Section 232

New Section 232 Action: What the June 2026 Aluminum, Steel & Copper Proclamation Means for Your Imports

Topline summary: On June 1, 2026, President Trump amended the Section 232 tariff framework for aluminum, steel, and copper. Importers of agricultural, industrial, and mobile equipment may qualify for temporarily reduced rates of 10–15%, while certain furniture parts, lithographic plates, and steel racks are newly dutiable for the first time. With a December 31, 2027, sunset on all temporary reductions, importers should audit their HTS classifications now to avoid overpaying or underpaying.

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” amending the April 2026 Section 232 framework (Proclamation 11021). U.S. Customs and Border Protection (CBP) followed on June 5 with implementation guidance in CSMS #68855869. The changes take effect for goods entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 a.m. ET on June 8, 2026

This is not a uniform tariff cut. The proclamation does two opposite things at once. It reduces Section 232 rates on a large block of machinery and equipment, while simultaneously adding new products to the duty regime for the first time. If you import equipment, the change may help you. If you import certain furniture parts, lithographic plates, or steel racks, you may have just become newly dutiable.  

What Changed on June 8 

  1. New products […]

Department of Commerce Issues New Duty-Free Code for 232 Tariffs 

On April 27, 2026, the Department of Commerce published a Federal Register notice adding a new duty-free code in the Harmonized Tariff Schedule of the United States (HTSUS). The addition resolves a discrepancy for goods classified under HTSUS Chapters for steel, aluminum, and copper that were subject to 232 tariff classification even though they did not contain any of these elements. The provision, subheading 9903.82, applies retroactively to April 6, 2026. 

Recent 232 Developments 

This notice is the latest in a series of adjustments to 232 tariffs on steel, copper, iron, and aluminum.  

On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. Key elements of the proclamation include: a tiered tariff structure and some products exempt from Sec. 232 tariffs, and manufacturing drawback claims. Read more here. 

CBP has attempted to help importers navigate 232 tariffs. The agency recently published  FAQs and CSMS messages on steel and aluminum about how to calculate and report the value of the steel and aluminum content of steel and aluminum derivative articles.  

232 has been a hot topic at the Court of International Trade (CIT) as well. There is a current case challenging how CBP has been valuing and […]

By |2026-04-30T11:25:15-04:00April 30, 2026|Import, tariffs|0 Comments

New Executive Order Adjusting Imports of Aluminum, Steel, and Copper into the United States

Authors:

Jennifer Diaz, President, Diaz Trade Law
Amber Pirson, Attorney, Diaz Trade Law

On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. 

Key elements include: a tiered tariff structure and some products exempt from Sec. 232 tariffs, effective at 12:01 am on April 6, 2026; and manufacturing drawback claims.  

Generally, tariffs will be assessed to the full value of imported products, “regardless of their metal content,” with reduced rates for certain products from the United Kingdom (UK) and the same 200% ad valorem duty for subject metal articles from Russia. 

  • Aluminum and steel articles, most copper articles, and certain derivative articles of aluminum and steel…  
    • 50%, unless either the 25% or 10% rates listed below can apply. 
      • 25% for UK products, the aluminum content of which is composed entirely of aluminum that was smelted or most recently cast in the UK, or the steel content of which is composed entirely of steel that was melted and poured in the UK. 
      • 10% for derivative articles, steel or copper content, when the metal content was smelted and cast in the U.S. 
  • For certain copper and […]

BIS Initiates 232 Investigations of Pharmaceuticals and Semiconductors

The U.S. Department of Commerce Bureau of Industry and Security (BIS) announced the initiation of investigations into the effects on U.S. national security of imports of pharmaceuticals and pharmaceutical ingredients and imports of semiconductors and semiconductor manufacturing equipment.

The basis of the investigations is Section 232 of the Trade Expansion Act of 1962. Under Section 232, the president can restrict imports of products that are found to threaten to impair national security.

On April 16, BIS published two federal register notices (pharmaceuticals, semiconductors) seeking public comment. Comments are due May 7, 2025.

Pharmaceuticals and Pharmaceutical Ingredients

The scope of the pharmaceutical investigation covers pharmaceuticals and pharmaceutical ingredients, including:

  • Finished drug products
  • Medical countermeasures
  • Critical inputs such as active pharmaceutical ingredients
  • Key starting materials, and derivative products of those items

Among other information, BIS is particularly interested in comments that address:

  • Demand for pharmaceuticals and pharmaceutical ingredients in the United States
  • The extent to which domestic production of pharmaceuticals and pharmaceutical ingredients can meet domestic demand
  • The role of foreign supply chains, particularly of major exporters, in meeting United States demand for pharmaceuticals and pharmaceutical ingredients
  • The impact of foreign government subsidies and predatory trade practices on United States pharmaceuticals industry competitiveness
  • Whether additional measures, including tariffs or quotas, are necessary to protect national security

Interested parties may submit a comment in this proceeding on or before May 7, 2025 at Regulations.gov using ID BIS-2025-0022.

Semiconductors and Semiconductor Manufacturing Equipment

The scope of the semiconductor investigation covers semiconductors, semiconductor manufacturing equipment, and their derivative products, […]

The Latest on Tariffs: Key Information for Importers 

In the last several weeks, the Trump Administration has issued dozens of executive orders impacting the trade community. The Orders impact tariffs, de minimis shipments, steel and aluminum imports, and potentially trade agreements with other countries.

New Tariffs on Mexico, Canada, and China

On February 1, 2025, President Trump first issued a fact sheet and thereafter signed three executive orders imposing new tariffs on imports from CanadaMexico, and China:

  • 25% tariff on imports from Canada
  • 25% tariff on imports from Mexico
  • 10% tariff on imports from China

The tariffs on imports from China went into effect February 4, 2025. The tariffs on imports from Canada and Mexico were initially set to take effect February 4, 2025, but were delayed by one month following commitments made by both countries to secure the border and stop the flow of drugs into the United States.

In a Truth Social post on February 27, President Trump confirmed that the tariffs on Canadian and Mexican goods will go into effect on March 4. He also announced that China will face an additional 10% tariff starting March 4.

On March 3, 2025, President Trump issued an Executive Order increasing tariffs on imports from China from 10% to 20%. The Federal Register Notice for China can be found here.

On March 5, 2025, the Administration announced a temporary one-month pause on automobile tariffs for Mexico and Canada. Subsequently, on March 6, 2025, President Trump temporarily suspended tariffs on certain goods from Canada and Mexico that meet the United States-Mexico-Canada Agreement (USMCA) requirements, effective March 7, […]

By |2025-03-21T17:00:42-04:00March 4, 2025|Canada, China, Countries, Import, Mexico, tariffs|0 Comments
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