Section 232 Metal Tariffs Overhauled: 50% Duty on Steel, Aluminum, Copper at Full Customs Value
Effective April 6, 2026, the U.S. expanded and restructured Section 232 tariffs on aluminum, steel, and copper — and their derivative products. The most significant change: duties now apply to the full customs value of the imported product, not just the metal content portion. Primary metal articles face a 50% ad valorem rate; derivative articles — including cookware, cutlery, hand tools, and hardware containing 15% or more metal by weight — face a 25% rate. Amazon FBA sellers importing metal-intensive home goods, tools, and kitchenware face a new layer of import costs that stacks on top of existing Section 301 and Section 122 tariffs.
Real-World Impact
Stainless-steel kitchen cutlery (Annex I-B derivative) imported at $10.00 customs value now pays 25% × $10.00 = $2.50 in Section 232 duties applied to the full item price. This $2.50/unit Section 232 cost stacks on top of any existing Section 301 and Section 122 tariff obligations.
Key Points
- Presidential Proclamation effective April 6, 2026: all Section 232 duties on aluminum, steel, and copper now assessed on the full customs value of the product, not just the metal content portion
- 50% rate on primary metal articles (Annex I-A: ~280 HTS codes) — products made entirely or almost entirely of aluminum, steel, or copper including structural steel, wire, rod, pipe, and sheet
- 25% rate on derivative articles substantially composed of covered metals — includes cutlery, cookware, hand tools, hardware, fasteners, bearings, and household metal goods
- 15% de minimis exemption: derivative products where covered metals total less than 15% of total product weight are fully exempt from Section 232 duties
- 10% reduced rate available for products manufactured from exclusively US-smelted, melted-and-poured, or cast metals — requires CBP documentation
- Russian-origin aluminum remains at 200%; UK-origin Annex I-A articles qualify for 25% and UK Annex I-B for 15%
What You Should Do Now
- 1Identify which of your products fall under Annex I-A (primary metals, 50%) vs. Annex I-B (derivative articles, 25%) by reviewing the HTS codes in CBP CSMS #68253075
- 2Verify the covered metal weight percentage for each product: if steel, aluminum, or copper is less than 15% of total product weight, the item is fully exempt from Section 232 duties
- 3Request a supplier letter documenting the percentage of metal content by weight for each SKU — this is the key document to support the 15% de minimis exemption
- 4If your supplier uses US-origin aluminum or steel, obtain documented evidence (melting/casting location) to claim the 10% reduced rate through your customs broker
- 5Update landed cost calculations for all metal-intensive SKUs — Section 232 now stacks on existing Section 301 and Section 122 duties, materially increasing total import costs