Proclamation 11021 moved Section 232 steel, aluminum, and copper duties onto the full customs value of the imported article, effective April 6, 2026. The headline rates are 50 percent on primary articles and Annex I-A derivatives, 25 percent on Annex I-B derivatives, and a temporary 15 percent combined rate on Annex III goods through December 31, 2027. The rate matters less than the base: duty is now charged on the value of the finished product, including every non-metal part in it.
The April 6 change was about the base, not the rate
The 50 percent rate itself is not new. Steel and aluminum went to 50 percent on June 4, 2025, with the UK held at 25 percent. What Proclamation 11021 changed, effective April 6, 2026, was what the percentage multiplies. Before that date, the duty on a derivative product applied only to the value of its steel, aluminum, or copper content. After it, the duty applies to the full customs value of the article as entered.
Take the insulated metal panel example trade press worked through when the rule landed. A panel imported at $10 per square foot with 25 percent declared steel content used to carry about $1.25 of Section 232 duty per square foot. Under the new rule the same panel carries about $5.00, because 50 percent now applies to the full $10. Nothing about the panel changed. The rate did not change. The base quadrupled the bill.
That is why landed-cost models built before April are wrong in a way that looks like a pricing error. The duty line in the model is not off by a few points. It is off by the ratio of the product's full value to its metal content, and on a finished good with a small metal share that ratio can be four or five to one.
Three tiers, and the line that decides which one you pay
The current structure runs through HTSUS chapter 99, subchapter III, headings 9903.82.01 through 9903.82.26. Annex I-A covers aluminum, steel, and copper articles plus the main derivative lists, and pays 50 percent. Annex I-B covers copper articles and other derivatives, including prefabricated buildings, HVAC and refrigeration equipment, and steel racks, and pays 25 percent. Annex III gets a temporary 15 percent combined rate through December 31, 2027.
Two carve-outs matter in practice. Goods with 15 percent or less applicable metal content fall under a de minimis threshold inside the program and escape the Section 232 duty, which is a different threshold from the suspended $800 de minimis exemption and should not be confused with it. And the UK keeps its 25 percent rate on steel and aluminum under heading 9903.82.04. Russian-smelted aluminum sits apart from all of this at 200 percent under headings 9903.85.67 and 9903.85.68.
Classification is where importers lose the argument. The annexes are lists, not principles, and a product family name is a guide rather than a scope ruling. The question CBP asks is which annex line the article falls under and where the metal was melted and poured or smelt and cast. Get the annex wrong and the entry is wrong from the first line.
What to fix in your entry before the next shipment
First, re-price every affected SKU on full customs value and check whether the product still makes sense at the new duty. A finished good with 20 percent metal content now pays duty on the other 80 percent too, and that changes the sourcing decision, not just the margin. Second, confirm the melt-and-pour or smelt-and-cast country for the metal, because origin decides which tier and which rate apply. Third, remember there is no drawback on the 50 percent tier, so duty paid on steel and aluminum that is later re-exported does not come back the way other duties do.
Fourth, watch the Federal Register notices. The inclusions process is gone, replaced by rolling additions by notice, which means the annex lists move without a new proclamation. A derivative that was outside scope last quarter can be inside it this quarter. And confirm the position with a licensed customs broker before a sourcing decision, because the annex structure and the country rules interact in ways a rate table alone does not show.
Frequently asked questions
What is the current Section 232 rate on steel and aluminum in 2026?
Fifty percent on primary steel, aluminum, and copper articles and Annex I-A derivatives, 25 percent on Annex I-B derivatives, and a temporary 15 percent combined rate on Annex III goods through December 31, 2027. Since April 6, 2026 the rate applies to the full customs value of the article, not just the metal content.
Does the Section 232 duty apply to the full value or just the metal content?
The full customs value, since April 6, 2026 under Proclamation 11021. Before that date, derivative duties were assessed on the value of the steel, aluminum, or copper content only. The change is why the same product can carry four times the duty with no change in the rate.
Can I claim drawback on Section 232 duties?
No, not on the 50 percent tier. There is no drawback on the Section 232 steel and aluminum duties, so duty paid on metal that is later re-exported does not come back. Check the current CBP guidance for your specific case before assuming any duty is recoverable.
Which HTS lines carry the Section 232 duties?
HTSUS chapter 99, subchapter III, headings 9903.82.01 through 9903.82.26. The main 50 percent line is 9903.82.02. UK-origin steel and aluminum use 9903.82.04 at 25 percent, and Russian aluminum uses 9903.85.67 and 9903.85.68 at 200 percent.