CBP Issues New Guidance on Section 232 Tariffs for Steel, Aluminum, and Copper Imports

Importers, manufacturers, distributors, and customs brokers should be aware of significant changes taking effect June 8, 2026, regarding Section 232 duties on certain steel, aluminum, and copper products and their derivatives.

Recent guidance issued by U.S. Customs and Border Protection provides additional clarity on how these tariffs will be administered, including the treatment of newly covered products, revised duty rates, and updated reporting requirements.

What Importers Need to Know

Several new products are now subject to Section 232 duties beginning June 8, including certain aluminum lithographic plates, steel furniture components, and metal storage rack products. Companies importing these commodities should review their classifications carefully to determine whether additional duties now apply.

The guidance also establishes different duty treatments depending on the product type, country of origin, and the amount of U.S.-origin metal incorporated into the finished article.

Expanded Opportunities for U.S. Content

One notable change is the adjustment to domestic content thresholds.

Previously, importers generally needed to demonstrate that products were made almost entirely from U.S.-origin metal to qualify for certain preferential tariff treatment. Under the revised framework, products containing at least 85% qualifying U.S. aluminum, steel, or copper may now be eligible for favorable treatment in certain situations.

For manufacturers utilizing significant U.S.-origin materials in their production process, this change could create opportunities to reduce overall tariff exposure.

New Reporting Complexity

The updated rules introduce additional compliance requirements for importers and customs brokers.

Depending on the product category, filers may now be required to report:

• Countries where steel was melted and poured
• Countries where aluminum was smelted and cast
• U.S. content calculations
• Non-U.S. content calculations
• Metal weight information for certain entries
• Additional Chapter 99 tariff classifications

For many companies, these reporting requirements will require closer coordination with overseas suppliers to obtain supporting production records and sourcing documentation.

USMCA Products Receive Special Treatment

Certain steel derivative products originating in Canada and Mexico may qualify for special treatment under the U.S.-Mexico-Canada Agreement (USMCA).

However, importers should understand that the rules are far from automatic. Proper valuation of U.S. content versus non-U.S. content will be critical, and entry summaries may require multiple reporting lines to correctly declare tariff liability.

Companies importing manufactured products from Canada or Mexico should review their supply chains carefully to determine whether these provisions may apply.

Increased Risk for Non-Compliance

As tariff programs continue to evolve, importers face growing compliance risks.
Incorrect classification, inaccurate country-of-origin reporting, unsupported U.S. content claims, or missing production data can result in:

• Duty underpayments
• Customs penalties
• Cargo delays
• Post-entry corrections
• Customs audits
• Increased scrutiny of future shipments

Manufacturers and their customers are increasingly finding that international trade compliance is no longer a back-office function but a critical component of supply chain management.

What Businesses Should Do Now

Companies importing products that contain steel, aluminum, or copper should:

1. Review affected HTS classifications.
2. Verify country-of-origin and production information with suppliers.
3. Confirm availability of melt-and-pour and smelt-and-cast documentation.
4. Evaluate whether any products qualify for U.S.-content preferential treatment.
5. Work with their customs broker to ensure proper Chapter 99 reporting.
6. Assess potential duty impacts on future purchasing decisions.

Final Thoughts

The Section 232 tariff landscape continues to become more complex, particularly for manufacturers, distributors, and importers operating global supply chains.

Businesses that proactively review their classifications, sourcing data, and compliance procedures will be better positioned to avoid costly surprises and maintain uninterrupted supply chain operations.

At ARI Shipping Corporation, we help importers navigate evolving customs regulations, tariff programs, trade compliance requirements, customs brokerage, and international logistics challenges. If your company imports products containing steel, aluminum, or copper, now is an excellent time to review your supply chain and ensure your customs processes are aligned with the latest CBP requirements.