New Section 232 Proclamation Reshapes Tariff Treatment for Aluminum, Steel, and Copper Imports
The Administration’s new Section 232 proclamation makes a major change to how tariffs are applied to covered aluminum, steel, and copper products. The biggest takeaway for members is that covered goods are now generally assessed based on the full customs value of the imported product, rather than only the value of the metal content. The proclamation also reorganizes products into new annexes that determine whether they fall into a 50% tariff bucket, a 25% tariff bucket, a temporary reduced-rate structure, or are removed from scope entirely.
What members should know
Annex I-A identifies products generally subject to a 50% Section 232 tariff on the full customs value of the imported product, unless reduced treatment applies under the proclamation for certain United Kingdom goods. For members, this is the highest-rate bucket and includes core aluminum product categories as well as certain derivative articles. The important practical point is that these products are now generally being assessed on full value, not just the aluminum content, which can materially change overall duty exposure.
Examples relevant to the extrusion industry include:
7601 - Aluminum, unwrought
7604 - Aluminum bars, rods and profiles
7610.10.00 - Aluminum doors, windows and frames
7610.90.00 - Aluminum, structures and parts of structures, nesoi; aluminum plates, rods, profiles, tubes and the like prepared for use in structures
The link to download the spreadsheet with the applicable tariff codes and descriptions is available at the end of this alert.
Annex I-B identifies products generally subject to a 25% Section 232 tariff on the full customs value of the imported product, unless reduced treatment applies under the proclamation for certain United Kingdom goods or qualifying U.S.-metal-content products. This annex is important because it covers a broader range of downstream and derivative products than Annex I-A. In practical terms, Annex I-B captures many fabricated, assembled, and end-use products that may sit farther downstream from primary extrusion production but still carry meaningful tariff exposure under the new framework.
Examples that may be relevant to members include:
8716.39.00 — Trailers and semi-trailers
8716.90.50 — Other parts for trailers and semi-trailers
7616.99.5130 — Aluminum ladders
8415.90.8020 — Air-conditioning evaporator coils and other items
Annex II is the removal list. It takes listed products back out of Section 232 aluminum, steel, and copper coverage under the new proclamation. For members, this annex is important because it shows that not every downstream manufactured or derivative product remains inside the revised tariff structure. In several cases, Annex II removes products that may be relevant to fabricated metal, building product, consumer product, and recreation-related downstream markets. It also includes a specific carveout for certain motorcycle-related parts listed in Annex I-B when they are imported exclusively for use in U.S. motorcycle manufacturing.
Of potential note to extruders and downstream markets, examples include:
9506.91.00 - Fitness and exercise equipment
9405.99.40 - Lighting and illuminated sign parts
9403.99.90.45 - Metal furniture parts
Annex III is the temporary reduction list. It largely appears to cover production-related inputs, equipment, and machinery rather than core aluminum articles. Instead of imposing a flat 25% Section 232 tariff, Annex III creates a temporary cap on the combined rate of normal duties plus Section 232 duties through December 31, 2027. For most listed products, the combined rate tops out at 15%. For qualifying aluminum products that meet the U.S. smelted and cast requirement for aluminum or qualifying steel products that meet the U.S. melted and poured requirement for steel, the combined rate can top out at 10%. For products from countries without permanent normal trade relations with the United States, the rate is 25%. Beginning January 1, 2028, the Annex III treatment ends and those products move to the applicable Annex I-B rates.
Examples called out in this section include:
8207.20.0070 — Parts of dies for drawing or extruding metal
8417.90.00 — Parts of industrial or laboratory furnaces and ovens
8428.70.00 — Industrial robots
8457.10.00 — Machining centers for working metal
Two additional provisions worth noting
First, the proclamation includes a 15% by weight rule for many Annex I-B and Annex III goods that are classified outside chapters 72, 73, 74, and 76. In those cases, the additional duty only applies if the applicable metal makes up at least 15% of the total weight of the imported article. If an article is classified under a code that appears on multiple lists, the aggregate weight of the listed metals applies.
Second, the proclamation provides a reduced 10% rate for qualifying derivative products that meet the U.S. smelted and cast requirement for aluminum or the U.S. melted and poured requirement for steel.
Members should also note that the existing 200% tariff on Russian primary aluminum continues. The proclamation states that aluminum articles and derivative aluminum articles listed in Annex I-A, I-B, or III remain subject to that 200% duty where the goods are the product of Russia, where any amount of primary aluminum used was smelted in Russia, or where the aluminum articles were cast in Russia.
Regarding stacking, the current Section 122 surcharge does not apply on top of Section 232 tariffs. If Section 232 applies to only part of an import, the Section 122 surcharge applies only to the portion not already covered by Section 232. It also remains unclear whether any future new Section 301 action would be written to stack on top of Section 232, so that will need to be evaluated if and when a new action is announced. For now, the key point for members is that the existing China Section 301 tariffs, along with any applicable AD/CVD duties, continue to apply on top of Section 232 where applicable.
In short, the new proclamation expands full-value tariff treatment, sorts products into new annex-based buckets, removes some downstream products from scope, and creates a temporary reduced framework for certain machinery, tooling, and equipment-related lines. Members should pay close attention not just to the tariff rate itself, but also to product classification, the 15% by weight rule, and whether qualifying products meet the U.S. smelted and cast requirement for aluminum.
A list of applicable articles is also available for download in spreadsheet format.
