On April 2, 2026, President Trump issued the section 232 full customs value 2026 proclamation, fundamentally restructuring how Section 232 national security tariffs are calculated on imports of steel, aluminium, and copper products into the United States. The proclamation, published in the Federal Register on April 7, 2026, took effect at 12:01 AM EDT on April 6, 2026. The change is structural, not marginal: Section 232 duties now apply to the full customs value of every covered product, not to the value of the metal content within the product. For importers of derivative products with high overall customs values but modest metal content, this is not a small adjustment. It is a duty multiplier that can triple or quadruple the Section 232 liability on a single entry. A copper cable previously dutiable at 50% on its copper content is now dutiable at 50% on the total value of the cable. A fabricated steel assembly previously dutiable on the steel within it is now dutiable on the full invoice price. Every importer affected by section 232 full customs value 2026 who has not yet updated their landed cost model and entry calculation methodology since April 6 may be calculating duty liability incorrectly. This guide explains every change introduced by the section 232 full customs value 2026 proclamation, what the annex structure means for your specific products, what the FTZ and drawback changes require, and what must happen before the June 30, 2026 copper report adds a further layer of complexity.
Section 232 Full Customs Value 2026: The Core Change Explained
Before the section 232 full customs value 2026 change, Section 232 duties on derivative products were assessed on the metal content of the product, not its total customs value. CBP’s Base Metals Center of Excellence had developed a practice of splitting the declared value between metal and non-metal components and applying the Section 232 rate only to the metal portion. A manufactured component with a total customs value of USD 100,000 and 30% copper content attracted Section 232 duty on USD 30,000 of that value. After April 6, 2026, that same component attracts Section 232 duty on the full USD 100,000 customs value. On a 50% tariff rate, the duty on that component moved from USD 15,000 to USD 50,000 per entry.
The proclamation describes this as a correction to ensure tariffs reflect the full customs value rather than an “artificially low foreign price.” CBP’s prior practice of calculating on metal content only was explicitly challenged in litigation at the US Court of International Trade before the proclamation was issued. Importers who received CBP rate-advancement notices in late 2025, before the formal section 232 full customs value 2026 proclamation,, where CBP retrospectively reassessed entries to calculate duty on full value rather than metal content, may have grounds to protest those assessments under the CIT litigation for entries before April 6, 2026. For entries on or after April 6, 2026, the full value basis is the operative law and is not subject to the pending litigation.
The Four-Annex Structure: Which Rate Applies to Your Product
The section 232 full customs value 2026 proclamation organises covered products into four annexes. Which annex your product falls into determines your applicable tariff rate and whether any reduced rate or exclusion applies. The annexes must be checked in sequence. Once your product is classified into an annex, apply only that annex’s rules:
Work through the annexes in order. The first annex that matches your product classification determines your rate. Do not apply more than one annex to the same product.
| Annex | Products Covered | Duty Rate (All Countries) | UK Rate | US-Processed Metal Rate | Key Notes |
|---|---|---|---|---|---|
| Annex I-A | Articles made entirely or almost entirely of steel, aluminium, or copper (e.g. steel coils, aluminium sheet, copper rod, copper pipe, copper wire) | 50% on full customs value | 25% for UK-smelted metal | 10% where 95%+ US-processed metal | Russian-origin aluminium: 200%. Russian metal in any product triggers 200% on Annex I-A classification. Check this first |
| Annex I-B | Derivative products substantially but not almost entirely made of steel, aluminium, or copper (e.g. fabricated components, assemblies, electrical equipment with significant metal content) | 25% on full customs value | 15% for UK-smelted metal | 10% where 95%+ US-processed metal | Manufacturing drawback available for Trade Agreement Partner products (UK, EU, Japan, South Korea, Mexico, Canada) with qualifying metal origin. As of current CBP guidance only |
| Annex II | Products explicitly removed from Section 232 scope entirely under the April 2026 proclamation | Zero. No Section 232 duty applies | Not applicable | Not applicable | Check Annex II before assuming continued liability. Products that were dutiable before April 6 may have been removed. Hundreds of products were removed from scope |
| Annex III | Certain metal-intensive industrial equipment and electrical grid equipment | Combined Column 1 MFN rate plus Section 232 capped at 15% through December 31, 2027 | Same cap applies | Same cap applies | Where Column 1 MFN rate already equals or exceeds 15%, no additional Section 232 duty is added. After December 2027, transitions to Annex I-B rates |
| Annex IV | Products with less than 15% steel, aluminium, or copper by total weight, not classified under HTS Chapters 72, 73, 74, or 76 | Zero. Excluded from Section 232 | Not applicable | Not applicable | First check to perform for complex assemblies and consumer products with incidental metal content. If under 15% by weight and outside Chapters 72-76, no Section 232 applies |
What Changed for FTZ Operators From April 6
Foreign Trade Zone operators face a material change to their Section 232 treatment under the April 2026 proclamation. Every covered product admitted to a US Foreign Trade Zone on or after April 6, 2026 must be admitted under privileged foreign status as defined in 19 CFR 146.41, unless the product qualifies for domestic status under 19 CFR 146.43. Privileged foreign status means the product’s duty liability is locked in at the rates applicable at the time of admission. Any product admitted under privileged foreign status before April 6, 2026 will be subject to the ad valorem rates applicable to its HTSUS classification upon withdrawal for consumption, including the April 6 changes where those apply.
The practical consequence: FTZ operators who had developed tariff planning strategies around zone manipulation, where goods could be processed or transformed within the FTZ to qualify for a lower rate upon withdrawal, have significantly reduced flexibility under the new rules. The mandatory privileged foreign status admission eliminates the ability to defer the classification and valuation decision to the point of withdrawal. Every covered product must be assessed at entry into the zone, not at the point of consumption entry. Under section 232 full customs value 2026, FTZ operators should conduct an immediate audit of their existing zone inventory admitted before April 6 under prior status assumptions and model the Section 232 duty exposure on withdrawal for all post-April 6 admissions under the new full-value methodology.
Drawback Under Section 232: What Survived and What Did Not
The section 232 full customs value 2026 proclamation significantly curtails duty drawback availability for Section 232 duties. General drawback is eliminated entirely for Section 232 metals duties. Only manufacturing drawback under 19 U.S.C. §1313(a) and (b) survives as of current CBP guidance, and only for a narrow category of qualifying products. Confirm eligibility with your drawback specialist before removing any Section 232 duty from your drawback programme:
- Available: Manufacturing drawback for Annex I-B and Annex III articles that are products of Trade Agreement Partners (currently UK, EU, Japan, South Korea, Mexico, and Canada), where the metal content was smelted or cast in the Trade Agreement Partner country or in the United States
- Not available: General drawback (unused merchandise drawback and rejected merchandise drawback) for any Section 232 metals duties. No drawback of any kind is available for Annex I-A products
- Not available: Manufacturing drawback for products from countries that are not Trade Agreement Partners, regardless of their metal origin
For importers who previously relied on duty drawback as part of their cost recovery programme on imported metal articles that were subsequently exported or used in exported manufactured products, this change materially reduces the available recovery. Importers with established drawback programmes should immediately assess which of their covered products remain eligible under the narrowed manufacturing drawback rules and which have lost drawback eligibility entirely under the new proclamation.
Copper Smelt and Cast Reporting: What Is Coming
Country of origin reporting for steel and aluminium has required smelt and pour, and smelt and cast reporting respectively since Section 232 was first implemented. The April 2026 proclamation extends this requirement to copper for the first time. CBP has confirmed that a separate CSMS message will be issued establishing when copper smelt and cast country reporting is required and when the functionality is available in ACE. Importers of copper articles and copper-intensive derivatives should begin building the data infrastructure to capture and report copper smelt and cast country information for every shipment before that CSMS guidance is issued. Importers who reported “unknown” origin for steel and aluminium content have faced automatic application of the 200% Russian-origin duty rate. The same logic is likely to apply to copper. CBP has not yet issued final guidance on the penalty treatment for unknown copper origins, but importers should treat unknown origins as high-risk given that unknown steel and aluminium origins trigger the 200% Russian-origin duty automatically. An unknown smelt and cast country for copper will carry significant financial risk once the reporting requirement takes effect.
The June 30, 2026 Copper Report: The Next Deadline Every Importer Must Plan For
The section 232 full customs value 2026 proclamation contains a built-in escalation mechanism for refined copper specifically. The Commerce Secretary is required to provide the President with a report on domestic copper markets by June 30, 2026. Following receipt of that report, the President may determine whether to impose additional duties on refined copper, an expansion of the current Section 232 copper framework that currently covers only semi-finished copper and copper-intensive derivatives. The Secretary’s prior recommendation, cited in the proclamation, included a phased universal import duty on refined copper of 15% starting in 2027 and 30% starting in 2028. If the President acts on the June 30 report by imposing these additional duties, every importer of refined copper, including copper cathodes, copper anodes, copper concentrates, and other currently excluded copper input materials, will face material new tariff exposure from January 2027 onward.
Importers of copper input materials who are currently not subject to Section 232 should model their landed cost under the scenario where a 15% duty on refined copper is imposed from January 2027. The June 30 report is 44 days away. Planning now costs nothing. Being unaware of the change after it is announced costs significantly more.
Real Example: What the Full Customs Value Change Costs in Practice
This real example shows the commercial impact of section 232 full customs value 2026 on a typical data centre supply chain. A US technology manufacturer imports copper wire harnesses from Mexico for use in data centre power distribution assemblies. Each harness has a total customs value of USD 12,000 and copper content by value of approximately USD 3,600, representing 30% of the total product value. Mexico is a USMCA partner but the harnesses do not qualify for USMCA treatment because the copper in them was smelted in China, failing the rules of origin requirement.
Before April 6, 2026 (metal content basis): Section 232 duty at 50% applied to USD 3,600 copper content value. Duty per harness: USD 1,800. On 500 harnesses per month: USD 900,000 per year in Section 232 duty.
After April 6, 2026 (full customs value basis): Section 232 duty at 50% applied to USD 12,000 full customs value. Duty per harness: USD 6,000. On 500 harnesses per month: USD 3,000,000 per year in Section 232 duty.
Annual duty increase: USD 2,100,000 on this single product line.
This manufacturer had two options that the pre-April 6 methodology made uneconomic but that now become commercially urgent. First, switch the copper wire supplier to a US-smelted source, qualifying the harness for the 10% US-processed metal rate and reducing duty from USD 6,000 to USD 1,200 per harness. Second, apply for USMCA qualification by switching to a copper supplier in a USMCA partner country with metal smelted in North America, eliminating Section 232 exposure on the USMCA-qualifying portion. Neither option was worth pursuing before section 232 full customs value 2026 raised the exposure to USD 3,000,000 per year. Both are worth pursuing when the exposure is USD 3,000,000 per year.
What Most Importers Are Getting Wrong Since April 6
The most common error under section 232 full customs value 2026 is still calculating on metal content only. The most common error since April 6 is importers whose customs brokers have not updated their entry calculation methodology. If your broker was calculating Section 232 duty on metal content before April 6 and has not confirmed a methodology change, your entries since April 6 are being filed incorrectly. CBP will assess the correct full-value duty on liquidation. The difference between what was paid and what should have been paid becomes a retrospective liability with interest.
Assuming the same products as before are still in scope. Annex II removed hundreds of products from Section 232 entirely. A product you have been paying Section 232 duty on for years may have been removed from scope in the April 2026 proclamation. Check Annex II before filing any post-April 6 entry for a product that was previously subject to Section 232. Paying duty on an excluded product is an overpayment.
Not checking for the Annex IV 15% metal content threshold. Products with less than 15% steel, aluminium, or copper by total weight and not classified under Chapters 72, 73, 74, or 76 are excluded under Annex IV. Importers of complex assemblies or consumer products with incidental metal content should verify the 15% threshold against their bill of materials before including Section 232 in their duty calculation.
Continuing general drawback claims on Section 232 duties. General drawback is eliminated for Section 232 metals duties under the April 2026 proclamation. Any drawback programme that previously included Section 232 duties in its recovery calculation through unused merchandise or rejected merchandise drawback is now overclaiming. Only manufacturing drawback remains available for qualifying Annex I-B and Annex III products from Trade Agreement Partners.
Not modelling the June 30 copper report scenario. Importers of refined copper, copper cathodes, copper anodes, and copper concentrates are not currently subject to Section 232. They may be from January 2027 if the President acts on the June 30 Commerce report. A landed cost model that does not include a 15% refined copper duty scenario for 2027 procurement is incomplete for any business with a copper-intensive supply chain.
How to Start This Week
- Pull every active HTS code for which you are currently paying Section 232 duty under section 232 full customs value 2026 and work through the annex structure. Start with Annex II to identify any products that have been removed from scope entirely. Then confirm your Annex classification for remaining products (I-A, I-B, III, or IV exclusion) and verify whether the full-value methodology has been applied by your broker since April 6. Any entry filed after April 6 at metal-content rates rather than full-value rates is a potential underpayment. Our Global Trade Compliance team conducts Section 232 annex classification reviews across active US import portfolios and identifies both underpayments (full-value not applied) and overpayments (products now in Annex II or Annex IV)
- Given section 232 full customs value 2026 eliminated general drawback, audit your drawback programme immediately. If your drawback programme includes Section 232 metals duties in its recovery calculation through general drawback, remove those claims immediately. General drawback of Section 232 duties is no longer available. Continuing to claim it produces incorrect refund applications that CBP will reject and that may trigger penalty attention. Confirm with your drawback specialist which of your products remain eligible for manufacturing drawback under the narrowed rules
- Under section 232 full customs value 2026, review your FTZ admissions since April 6. Confirm that all Section 232 covered products admitted to your FTZ on or after April 6 were admitted under privileged foreign status. Admissions processed under non-privileged or domestic status for covered products may require specific corrective filings with CBP, such as a Type 01 corrective entry or formal protest, before those goods are withdrawn for consumption. The specific procedure depends on the zone operator’s circumstances and CBP port requirements. Confirm the applicable corrective process with your customs broker before attempting any corrections
- Build a copper supply chain map before June 30. For every copper product in your supply chain, identify whether the copper was smelted in a Trade Agreement Partner country, the US, China, Russia, or another origin. This supply chain map is the data you need to assess your exposure if refined copper tariffs are imposed from 2027, to prepare for the copper smelt and cast reporting requirement when CBP issues its CSMS guidance, and to evaluate whether sourcing changes can qualify your copper inputs for reduced rate treatment. Understanding what an Importer of Record does in managing country of origin documentation for metals imports is the foundation of this compliance step. Our IOR services include country of origin tracking and smelt and cast documentation management for steel, aluminium, and copper imports as part of the entry compliance function
How Carra Globe Supports Metals Import Compliance
Carra Globe provides IOR services and Global Trade Compliance for importers of steel, aluminium, and copper products affected by the April 2026 Section 232 full customs value change. Our trade compliance team conducts Section 232 annex classification reviews identifying which annex applies to each product line, whether Annex II exclusions apply, whether Annex IV thresholds exempt any products, and whether the full-value methodology is being applied correctly on every post-April 6 entry. We manage country of origin documentation for smelt and cast reporting for steel and aluminium, and are building the copper smelt and cast data infrastructure ahead of the forthcoming CBP CSMS requirement. For businesses importing metals and metal-containing products from China, Mexico, Canada, Germany, and other major metal-producing economies, our IOR filing capability ensures Section 232 Chapter 99 HTSUS provisions are correctly applied on every entry. For the broader context of the 2026 tariff environment, see our guides to Section 232 pharmaceutical tariffs 2026, US tariff evasion enforcement 2026, and how to reduce import duty in the US legally.
Frequently Asked Questions: Section 232 Full Customs Value 2026
What exactly changed under section 232 full customs value 2026 on April 6?
Section 232 duties now apply to the full customs value of every covered steel, aluminium, and copper product, including derivative products. Previously, CBP applied the duty rate to the metal content value only. A product with 30% copper content and a USD 100,000 customs value previously attracted duty on USD 30,000. From April 6, 2026, it attracts duty on the full USD 100,000. This is the core of section 232 full customs value 2026. It is not a rate change. It is a valuation base change that multiplies the effective duty burden on derivative products with significant non-metal content.
Which products are covered under the section 232 full customs value 2026 proclamation?
Coverage depends on which annex your product falls into. Annex I-A covers pure metal articles at 50% full value. Annex I-B covers substantial metal derivatives at 25% full value. Annex III covers certain industrial and electrical grid equipment capped at 15% through 2027. Annex IV excludes products with less than 15% metal content by weight not classified in Chapters 72, 73, 74, or 76. Annex II lists products removed from scope entirely. Work through the annexes in order for each product. The first annex your product matches is the one that applies.
Can I still claim drawback under section 232 full customs value 2026?
Only manufacturing drawback, and only for a narrow category. General drawback (unused merchandise and rejected merchandise) is eliminated entirely for Section 232 metals duties. Manufacturing drawback survives only for Annex I-B and Annex III products from Trade Agreement Partners where the metal was smelted or cast in a qualifying country. If your drawback programme included Section 232 duties recovered through general drawback, remove those claims immediately and review what remains eligible under the narrowed manufacturing drawback rules.
Does USMCA exempt goods from section 232 full customs value 2026?
No. Section 232 applies regardless of FTA status. USMCA preferential treatment does not exempt goods from Section 232 tariffs. However, USMCA qualification does affect which rate tier applies. Products from Mexico or Canada that qualify as Trade Agreement Partners may access reduced rates where the metal content meets the smelt and cast origin requirements for the partner country. The USMCA exemption that applies to Section 122 does not extend to Section 232.
What is the June 30 copper deadline in the section 232 full customs value 2026 proclamation?
The Commerce Secretary must submit a report to the President on domestic copper markets by June 30, 2026. Following that report, the President may impose duties on refined copper products currently excluded from Section 232, such as copper cathodes, anodes, and concentrates. The Commerce Secretary’s prior recommendation was a 15% duty on refined copper from 2027 and 30% from 2028. This has not been enacted yet. Model your 2027 landed cost under the scenario where refined copper duties take effect from January 2027 before June 30 arrives.
Do steel and copper tariffs stack under section 232 full customs value 2026?
No. The April 2026 proclamation explicitly states that where a product falls within the scope of more than one Section 232 action (steel, aluminium, or copper), only one tariff applies. The product pays the single highest applicable rate, not a combination of two or three rates. This non-stacking rule prevents the Section 232 tariffs from compounding on multi-metal products.