Section 232 Derivatives in 2026: 10% to 50% on Full Value

As of November 10, 2026, Section 232 duties on steel, aluminum and copper products are not one rate. Depending on the product and where its metal was melted or smelted, the rate runs from 10% to 50%, and some tiers are set as a combined floor with your normal duty rate. Since April 6, 2026, every tier applies to the full customs value of the product, not just the value of the metal inside it. Here is how the tiers work, what counts as a "derivative," how Section 232 stacks with other duties, and where its coverage takes another duty off the entry.

What Changed on April 6, 2026

Section 232 of the Trade Expansion Act of 1962 lets the President adjust imports that threaten national security. In 2026 the steel, aluminum and copper program was rebuilt in steps:

The line that matters most is clause (1) of the April proclamation: the duties "shall apply to the full customs value of the imported product, regardless of metal content." Before that, many derivative products were assessed only on their metal content. Now a machine whose steel is a fifth of its value pays the Section 232 rate on the whole machine.

CBP's filing instructions are CSMS #68253075 (April 3) and CSMS #68855869 (June 5). CSMS is the Cargo Systems Messaging Service, CBP's official channel for trade guidance. CBP's trade remedies page, last modified November 2, 2026, lists no Section 232 metals message after the July 15 copper reporting message, and we found no new metals proclamation in the Federal Register through November 6, 2026.

The Rate Tiers, Heading by Heading

Each tier has its own Chapter 99 heading, reported alongside the product's Harmonized Tariff Schedule of the United States (HTSUS) classification. As of November 10, 2026:

The 15% tiers are floors, not add-ons. Proclamation 11032 says Annex III covered fixed industrial machinery and power equipment, and on June 8 it added agricultural equipment and certain residential HVAC. CBP's heading text says "the sum of the column 1 duty rate and the additional ad valorem rate of duty will be 15%." A product with a 2.5% column 1 (normal duty) rate pays 12.5% under Section 232; one already at 15% or more reports 9903.82.11 and pays nothing extra. From January 1, 2028, Annex III goods move to the 25% Annex I-B rate.

Annex I-C is the mobile-equipment tier. Proclamation 11032 ties it to mobile industrial equipment and machinery. The 15% partners are Argentina, Ecuador, El Salvador, Guatemala, Japan, South Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom and EU member states. For goods qualifying under the United States–Mexico–Canada Agreement (USMCA), non-U.S. content is "the total value of the product minus the value attributable to parts produced in the United States," with a 15% minimum. CBP splits the entry into 9903.82.20 at 25% and 9903.82.21 at 0%, and the 0% line can carry U.S. content only up to 40% of value. By our arithmetic, that cap is what holds the rate at the 15% minimum: 25% of the remaining 60% is 15%. Where more than one interim rate applies, "the lowest applicable rate of duty shall apply."

The U.S.-metal rate needs proof. The 10% rate applies when U.S.-smelted or U.S.-melted metal is at least 85% of the product's aluminum, steel and copper by weight (95% until June 8). You report the country of melt and pour or smelt and cast, and you need supplier records behind it.

What Counts as a "Derivative" Product

A derivative is a steel, aluminum or copper product the government has chosen to list, from a wire harness to a steel rack. The test is the list, not the metal: if your HTSUS number is in an annex, you are in scope. Three rules decide the edges.

No metal, no duty. CSMS #68554727 created 9903.82.01 at 0% for listed articles that "do not contain any aluminum, steel, or copper," back to April 6.

The 15% weight test. Goods outside Chapters 72, 73, 74 and 76 whose covered metal is under 15% of the article's weight go on 9903.82.03 at 0%, with the metal's weight in kilograms reported as a second quantity. Count only the metals the annex names for that line. CBP's example is 8302.10.60, listed under aluminum and steel, so those weights are combined and copper is not.

One metal, one rate. Under clause (9) of Proclamation 11021, a good listed under more than one metal pays "only... once."

The list also moves. The April proclamation replaced the old inclusion request processes with rolling additions decided jointly by the Commerce Secretary and the U.S. Trade Representative, at the 25% Annex I-B rate unless similar articles are in Annex I-A. On August 6, 2026, the Bureau of Industry and Security (BIS) proposed 14 articles, including aluminum powder, brass-wind instruments, floor safes, fire extinguishers, several trailer types, certain cranes and filled steel gas containers. For the containers, the duty "would only apply to the value of the metal container." The notice gave no effective date, and as of November 9, 2026, BIS has published no final notice. Plan for it, but don't file it until it's final.

Copper Tariffs in 2026

Proclamation 11021 puts "most copper articles" in the 50% tier and the copper articles in Annex I-B at 25%; U.S.-smelted copper can qualify for 10% under 9903.82.06. Under CSMS #69252300, since July 30, 2026, four insulated wire and cable classifications (8544.42.10, 8544.42.20, 8544.42.90 and 8544.49.10) must report the primary country of smelt and the country of cast. Since September 14, ACE (the Automated Commercial Environment, CBP's entry system) rejects those entry summaries without it. Our post on the ACE copper smelt and cast error covers that record.

Full Value in Practice: A Worked Example

Take a hypothetical steel-framed product entered at $200,000, with $40,000 of steel in it and a 2.5% column 1 rate. Section 232 under each tier, by our arithmetic:

• Annex I-A at 50%: $100,000.
• Annex I-B at 25%: $50,000.
• Annex III, 15% combined: a 12.5% add-on, $25,000, plus $5,000 of column 1 duty.
• Annex III with qualifying U.S.-melted steel, 10% combined: a 7.5% add-on, $15,000.

The $40,000 of steel appears nowhere. Which annex the HTSUS number sits in now matters more than the bill of materials. The exception is the weight test: outside Chapters 72, 73, 74 and 76, metal share by weight can still take a product to 0%.

How Section 232 Stacks With Other Duties

Our 2026 tariff stacking guide covers the general mechanics. For Section 232 metals:

• Column 1 (MFN) duty. The 50%, 25% and flat 10% tiers add to it. The Annex III floors and Annex I-C partner rate instead raise it to a combined 15% (or 10%), or add nothing.
• AD/CVD. CBP's April and June messages say antidumping, countervailing and other applicable duties must still be reported.
• The 2018–2019 China Section 301 duties. Nothing in the metals proclamations or CBP's metals messages we reviewed exempts a good from them, and CBP's filing sequence puts Section 301 and Section 232 numbers on the same line.
• Other metals. Under the one-metal rule, steel, aluminum and copper rates don't stack on each other.

Where Section 232 Coverage Works as an Exemption

Two other programs exempt Section 232 metal goods, but each exemption is written by heading number, not by "anything with metal in it."

The forced-labor Section 301 duty. Since July 24, 2026, USTR's forced-labor action has added a country-specific duty on products of 60 economies. U.S. note 52(f), as published in the July 28 Federal Register notice, says it does not apply to "articles of aluminum, of steel or of copper" or to derivative aluminum and steel articles "provided for in headings 9903.82.02 and 9903.82.04-9903.82.26." The claim goes under 9903.05.90, per CSMS #69326983.

That range leaves out 9903.82.01 (no metal) and 9903.82.03 (under 15% by weight). A product that drops out of Section 232 on the weight test falls outside that range too, so it will usually owe the forced-labor duty unless another exemption applies. The reverse also happens: an Annex III product reporting 9903.82.11 owes no Section 232 duty but sits inside the exempt range as written. And the text names copper articles, but its derivative language names only aluminum and steel derivatives. If you import copper-containing derivatives outside Chapter 74, confirm how your filer reads that before claiming it. Our forced-labor tariff page covers the rest of the exemption list.

The Section 122 surcharge, February 24 to July 24, 2026. The 10% surcharge applied from 12:01 a.m. February 24 until 12:01 a.m. July 24, 2026. Heading 9903.03.06 exempted Section 232 steel and aluminum articles and derivatives and the copper products listed in CSMS #67844987. CBP's June 5 message adds that imports under 9903.82.03, 9903.82.13 and 9903.82.21 "are not eligible." If a metals line from that window was filed with the wrong one of 9903.03.01 or 9903.03.06, a Post Summary Correction (PSC, an electronic correction to an entry summary on file) is the fix while the entry is unliquidated. See our Section 122 surcharge page and our post on the Section 122 refund appeal.

CBP's PSC page, last modified August 6, 2026, allows a PSC "within 300 days from the date of entry" and "up to 15 days of the scheduled liquidation date, whichever date is earlier," on an accepted, paid, unliquidated entry not under CBP review. After liquidation, a protest under 19 U.S.C. 1514 is filed "within 180 days after but not before" the liquidation date. CBP decides each on its merits, neither guarantees a refund, and a review that finds an underpayment corrects that too.

What to Do This Month

1. Map every metal-adjacent HTSUS number to its annex and heading, using the HTS list attached to CBP's June 5 message, not the April one.
2. Check your entries since April 6 for tier errors and for 9903.82.03 claims without a weight on file.
3. Get melt and smelt records for every U.S.-metal or U.K. rate claim. The U.S. test is 85% by weight since June 8.
4. Cross-check exemptions. Lines in 9903.82.02 and .04–.26 from forced-labor economies should carry 9903.05.90; .01 and .03 lines should be checked for the forced-labor duty.
5. Find your liquidation dates before planning corrections, using our guide to checking liquidation dates in ACE. For USMCA goods, document U.S. content under the BIS definition in effect since October 14, 2026.

Only for products in Annex I-A, as of November 10, 2026. Other derivatives pay 25% (Annex I-B), a combined 15% floor (Annex III, and Annex I-C for listed partners), or 10% when the metal was melted or smelted in the United States. Listed articles with no metal, or under 15% metal by weight outside Chapters 72, 73, 74 and 76, pay 0%.

Is Section 232 duty still based on the metal content of a product?
No. Since April 6, 2026, Proclamation 11021 applies the duty "to the full customs value of the imported product, regardless of metal content." The proposed filled steel containers would be dutiable on the container's value only, but as of November 9, 2026 that proposal is not final.

What is the copper tariff in 2026?
Most copper articles are in the 50% tier, copper articles listed in Annex I-B are at 25%, and copper smelted and cast in the United States can qualify for 10%. Four insulated wire and cable classifications also require smelt and cast country reporting, and since September 14, 2026, ACE rejects those entry summaries without it.

Are Section 232 goods exempt from the forced-labor Section 301 tariff?
Most Section 232 metal goods are, through 9903.05.90, but the exemption follows the heading numbers in U.S. note 52(f): articles of aluminum, steel or copper, and aluminum and steel derivatives under 9903.82.02 and 9903.82.04 through .26. Goods reported under the 0% headings 9903.82.01 and .03 fall outside that range.

How We Help

Section 232 entries now turn on which annex and tier a product falls in, and those calls are worth getting right before the entry is filed. We help in four ways:

• Clear. We file metals entries with the right tier, Chapter 99 lines and exemption claims. Self-filing with our ABI-certified software is $30 per entry, and full brokerage is $100–$250 per entry.
• Consult. A licensed broker maps your HTSUS numbers to their annexes and reviews your entries since April 6, line by line.
• Comply. We file Post Summary Corrections at $150 per PSC entry, up to 10 lines, for tier errors, missed exemptions and Section 122-window lines, and help you build the supplier melt and smelt file.
• Automate. For importers who self-file, our ABI software's built-in validation catches bad entry data before it goes to CBP.

If you import anything made of steel, aluminum or copper and haven't checked your tiers since June 8, talk to our team.