"Metals tariffs: when a product is caught for what's inside it"

Section 232 duties on steel, aluminium and copper do not stop at raw metal. They reach long lists of derivative products, meaning finished goods that contain those metals. A bracket, a housing, a fastener, a piece of furniture or a cable can be caught.

Since 6 April 2026 the duty applies to the full customs value of a covered product rather than to the value of its metal content. For a product with modest metal content and high total value, that change alone can multiply the duty owed on a single entry.

Why ordinary products get caught

Section 232 began as a measure on metal itself. It was extended repeatedly to cover derivative articles, on the reasoning that importing a finished part made of foreign steel has the same effect as importing the steel.

The derivative lists are published as annexes and identified by tariff classification. They have been expanded and revised several times, and the April 2026 proclamation both added products and removed hundreds of others with low metal content.

The practical consequence is that you cannot know whether your product is covered by looking at what it is. You have to look up its classification against the current annexes.

What changed in April 2026

Three structural changes took effect for goods entered on or after 6 April 2026.

The duty base moved to full customs value. Previously, duty on many derivative articles was calculated only on the declared value of the metal inside them. Now it applies to the entire customs value of the product. This is a valuation change rather than a rate change, and it is the change that surprised most importers.

A weight threshold was introduced. Where the applicable metal is 15% or less of the total weight of the article, Section 232 duty does not apply. There is an important exception: goods classified in chapters 72, 73, 74 and 76 remain covered regardless. If an article contains both steel and aluminium and is flagged for both, the weights are added together before the threshold is applied.

Rates were restructured into tiers. Different tiers apply depending on the classification, the metal content, and whether the metal originated in the United States. Certain metal-intensive industrial and electrical grid equipment received a temporarily capped rate through 2027. Rates have been adjusted again since April, so check the current figure rather than relying on any published summary, including this one.

How to check your product

Work through this in order. Each step needs the previous one.

1. Get the tariff classification confirmed. Everything depends on the ten-digit code. Have your customs broker confirm it rather than estimating from the product description, because classification turns on materials and construction rather than on what the product is called.

2. Check that code against the current annexes. The proclamation annexes list covered articles and derivatives by classification. Some codes are covered, some were removed, some sit in the capped category. CBP publishes implementation guidance through its CSMS messages, and your broker will have access to the current version.

3. If it appears covered, calculate the metal weight. You need the weight of the applicable metal as a proportion of the total weight of the article. If it comes to 15% or less and the article is outside chapters 72 to 74 and 76, it falls outside the measure.

4. Get the evidence before you ship. A claim that your product is under the threshold has to be supported when CBP asks. That means a bill of materials, product specifications, and weight documentation from the factory. Ask for these at purchase order stage. Requesting them after a shipment has been flagged is much harder, and a supplier who cannot produce them leaves you unable to support the claim.

What to ask a supplier for

Add these to the purchase order rather than requesting them later:

• A full bill of materials, naming each material
• The weight of each metal component, and the total weight of the article
• The type and grade of metal used
• Where the metal was melted and poured, or smelted and cast

That last item matters because some tiers depend on the origin of the metal rather than the origin of the finished article. It is also the piece suppliers are least used to providing, so ask early.

Entries before April 2026

CBP's earlier practice of increasing duty on derivative entries has been challenged at the Court of International Trade. Importers who received additional duty bills on entries made before 6 April 2026 may have grounds to file protests.

Protest deadlines run from liquidation and they do not wait for litigation to conclude. If this affects entries you made in late 2025 or early 2026, raise it with your broker or a customs attorney now rather than after the deadline passes.

How this interacts with other duties

Section 232 sits alongside other measures, and the stacking rules differ between them. Some measures apply on top of Section 232. Others specifically exclude goods already covered by it, to avoid duplication.

This is worth checking rather than assuming, because getting the stacking wrong in either direction is expensive. Overpaying is a refund you have to chase. Underpaying is a penalty.

What to do if your product is caught

Check the classification again. Classification disputes are common and a code that is genuinely wrong is worth correcting. This is a technical argument, not wishful thinking, and it should be made with a broker.

Check the weight threshold seriously. Many importers assume they are over it without measuring.

Look at redesign where it is realistic. Reducing metal content below the threshold changes the answer, though only if the product still works and the classification does not change as a result.

Consider a binding ruling. If your position depends on an arguable classification or on the threshold, a ruling from CBP gives you certainty before you commit to volume.

Reprice. If the duty applies and cannot be avoided, it is a cost like any other and it belongs in your landed cost model. What you should not do is discover it after the goods arrive.

The short version

Products get caught by what they contain, not by what they are. The list changes. The duty now applies to the whole value of the article rather than to the metal inside it.

Confirm the classification, check it against the current annexes, and get the bill of materials from your supplier before the goods ship.

Verified August 2026. Next review February 2027. Section 232 coverage, rates and annexes have changed several times and will change again. Confirm current treatment with a licensed customs broker before relying on any figure here.