Proclamation 11032, signed June 1, 2026 and effective June 8, moved Section 232 duties onto the full customs value of the imported article: 50 percent on covered steel, aluminum, and copper articles, 25 percent on derivative products predominately composed of those metals, and a combined 15 percent for products of listed trading partners. The hinge is the US-content test. A product's metal counts as entirely US-melted steel or US-smelted aluminum or copper if that metal accounts for at least 85 percent of the weight of the metal in the product. Hit 85 percent by weight and the whole part counts as American metal. Miss it, and the full rate applies. CBP's filing guidance is CSMS 68253075 from April 3, 2026, updated by CSMS 68855869 on June 5.
The rate stack, as it stands
The headline rates are only the start, because the chapter 99 headings split by origin of the metal. Heading 9903.82.02 carries the 50 percent rate on covered articles and main derivatives. UK articles and derivatives, where the metal was melted and poured or smelted and cast in the UK, sit at 25 and 15 percent under 9903.82.04 and 9903.82.05. Derivatives whose metal was melted and poured or smelted and cast in the United States carry a 10 percent floor under 9903.82.07 and 9903.82.08. The reduced Annex I-C rates run only until 11:59 p.m. eastern on December 31, 2027, and on January 1, 2028 the affected products revert to the full Proclamation 11021 rates.
Two features of the regime catch importers out. First, the duties cannot be waived under a free trade agreement, and drawback is limited, so there is no USMCA escape hatch. Second, antidumping and countervailing duties apply on top of the Section 232 rate, so the stack is MFN plus 301 plus 232 plus AD/CVD where each applies. Quote one clean number and the landed cost is wrong.
Related reading on this site: LandedWatch and LandedWatch cover the neighbouring problems in more depth.
85 percent is a weight test, not a price test
The threshold is the weight of American steel against everything else in the part, not the price of the steel and not the part count. That is why the mill certificate matters more than the invoice. The certificate states where the steel was melted and poured, or where the aluminum was smelted and cast, and the weight of that metal. A supplier who can only confirm the country where the finished product was assembled cannot support a reduced-rate claim, and CBP's guidance is explicit that a wrong claim about US content draws penalties.
The June 2026 change lowered the threshold from 95 percent to 85 percent, which looks like relief until you try to prove it. Most compliance teams do not hold supplier-verified metal origin data, because the answer usually sits with the direct supplier and their supplier, the mill or smelter. The teams that get the lower rate are the ones that asked for mill certs before the entry, not the ones that went looking after CBP asked.
What to get from the supplier before the entry
Ask for three things in writing, and file them with the entry record. The country of melt and pour for steel, or smelt and cast for aluminum and copper, for the metal in the product. The weight of US-origin metal against total metal weight, so the 85 percent test can be calculated rather than asserted. And the mill certificate or smelter statement that supports both, because CBP can ask for the documentation behind the claim and a supplier email is not the same as a mill cert.
Basic steel mill products also need a Commerce import license under 19 CFR Part 360 before the entry summary is filed. Build that step into the ordering calendar, not the filing calendar, because a license that is not in hand when the goods arrive is a delay at the port, and a delay at the port is a missed delivery window.
Frequently asked questions
What counts as US metal under the 85 percent test?
Metal counts as US-melted steel or US-smelted aluminum or copper when that metal accounts for at least 85 percent of the weight of the metal in the product. At or above that threshold, the whole part is treated as American metal for the reduced rate.
Does the 85 percent test use weight or value?
Weight. The proclamation measures the weight of US-origin metal against the total weight of the metal in the product. Price, part count, and assembly location do not enter the calculation.
What happens to the reduced rates after 2027?
The reduced Annex I-C rates expire at 11:59 p.m. eastern on December 31, 2027. On January 1, 2028, the affected products revert to the full Proclamation 11021 rates, so any sourcing decision that depends on the reduced rate has a dated shelf life.
Can Section 232 duties be waived under a free trade agreement?
No. The duties cannot be waived under a free trade agreement, and drawback is limited. USMCA qualifying goods from Canada and Mexico face a 25 percent duty on only the non-US content, which is a different mechanism from a waiver.