Navigating the Latest Section 232 Changes: Annex additions, Reduced Rates, and the 85% Threshold. 6/15/2026
Effective June 8, 2026, certain steel, aluminum, and copper products (collectively “Metal Products”) benefit from reduced Section 232 duty rates. The Section 232 duty rules for Metal Products were updated in Proclamation 11021, dated April 2, 2026 (“Section 232 Metals Regime II”), and amended by Proclamation 11032 (the “Proclamation”), which reduced duty rates and exemption requirements for certain Metal Products classified in certain HTSUS codes identified in Annexes to the Proclamation, as summarized below:
- Annex 1-C provides for temporarily reduced rates for certain derivative articles from certain countries
For HTS codes listed under newly established Annex I-C, a 25% rate applies, unless one of the criteria for one of the following exceptions is met:
- A 15% “all in” rate comprised of the Column 1 and Section 232 rate applies if the country of origin of the product is Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union.
- A 10% “all in” rate comprised of the Column 1 and Section 232 rate applies if the product is composed entirely of aluminum that was smelted and cast in the U.S., of steel that was melted and poured in the U.S., or of copper that was smelted and cast in the U.S.
Annex I-C includes agricultural equipment, HVAC systems for residential use, and mobile industrial equipment and machinery, including the following HTSUS codes:
- fork-lift trucks and work trucks (8427.10.40 – 8427.90.00),
- earth-moving machinery (8429.11.00 – 8429.59.50),
- parts (8431.20.00, 8431.42.00, 8431.49.90),
- tractors (8701.10.01, 8701.30.50, 8701.91.50, 8701.92.50, 8701.93.50, 8701.94.50, 8701.95.50), and
- mobile cranes (8705.10.00 – 8705.20.00)
For USMCA-qualifying goods, the 25% only applies to the non-U.S. content of the products, which is the total value of the product minus the value attributable to parts produced in the United States, provided the total effective duty assessed on the imported product is not less than 15% ad valorem.
These changes to Annex I-C apply to goods entered for consumption or withdrawn from the warehouse for consumption, on or after 12:01 a.m. EDT on June 8, 2026, through 11:59 p.m. EST on December 31, 2027.
- Additional HTSUS codes are now listed under Annex III, which benefit from temporarily reduced rates
If the product’s HTSUS is listed under Annex III, it is subject to a 15% “all in” rate comprised of the Column 1 and Section 232 rate until December 31, 2027, unless the product comes from a country that does not have “normal trade relations” with the U.S. (at a 25% rate), or if the all the product’s aluminum content was smelted and cast in the U.S. and steel content was melted and poured in the U.S.
Annex III now covers additional HTSUS codes, including:
- 8415.10.60: Air-conditioning machines, window- or wall-types, incorporating a refrigerating unit and a valve for reversal of the cooling/heating cycle
- 8419.81.50: Cooking stoves, ranges and ovens for making hot drinks or for cooking or heating food
- 8433.51.00: Combine harvester-threshers
- 8479.89.55: Trash compactors with self-contained electric motor
- 8701.30.10: Track-laying tractors, suitable for agricultural use
- 8716.80.10: Farm wagons and carts, not mechanically propelled
- Additions of products to Annex 1-B
For HTS codes listed under Annex 1-B, a 25% rate applies, which now includes aluminum lithographic plates (3701.30.00) and steel racks (9403.20.0082 and 9403.99.9040).
- The threshold to be considered “entirely” of aluminum, steel, or copper was reduced from 95% to 85% weight
The threshold for a product to qualify as made “entirely” of U.S. aluminum, steel, or copper and their derivatives was reduced from 95% to 85% by weight, which is a reduction from 95% for the entries prior to June 8, 2026.
Important Links:
- See CSMS #68855869 for entry reporting guidance.
Roberts & Kehagiaras can assist importers with reviewing their HTSUS classifications and the applicable Annexes to the Proclamation to determine whether their products are subject to Section 232 duties and whether they qualify for a reduced duty rate.
