A client called me in June about an entry that had gone wrong in a way nobody could explain. The product was a packaging line, invoiced at $184,000, and the steel in it accounted for maybe a sixth of the weight. The duty their broker calculated was roughly four times what the same machine had cost to import in March. Nothing about the machine had changed. What changed was the base the tariff is applied to, and that single change is the most expensive thing to happen to metal-adjacent imports in 2026.
Section 232 has been part of the furniture since 2018, and most importers I work with think of it as a steel-and-aluminium problem belonging to steel-and-aluminium companies. That framing stopped being useful this summer. If you import machinery, furniture, appliances, fixtures, cable, or almost anything assembled with metal in it, the June 2026 proclamation reaches you, and a reporting requirement that took effect today reaches a further set of importers who have never thought of themselves as metals filers at all.
We have covered the sectoral side of Section 232 before, in the guide to the pharmaceutical tariff and its 100% duty, and there is an older explainer on the original steel and aluminium measures that still describes the 2018 architecture accurately. This is not that. This is the mechanics of how the duty is now calculated, which annex your product sits in, and what you must transmit at entry.
What changed, and the date it changed
Proclamation 11032 was signed on 1 June 2026 and took effect on 8 June 2026, amending the framework that Proclamation 11021 had established in April. The American Presidency Project The changes are expressed as temporary, running through 31 December 2027, after which the covered products revert to the earlier rates. I would not plan around that expiry. In eight years of Section 232 practice I have watched more sunset dates get extended than honoured, and a reversion at the end of 2027 is a hope, not a schedule.
Two substantive things happened. The first is the duty base. Section 232 duties on covered articles and their derivatives now apply to the entire customs value of the imported product rather than only to the declared value of the metal inside it. White & Case The second is a threshold change that runs the other way and has been almost entirely lost in the coverage, which I will come to after the arithmetic, because it is the one piece of good news in the document.
The arithmetic, on a real shape of product
Take a derivative article at the 25% rate with a customs value of $100,000 and steel content that the importer can document at 20% of the product's value. Under the metal-content method that governed until 8 June, the duty attached to the $20,000 of steel. Under the full-value method it attaches to the whole $100,000.
| Basis | Dutiable amount | Duty at 25% | Duty at 50% |
|---|---|---|---|
| Metal content only (before 8 June 2026) | $20,000 | $5,000 | $10,000 |
| Full customs value (from 8 June 2026) | $100,000 | $25,000 | $50,000 |
That is a five-fold move on identical goods, and it scales with how little metal your product contains. The counter-intuitive consequence is worth sitting with: the lower your metal content, the larger the multiple by which your duty increases, because the old base was small and the new base is the invoice. My packaging-line client was not an outlier. They were the predictable case.
The practical follow-on is that metal-content documentation, which importers spent 2025 building, lost most of its value overnight for products inside the annexes. Those mill certificates and content declarations still matter for the exclusion I am about to describe, and for origin questions, so do not throw the process away. But if you were funding a content-tracking exercise on the theory that it reduces your duty bill on a covered derivative, that theory expired on 8 June.
The 85% rule, which is relief rather than expansion
Here is the part I have had to point out to nearly every importer who has raised the proclamation with me, because the alerts led with the tariff increase and buried this. The threshold for a product to count as composed entirely of US-origin metal dropped from 95% to 85%. Switzerland Global Enterprise The test is measured by weight of the product's aluminium, steel, or copper content, and the metal has to be smelted and cast in the United States for aluminium and copper, or melted and poured in the United States for steel.
Qualifying takes the article out of scope. So a fabricated assembly using 88% domestic steel by weight, which failed the old 95% test and paid duty on its full value, can now clear the threshold and pay nothing under Section 232. For fabricators sourcing mostly domestic metal with a minority of imported stock, that is a genuine and substantial saving, and it is claimable now.
What it requires is evidence you probably do not have in the right form. The test is weight-based and origin-specific at the melt or the smelt, not at the mill or the supplier. A certificate saying your supplier is a US company proves nothing about where the metal was poured. I have reviewed 2 claims this month where the importer believed they were comfortably over 85% and could document about 60% of the weight to a US furnace. The claim is only as good as the furnace-level paperwork behind it.
Which annex you are in decides your rate
The proclamation sorts covered goods into two annexes carrying different rates, and knowing which one holds your tariff line is the first thing to establish.
- Annex I-A, at 50%. Around 280 tariff classification codes covering primary steel, aluminium, and copper articles together with closely related derivatives.
- Annex I-B, at 25%. Around 410 HTSUS codes covering downstream products, and the list is broader than most importers expect: household articles, cutlery, door hardware, certain automotive parts, machinery.
Read that second list again if you make consumer or industrial goods. Door hardware and cutlery are not products anyone files under a metals mindset, and 410 codes is a large enough net that I now run the annex check on every new tariff line a client onboards, not only the obviously metallic ones.
One important caveat on the 50% figure, because it is no longer the end of the story. A further proclamation in July 2026 created an incentive programme aimed at new investment in US primary aluminium production, under which the 50% duty on primary aluminium products is halved for companies holding approved plans to build, expand, or refurbish domestic aluminium smelters. So the headline rate on a primary aluminium line is not necessarily the rate a given importer pays, and anyone with aluminium in the supply chain should establish whether a supplier or affiliate qualifies before accepting 50% as fixed. This is the first mechanism in the current Section 232 architecture that ties an importer's rate to domestic investment rather than to the product itself, and I expect it to be copied.
Proclamation 11032 also added derivative categories that were previously outside the aluminium and steel measures. The named additions include aluminium lithographic plates and steel racks, along with certain furniture parts. Lithographic plates are a good illustration of how far this reaches from heavy industry. A commercial printer importing plates has, as far as I can tell, never once thought of itself as a party to a metals trade action, and is now squarely inside one.
Copper smelt and cast reporting starts today
The operational item with the nearest deadline is not a rate at all. It is a data requirement, and it takes effect on 30 July 2026.
CBP issued guidance on 15 July 2026 requiring importers of specified copper wire and cable products to transmit country-of-smelt and country-of-cast information through ACE. U.S. Customs and Border Protection The covered classifications are narrow and specific: 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10. On the entry summary line you report the primary country of smelt and the country of cast, with a secondary country of smelt available as an optional field. Imports of US origin are outside the requirement. CBP made the functionality available in the ACE certification environment on 16 July and in production on 30 July.
Where the information genuinely cannot be determined, the guidance permits reporting "OTH" for other. U.S. Customs and Border Protection I want to be careful here, because I have already heard "OTH" described as the easy path, and I think that reading is a mistake in the making. A permitted fallback for genuinely unknowable data is not a permitted default for data you did not bother to request. Origin-of-smelt reporting has a history: the aluminium smelt-and-cast regime has been running for years, and the pattern there was that filers who leaned on the unknown option accumulated a record that became awkward the moment the agency asked how the determination was made. If your entries carry "OTH" across a whole product line, you are asserting, entry after entry, that the origin of the metal in your cable is unknowable. That is a difficult position to hold for long.
Getting furnace-level data out of a supplier
Every part of this regime, the 85% exclusion and the copper reporting alike, ultimately asks the same question: where was the metal melted or smelted, and can you prove it. Most first attempts at asking fail, and they fail in the same predictable way.
- Ask for the mill test certificate, not a statement. A supplier declaration that metal is "of US origin" is a conclusion. The mill or smelter certificate is the evidence, and it names the facility.
- Put it in the purchase order. Requests sent to a sales contact after shipment go nowhere. A documentation clause in the PO, with the certificate as a condition of payment, works because it moves the obligation upstream before the metal is bought.
- Expect distributors to be the hard case. A supplier buying mixed stock from a trader often genuinely does not know the furnace, and no amount of pressure creates a record that was never kept. That is where you either change the sourcing or accept the duty.
- Keep it entry-linked. The certificate has to tie to the specific material in the specific shipment. A general annual letter proves nothing about the reel of cable on the entry CBP is looking at.
Budget more time than feels reasonable. On the last 3 programmes I helped set up, useful furnace-level documentation took between 6 and 10 weeks to start arriving reliably, and the first responses were all conclusions rather than certificates.
The inclusions process cuts both ways
One structural feature of this regime deserves more attention than it gets, because it means your exposure can change without any new proclamation. The Commerce Department established a Section 232 inclusions process by interim final rule effective 30 April 2025, with the first submission window opening on 1 May 2025.
The mechanism lets interested parties petition to have additional derivative products brought inside the tariffs. In practice that means a domestic producer who competes with your imported product can apply to have your tariff line added, and windows recur. I have watched importers treat annex membership as a fixed fact about their product and get caught when a line they had cleared for years was added in a later round.
The same door opens outward. If your product was captured in a way that looks wrong, or the classification sweeping it in does not fit what you actually import, the process is where you make that argument. Either way, the operational point is that somebody in your organisation should be watching the windows rather than discovering the outcome at entry.
Where this sits next to your other tariff exposure
Section 232 duties do not exist alone on an entry, and the interaction is where I see the largest planning errors. A single shipment can carry a 232 metals duty, a Section 301 rate, and an antidumping deposit at once, and the stacking arithmetic decides whether a sourcing change is worth making. If China sits in your bill of materials, the moving piece this autumn is the exclusions timetable, which we walk through in the guide to Section 301 exclusions and what expires in November 2026.
Two recovery mechanisms are worth checking before you accept a higher duty bill as permanent. Duty drawback returns up to 99% of duties paid on goods that are later exported or destroyed, and with a full-value base the amounts now at stake are materially larger than they were in May; the mechanics are in our 2026 duty drawback guide. Deferral through a foreign trade zone changes when the duty is owed, and for goods that are processed and re-exported it can change whether it is owed at all.
One more caution on the compliance side. A higher duty base raises your penalty exposure on the same error, because civil penalties under the customs statute are calculated as multiples of the duty the government was deprived of. An origin or classification mistake that would have carried a modest exposure in May carries a much larger one now, and the mitigation framework that used to soften that outcome is itself being rewritten, as we set out in the CBP penalty mitigation and prior disclosure playbook.
What I would do this week
The sequence I am running with clients right now is short, and it starts with the copper item because that requirement is live as of today.
Pull your entry lines against the 4 copper classifications and establish whether you file any of them. If you do, find out today whether your broker has the smelt and cast fields populated with real data or with "OTH", because that answer tells you whether you have a paperwork task or a sourcing conversation.
Then check every tariff line you import against both annexes, not only the ones you think of as metal. Around 690 codes are in play across the 2 lists, and door hardware sitting in Annex I-B at 25% is the kind of line that gets missed. Where a line is covered, recalculate landed cost on the full customs value and find out whether the products you quoted in the spring are still profitable at the duty you are now paying.
Where you fabricate with mostly domestic metal, test yourself against the 85% threshold properly, at furnace level, because that exclusion is worth real money and the drop from 95% may have moved you inside it. And put the documentation clause into your purchase order template now rather than chasing certificates after the fact, since the evidence has to exist before the shipment does.
Finally, if aluminium appears anywhere in your bill of materials, check the July 2026 smelter-investment programme before you rebuild your landed-cost model, because a halved rate on primary aluminium changes the answer enough to be worth a phone call to your supplier about their investment plans.
This is general information for trade and logistics professionals, not legal advice. Tariff classification, origin, and exclusion determinations turn on specific facts and should be confirmed with qualified customs counsel or a licensed customs broker.