforcement exposure created growing pressure for a more predictable and administrable system.

In April 2026, the administration responded by fundamentally revising how Section 232 metal tariffs apply to derivative products. The revised framework abandons the requirement to calculate the value of steel or aluminum content and instead adopts a classification-based methodology that applies Section 232 duties to the full entered value of the imported product, with the applicable tariff rate determined by the product’s HTS classification and relevant Section 232 tariff category.

The shift reflects a policy judgment that a simpler and more uniform framework, even if less precise in targeting the actual metal content of a product, will prove more administrable. The revised approach, however, often imposes significantly higher tariffs, as detailed below.

How Section 232 Duties Now Will Be Calculated

The revised structure was established through the April 2, 2026, Presidential Proclamation and its associated annexes. Effective for goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on April 6, 2026, Section 232 duties apply to the full customs value of covered steel, aluminum, copper, and derivative articles, regardless of the actual value of the embedded metal content. The revised Section 232 framework replaces the former complex content-based valuation exercise with a more standardized, classification-driven tariff methodology. Rather than requiring importers to isolate, calculate, and substantiate the value of steel or aluminum inputs embedded within imported merchandise, the revised system generally applies Section 232 duties to the full entered value of the imported product. The applicable tariff rate is then determined based on the product’s HTS classification, which effectively serves as a proxy for the extent to which the product is composed of steel, aluminum, or copper.

In practical terms, the government has shifted away from attempting to measure the actual value of embedded metal content and instead adopted a tariff structure that ties duty exposure directly to tariff classification. Products classified in HTS provisions associated with primary metal goods or products consisting predominantly of steel, aluminum, or copper are subject to higher Section 232 rates. By contrast, downstream derivative products that merely incorporate covered metals as one component among many generally receive lower rates. The result is a tiered tariff framework in which HTS classification now plays the central role in determining Section 232 liability.

The new Section 232 metals tariffs framework generally operates as follows:

• 50% Duty on Full Customs Value – Annex I-A. Annex I-A applies a 50% Section 232 duty to the full customs value of covered aluminum and steel articles, most copper articles, and certain steel and aluminum derivative products. This category generally includes products made entirely or almost entirely of the covered metal, including many Chapter 72 steel products, certain Chapter 73 steel articles, Chapter 76 aluminum products, and Chapter 74 copper products.
• 25% Duty on Full Customs Value – Annex I-B. Annex I-B applies a 25% Section 232 duty to certain copper articles and derivative steel and aluminum products that remain within the Section 232 derivative regime but are not treated as predominantly metal articles. These products typically incorporate covered metals as one component within a broader manufactured good.
• Temporary 15% Treatment – Annex III. Certain steel and aluminum derivative products identified in Annex III receive temporary reduced treatment through December 31, 2027, meaning that the Section 232 duty is reduced so the combined ordinary Column 1 duty rate plus the Section 232 duty equals 15%. If the applicable Column 1 duty rate is already 15% or greater, no additional Section 232 duty applies under this temporary framework.
• 10% Rate for Qualifying U.S.-Origin Metal Inputs. Covered products manufactured abroad using qualifying U.S.-origin metal inputs may qualify for a reduced 10% Section 232 rate. For steel products, this generally requires that the steel be U.S. melted and poured. For aluminum and copper products, the applicable standard generally requires U.S. smelted-and-cast metal.
• Special Reduced Rates for Certain U.K. Products. Certain qualifying U.K.-origin steel and aluminum products receive reduced Section 232 rates pursuant to the applicable U.S.-U.K. arrangements. Products otherwise subject to the 50% Annex I-A rate may qualify for a reduced 25% rate, while products otherwise subject to the 25% Annex I-B rate may qualify for a reduced 15% rate, provided the applicable U.K. melt-and-pour or smelt-and-cast requirements are satisfied.
• Low Metal Content Exception. Products listed in the annexes, other than goods classified in HTSUS Chapters 72, 73, 74, or 76, are generally excluded from the revised Section 232 duties if they contain less than 15% aggregate weight of the applicable covered metal or metals. CBP has also confirmed that products listed in the annexes but containing no steel, aluminum, or copper are not subject to the duties.
• No “Metals-on-Metals” Stacking. Where a product qualifies as an article or derivative of more than one covered metal, only one Section 232 metals duty applies. CBP has expressly confirmed that Section 232 duties do not stack where products contain combinations of aluminum and steel, aluminum and copper, steel and copper, or all three metals.

Although the revised framework eliminates the need to calculate the value of embedded metal content, product composition remains highly relevant in several important respects. Most notably, the low-metal-content exception continues to require importers to substantiate the percentage by weight of steel, aluminum, or copper contained in covered products. Accordingly, companies claiming eligibility for these exceptions should expect to maintain supporting engineering data, bills of materials, technical specifications, supplier certifications, testing data, or other records sufficient to substantiate the composition and weight of their products.

From an operational standpoint, the revised framework significantly changes where compliance risks arise. Under the prior regime, enforcement disputes frequently centered on how importers calculated the value of steel or aluminum inputs. Under the new system, CBP scrutiny is likely to focus far more heavily on HTS classification decisions, particularly where multiple classifications may reasonably apply or where classification outcomes materially affect Section 232 duty exposure. Importers should also expect increased attention to documentation supporting exceptions and reduced-rate claims, including evidence relating to product composition, weight percentages, and qualifying U.S.-origin metal inputs.

What Importer Should Be Doing Now

Importers should treat the April 2026 revisions as a trigger for a fresh and comprehensive Section 232 review. The revised framework simplifies one important aspect of compliance because companies no longer need to calculate the value of embedded steel or aluminum content. At the same time, however, the revisions fundamentally change the duty base, alter the applicable tariff rates, and place significantly greater emphasis on HTS classification, product composition, sourcing, origin substantiation, and documentation controls.

In light of these changes, importers should consider the following steps:

• Map all imported products against the new annexes. Companies should confirm whether imported products fall within Annex I-A, I-B, II, III, or IV and should not assume that prior Section 232 treatment remains unchanged. CBP guidance states that the revised duties apply to the full customs value of covered steel, aluminum, copper articles, and derivative products effective April 6, 2026.
• Reconfirm HTS classifications. Because the revised framework uses HTS classification to determine the applicable Section 232 rate, classification decisions now directly determine whether a product is subject to 50%, 25%, 15%, 10%, or no Section 232 duty. Companies should pay particular attention to products where multiple classifications may plausibly apply or where classification outcomes materially affect duty exposure.
• Implement heightened classification governance controls. Importers should consider enhanced internal review procedures for high-risk classifications, including escalation protocols for borderline classifications, periodic audits of classification decisions, and greater coordination among engineering, procurement, legal, and trade compliance teams. The revised framework significantly increases the commercial importance of classification accuracy.
• Model the new landed-cost impact. For many derivative products, Section 232 duties now apply to the full customs value of the imported merchandise rather than only the value of the embedded metal content. This change may materially increase tariff exposure for high-value finished goods containing relatively modest amounts of steel, aluminum, or copper.
• Reevaluate sourcing and supply-chain strategies. Becausethe revised framework substantially changes Section 232 duty exposure, companies should reassess sourcing arrangements, supplier locations, manufacturing footprints, and product-design decisions that may have been developed under the prior content-based methodology. In some cases, the revised framework may alter the relative cost advantages associated with particular sourcing strategies or manufacturing locations.
• Identify products that may qualify for the low-metal-content exception. Products listed in the annexes, other than goods classified in Chapters 72, 73, 74, or 76, may fall outside the Section 232 metals tariffs if they contain less than 15% aggregate weight of the applicable covered metal or metals. Companies should gather bills of materials, engineering specifications, testing data, supplier certifications, and weight calculations necessary to support any claimed exception.
• Confirm whether reduced rates are available. Products manufactured using qualifying U.S.-origin or U.K.-origin metal inputs may qualify for reduced Section 232 rates. Importers should confirm whether they can substantiate the applicable melt-and-pour or smelt-and-cast requirements through supplier certifications and supporting origin documentation.
• Review supplier-data collection processes. Although importers no longer need to calculate the value of embedded metal content, companies may still need supplier certifications, composition data, engineering specifications, and origin records to support reduced-rate claims, low-metal-content exceptions, and other Section 232 positions. Importers should confirm that suppliers can consistently provide the required information and that internal systems can capture and maintain it.
• Update HTS classification indexes, ERP systems, and broker instructions. Importers should ensure that brokers are using the correct HTS numbers, Chapter 99 provisions, product flags, origin indicators, and exception claims. Companies should also review whether ERP systems, tariff databases, landed-cost models, and reporting systems accurately reflect the revised Section 232 framework.
• Check for mixed-metal products. CBP has confirmed that products listed as articles or derivatives of more than one covered metal are subject to only one applicable Section 232 metals duty rate, even where the product contains steel, aluminum, and copper together. Companies should review mixed-metal products carefully to ensure the correct treatment is being applied.
• Review transition-period entries and contracts. Importers should examine entries made around the April 6, 2026, effective date, including warehouse withdrawals and in-transit merchandise, to confirm that the revised tariff framework was correctly applied. Companies should also assess whether existing purchase agreements, transfer-pricing structures, or customer contracts negotiated under the prior methodology require adjustment.
• Review FTZ and drawback treatment. Covered products admitted into foreign trade zones after the effective date generally must be entered in privileged foreign status, which may limit the ability to benefit from subsequent tariff reductions or classification changes. Companies should also evaluate whether drawback remains available for affected products and whether revised Section 232 treatment alters existing FTZ or drawback strategies.
• Establish post-entry review and correction procedures. Because HTS classification and exception claims now directly drive Section 232 exposure, importers should implement procedures to identify and correct potential entry errors through post-summary corrections (PSCs), protests, or other available mechanisms where appropriate.
• Assess enforcement exposure. The revised framework is likely to increase CBP scrutiny of HTS classification decisions, reduced-rate claims, low-metal-content exceptions, and origin documentation. Importers should expect increased use of CF-28 requests, audits, investigations, and potential penalty exposure in cases involving unsupported classifications or exception claims. Given the magnitude of the applicable duty rates, the revised framework may also increase False Claims Act and whistleblower risk.
• Build a comprehensive audit file. Even though the revised methodology is operationally simpler in certain respects, importers should maintain robust documentation supporting classification decisions, product composition analyses, origin determinations, claimed exceptions, supplier certifications, broker instructions, and reasonable-care analyses. Companies should assume that CBP may later request documentation supporting the basis for Section 232 treatment.

The revised Section 232 framework for steel, aluminum, copper, and derivative products trades one form of complexity for another. The new system eliminates the difficult and often highly subjective exercise of calculating embedded metal-content value but replaces it with a framework in which HTS classification, product composition, origin substantiation, and supporting documentation now play the central role in determining duty exposure. For some importers, the revised approach will welcome administrative clarity and greater predictability. For others, particularly companies importing high-value finished goods that incorporate steel, aluminum, or copper as only one component among many, the application of Section 232 duties to the full entered value of the product may significantly increase tariff liability.

The revised framework also reflects a broader shift in how Section 232 compliance risk is likely to be enforced going forward. Under the prior regime, disputes frequently focused on how companies calculated and documented the value of embedded metal content. Under the new framework, CBP scrutiny is likely to focus far more heavily on HTS classification decisions, reduced-rate claims, origin documentation, low-metal-content exceptions, and the sufficiency of importer reasonable-care processes. In many respects, the revised methodology transforms Section 232 compliance from primarily a valuation exercise into a broader classification, sourcing, and supply-chain governance issue.

Companies therefore should not view the April 2026 revisions as merely another tariff-rate adjustment. The administration has effectively introduced a new operating model for Section 232 compliance. Importers that respond proactively, including by reassessing classifications, reviewing sourcing strategies, strengthening documentation controls, updating broker instructions and ERP systems, and reevaluating landed-cost assumptions, will be best positioned to manage both the commercial and enforcement risks associated with the revised framework.