Update, 28 July 2026: The full-value basis introduced on 6 April 2026 remains the operative rule, and a follow-on proclamation of 1 June 2026 (effective 8 June) has since amended the framework: it lowered the US-origin metal threshold from 95% to 85%, added a new Annex I-C for mobile industrial equipment, expanded the reduced 15% rate to more equipment categories, and broadened preferential rates well beyond the UK. This guide reflects those changes.
The one still-moving piece is refined copper: the Commerce Secretary’s market update was due by 30 June 2026, after which the President may decide on the recommended phased duty. As of this update that decision has not been announced and refined copper remains exempt, so the 2027 scenario below is one to model, not a duty in force.
On 2 April 2026, President Trump issued the proclamation that restructured how Section 232 national security tariffs are calculated on imports of steel, aluminium, and copper. Published in the Federal Register on 7 April and effective at 12:01 a.m. EDT on 6 April 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 it.
For importers of derivative products with high overall value but modest metal content, this is a duty multiplier that can triple or quadruple Section 232 liability on a single entry. A copper cable once dutiable at 50% on its copper content is now dutiable at 50% on the total value of the cable. Any importer who has not updated their landed cost model and entry methodology since 6 April may be calculating duty incorrectly. This guide explains the change, the amended annex structure (now including Annex I-C from the June proclamation), the FTZ and drawback rules, and where the copper timeline now stands.
Section 232 Full Customs Value: At a Glance
- What changed: from 6 April 2026, Section 232 duty applies to a product’s full customs value, not just its metal content.
- The effect: derivative products with high value and modest metal content can see duty triple or quadruple on a single entry.
- The annexes: six annexes set the rate, from 50% (pure metal) through 25% (derivatives) and a new I-C for mobile equipment, to capped or zero (excluded). Check them in order.
- US-content relief: since 8 June 2026, the threshold to qualify as US-made metal dropped from 95% to 85% by weight, widening access to the 10% reduced rate.
- FTZ and drawback: covered goods must enter an FTZ under privileged foreign status, and general drawback of Section 232 duty is eliminated.
- Copper watch: a refined-copper duty (15% from 2027, 30% from 2028) is recommended but not yet decided, and refined copper is still exempt.
The Core Change Explained
Before this change, Section 232 duty on derivative products was assessed on the metal content, not the total customs value. CBP’s Base Metals Center of Excellence split the declared value between metal and non-metal components and applied the Section 232 rate only to the metal portion. A component with a total customs value of 100,000 dollars and 30% copper content attracted duty on 30,000 dollars. After 6 April 2026, that same component attracts duty on the full 100,000 dollars, so at a 50% rate the duty moved from 15,000 to 50,000 dollars per entry.
The April 2026 proclamation frames this as a correction to ensure tariffs reflect full customs value rather than an artificially low metal price. CBP’s prior metal-content practice had been challenged in litigation at the Court of International Trade before the proclamation issued. Importers who received CBP rate-advancement notices in late 2025, where CBP retrospectively reassessed entries on full value, may have grounds to protest those assessments for entries before 6 April 2026. For entries on or after 6 April, the full-value basis is the operative law and is not subject to that pending litigation.
The Annex Structure: Which Rate Applies
The framework organises covered products into six annexes, expanded by the June 2026 proclamation, and the annex your product falls into determines the rate and whether any reduction or exclusion applies. Work through them in order: the first annex that matches your product classification governs, and you do not apply more than one to the same product. The temporary rates in Annex I-C and the expanded reduced categories run through 31 December 2027, after which products revert to the standard rates.
| Annex | Products covered | Rate (full value) | Key notes |
|---|---|---|---|
| I-A | Articles made entirely or almost entirely of steel, aluminium, or copper (coils, sheet, rod, pipe, wire) | 50%; 10% where 85%+ US-processed metal | Russian-origin aluminium or Russian metal triggers 200%. Check this first. |
| I-B | Derivative products substantially but not almost entirely metal (fabricated components, assemblies, electrical equipment) | 25%; 10% where 85%+ US-processed metal | Manufacturing drawback available for Trade Agreement Partner products with qualifying metal origin. |
| I-C (new, June 2026) | Mobile industrial equipment and machinery: forklifts, earth-moving equipment, non-agricultural tractors, mobile cranes (28 HTSUS codes, Chapters 84 and 87) | 25% standard; 15% for framework partner economies; 10% for 85%+ US metal; value-based formula for USMCA goods | Temporary through 31 Dec 2027, then reverts to Annex I-B rates. |
| II | Products explicitly removed from Section 232 scope | Zero | Hundreds of products were removed. Check here before assuming continued liability. |
| III | Certain fixed industrial machinery and power equipment (June proclamation also drops agricultural equipment and some residential HVAC to this 15% tier) | MFN plus Section 232 capped at 15% through 31 Dec 2027 | Where MFN already meets or exceeds 15%, no extra 232 applies. Then transitions to I-B rates. |
| IV | Products under 15% steel, aluminium, or copper by weight, outside HTS Chapters 72, 73, 74, 76 | Zero | First check for complex assemblies with incidental metal content. |
Reduced rates are not limited to the UK. The June proclamation extended preferential treatment to a set of roughly 37 framework partner economies, including the EU, Japan, South Korea, Switzerland, Taiwan, and several others, which access the 15% tier under Annex I-C and reduced rates elsewhere where the metal-origin conditions are met. Because classification order determines the outcome, checking Annex II and Annex IV first can still reveal that a product long treated as dutiable is now excluded entirely.
What Changed for FTZ Operators
Foreign Trade Zone operators face a material change. Every covered product admitted to a US FTZ on or after 6 April 2026 must be admitted under privileged foreign status as defined in 19 CFR 146.41, unless it qualifies for domestic status under 19 CFR 146.43. Privileged foreign status locks duty liability in at the rates applicable at the time of admission, so the classification and valuation decision can no longer be deferred to the point of withdrawal.
The practical consequence is that FTZ operators who built tariff planning around zone manipulation, transforming goods within the zone to qualify for a lower withdrawal rate, have far less flexibility. Every covered product is now assessed at entry into the zone, not at consumption. Operators should audit existing zone inventory admitted before 6 April under prior assumptions, and model the full-value Section 232 exposure on withdrawal for all post-6 April admissions.
Drawback: What Survived and What Did Not
The proclamation significantly curtails duty drawback 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, and only for a narrow category. Confirm eligibility with your drawback specialist before removing any Section 232 duty from a drawback programme.
- Available: manufacturing drawback for Annex I-B and Annex III articles that are products of Trade Agreement Partners, where the metal was smelted or cast in that partner country or in the US.
- Not available: general drawback (unused merchandise and rejected merchandise) for any Section 232 metals duty, and no drawback of any kind for Annex I-A products.
- Not available: manufacturing drawback for products from countries that are not Trade Agreement Partners, regardless of metal origin.
For importers who relied on drawback to recover duty on metal articles later exported or used in exported products, this materially reduces available recovery. Assess immediately which covered products remain eligible under the narrowed manufacturing rules and which have lost eligibility entirely.
Is your broker still calculating Section 232 on metal content? If so, your entries since 6 April are being filed wrong, and CBP will assess the full-value duty on liquidation with interest. Carra Globe runs annex classification reviews to catch both underpayments and overpayments, and acts as importer of record across 175+ countries.
Copper Smelt and Cast Reporting, and the Refined Copper Question
Country-of-origin reporting for steel and aluminium has required smelt-and-pour and smelt-and-cast reporting since Section 232 began. The April 2026 proclamation extends this to copper for the first time. CBP has said a separate CSMS message will establish when copper smelt-and-cast reporting is required and when the ACE functionality is available, with current guidance published on the CBP Section 232 tariffs page. Importers of copper articles and copper-intensive derivatives should build the data infrastructure to capture and report copper smelt-and-cast origin now, ahead of that guidance.
This matters because importers who reported unknown origin for steel and aluminium content have faced automatic application of the 200% Russian-origin rate. The same logic is likely to apply to copper. CBP has not issued final guidance on the penalty treatment for unknown copper origins, but an unknown smelt-and-cast country should be treated as high-risk once the requirement takes effect.
On refined copper itself, the proclamation built in an escalation mechanism. The Commerce Secretary was required to deliver an update on domestic copper markets, including refining capacity, by 30 June 2026, after which the President may decide whether to impose the recommended phased duty on refined copper of 15% from 1 January 2027 and 30% from 1 January 2028. That expansion would reach refined copper inputs currently outside Section 232, including cathodes, anodes, and concentrates.
As of this update, the decision has not been announced and refined copper remains exempt, so importers of copper input materials should model their 2027 landed cost under the 15% scenario rather than treat it as either enacted or ruled out.
What the Full-Value Change Costs in Practice
Consider a US technology manufacturer importing copper wire harnesses from Mexico for data centre power distribution. Each harness has a total customs value of 12,000 dollars and copper content of about 3,600 dollars, roughly 30% of value. Mexico is a USMCA partner, but the harnesses do not qualify for USMCA because the copper was smelted in China, failing the rules of origin.
- Before 6 April (metal-content basis): 50% on 3,600 dollars is 1,800 dollars per harness, or 900,000 dollars a year on 500 harnesses a month.
- After 6 April (full-value basis): 50% on 12,000 dollars is 6,000 dollars per harness, or 3,000,000 dollars a year. An annual increase of 2,100,000 dollars on one product line.
Two options that the old methodology made uneconomic are now commercially urgent. Switching to a US-smelted copper source qualifies the harness for the 10% US-processed rate, cutting duty to 1,200 dollars per harness. Alternatively, qualifying for USMCA by sourcing copper smelted in North America eliminates Section 232 on the qualifying portion. Neither was worth pursuing when exposure was 900,000 dollars; both are worth pursuing at 3,000,000 dollars.
What Importers Are Getting Wrong Since April 6
- Still calculating on metal content. If your broker has not confirmed a methodology change, entries since 6 April are being filed wrong, and the shortfall becomes a retrospective liability with interest on liquidation.
- Assuming the same products are in scope. Annex II removed hundreds of products entirely. A product you have paid duty on for years may now be excluded, so check Annex II before filing.
- Missing the Annex IV 15% threshold. Products under 15% metal by weight and outside Chapters 72 to 76 are excluded. Verify the threshold against your bill of materials.
- Continuing general drawback. General drawback of Section 232 duty is eliminated, so any programme still claiming it is overclaiming and risks rejection and penalty attention.
- Not modelling the refined copper scenario. A landed cost model without a 15% refined-copper scenario for 2027 procurement is incomplete for any copper-intensive supply chain.
How to Start This Week
- Work every active HTS code through the annex structure. Start with Annex II for removed products, then confirm the annex for what remains and check whether the full-value method has been applied since 6 April. Any post-6 April entry at metal-content rates is a potential underpayment.
- Audit your drawback programme. Remove any Section 232 general drawback claims immediately, and confirm with your specialist which products remain eligible for manufacturing drawback under the narrowed rules.
- Review FTZ admissions since 6 April. Confirm all covered products were admitted under privileged foreign status, and check the corrective procedure with your broker for any that were not, before those goods are withdrawn.
- Build a copper supply chain map. For every copper product, identify whether the copper was smelted in a Trade Agreement Partner, the US, China, Russia, or elsewhere. This is the data you need for smelt-and-cast reporting, for reduced-rate qualification, and for the refined-copper scenario. Our IOR service includes country-of-origin tracking and smelt-and-cast documentation for metals imports.
How Carra Globe Supports Metals Import Compliance
Carra Globe provides IOR services and Global Trade Compliance for importers of steel, aluminium, and copper affected by the full-value change. Our team runs Section 232 annex classification reviews, identifying which annex applies to each product line, whether Annex II or Annex IV exclusions apply, and whether the full-value method is being applied correctly on every post-6 April entry.
We manage country-of-origin documentation for smelt-and-cast reporting on steel and aluminium, and are building the copper smelt-and-cast data infrastructure ahead of CBP’s forthcoming CSMS requirement. For importers of metals and metal-containing products from China, Mexico, Canada, Germany, and other major producers, our filing capability ensures the Section 232 Chapter 99 provisions are applied correctly on every entry.
For the wider 2026 tariff picture, see our guides to the Section 301 tariffs, the Section 301 electronics exemption, and how to reduce import duty in the US legally.
Frequently Asked Questions: Section 232 Full Customs Value 2026
What is Section 232 and how does it differ from Section 301?
Section 232 imposes tariffs on national-security grounds, currently on steel, aluminium, and copper. Section 301 targets unfair foreign trade practices, such as forced labour or overcapacity, through a USTR investigation.
They rest on different statutes and apply independently, though the forced-labour Section 301 action exempts goods already covered by Section 232 rather than stacking on them. See our guide to the Section 301 tariffs for that side.
What exactly changed on 6 April 2026?
Section 232 duty now applies to the full customs value of every covered steel, aluminium, and copper product, including derivatives. Previously CBP applied the rate to the metal content only.
It is not a rate change but a valuation-base change, so a product with 30% metal content and a 100,000 dollar value now attracts duty on the full amount, not on 30,000.
Which products are covered, and at what rate?
Coverage depends on the annex. Annex I-A covers pure metal at 50%, Annex I-B substantial derivatives at 25%, Annex III certain equipment capped at 15% through 2027, while Annexes II and IV exclude products entirely.
Work through the annexes in order for each product, since the first annex a product matches is the one that applies.
Can I still claim drawback?
Only manufacturing drawback, and only for Annex I-B and Annex III products from Trade Agreement Partners with qualifying metal origin. General drawback is eliminated entirely for Section 232 metals duties.
If your programme recovered Section 232 duty through general drawback, remove those claims now and review what remains eligible under the narrowed rules.
Does USMCA exempt goods from Section 232?
No. Section 232 applies regardless of FTA status, and the USMCA exemption that applied to Section 122 does not extend to Section 232. USMCA qualification can, however, affect which rate tier applies.
Products from Mexico or Canada may access reduced rates where the metal content meets the smelt-and-cast origin requirements for the partner country.
Has the refined copper duty been imposed?
Not yet. The Commerce Secretary’s copper market update was due by 30 June 2026, after which the President may decide on the recommended 15% duty from 2027. For now, refined copper remains exempt.
Because the decision is pending rather than settled either way, model your 2027 copper procurement under the 15% scenario without assuming it will or will not take effect.
Do steel and copper tariffs stack under Section 232?
No. Where a product falls within more than one Section 232 action, only one tariff applies: the single highest applicable rate, not a combination. The proclamation’s non-stacking rule prevents compounding on multi-metal products.
This is distinct from how Section 232 interacts with other regimes, and goods under Section 232 are exempt from the Section 122 surcharge that applied earlier in 2026.
This guide is for informational purposes only and does not constitute legal or customs advice. Section 232 rates, annex classifications, drawback and FTZ rules, and the pending refined-copper decision are subject to change as CBP and the administration issue further guidance. Always consult a licensed US customs broker or trade attorney before filing entries or making valuation decisions.