Section 232 Steel, Aluminum, and Copper Content Updates

On April 2, 2026, the Whitehouse released an updated fact sheet pertaining to section 232 tariffs on steel, aluminum and copper. The update helps address the confusion and need for interpretation around how to report the content of an item that falls on the section 232 list for steel, aluminum, and copper, as the previous guidance lacked substantial information on how the content should truthfully be reported.

In this new update, not only is there clarification on how to handle content, but an update to the rate that is applied to the product being imported. This is also the first full guidance on how copper should be handled, as previously it was implied that it shared the same method as steel or aluminum.

• Products that are wholly, or almost wholly made of steel, aluminum, or copper, will have a flat duty rate of 50% on the entire value of the article.
• Articles that are on the section 232 derivatives list, substantially made of steel aluminum or copper, will have a flat 25% duty rate applied across the entire value of the article.
• Certain metal-intensive industrial equipment will have a duty rate of 15% applied to the entire value of the equipment.
• Products produced abroad where the material is 100% American steel, aluminum, or copper will have a rate of 10% applied to the entire value of the article.
• Derivatives that are made of 15% or less steel, aluminum, or copper will not be subject to section 232, and the importers will not have to pay the applicable duties listed above.

Prior to this update, the existing guidance stated that for steel and aluminum, the steel or aluminum content of an article should be reported but lacked details explaining what content meant. The Base Metal Center of Excellence shared unofficial guidance on what they believed to be the correct interpretation of the meaning of content, which weighed heavily in CBP’s favor, and they used this to enforce CF28’s and CF29’s requiring that importers follow their instructions. The details shared above help provide clarity and more explicit instructions on how to properly manage imports for section 232 on steel, aluminum, and copper.

Click here to see the newest Annex with applicable HTS numbers and duty rates.

Contributor: George Ciaffone

At Allyn International, we are committed to supporting the global trade community with strategic, forward-thinking solutions to help navigate today’s complex tariff landscape. If you have questions about tariffs or would like to explore strategies to reduce their impact on your business operations, our team is here to help. Contact us today for a consultation at sales@allynintl.com