Trump Restructures Section 232 Tariffs With Five-Tier Metal Import Framework Taking Effect April 6
A presidential proclamation replaces flat-rate Section 232 duties with a five-tier framework imposing up to 50 percent tariffs on steel, aluminum, and copper imports, effective April 6.
President Donald Trump signed a proclamation on April 2 overhauling the Section 232 tariff framework for steel, aluminum, and copper imports, replacing the existing flat-rate regime with a five-tier duty structure that takes effect on April 6. The restructuring marks the most significant revision to the metals tariff architecture since Section 232 duties were first imposed in March 2018.
The new framework applies tariffs based on the metal composition of finished goods rather than a uniform rate across all covered products. Articles made entirely or almost entirely of steel, aluminum, or copper, such as steel coils and aluminum sheet, will face a 50 percent duty on their full customs value. Derivative articles substantially composed of these metals will carry a 25 percent rate.
Tiered Structure and Exemptions
The proclamation introduces three additional tiers below the top rate. Metal-intensive industrial equipment and electrical grid equipment will be subject to a temporary 15 percent rate through the end of 2027, a provision the administration says is designed to accelerate the domestic industrial buildout currently underway. Products manufactured abroad using exclusively American-origin steel, aluminum, and copper qualify for a 10 percent rate.
Products containing 15 percent or less of the covered metals by value are fully exempted from Section 232 duties under the new rules. This de minimis threshold could benefit importers of electronics housings, composite goods, and other mixed-material products where metal content is incidental.
Shift to Full Customs Value
One of the most consequential technical changes in the proclamation is a shift in how tariffs are calculated. Under the previous framework, duties were assessed based on the metal content within a product. The revised rules apply the Section 232 duty to the full customs value of the imported article, regardless of metal content. For products where metal represents a significant but not total share of the finished good, this change could substantially increase the effective duty paid.
The proclamation also eliminates prior product-specific exceptions and country-specific exemptions that had accumulated since the original 2018 duties, though it includes a carve-out for United Kingdom products composed entirely of UK-origin metal, which remain subject to a 25 percent rate.
Domestic Manufacturing Context
The administration framed the restructuring as a continuation of policies it credits with reviving American metals production. According to the White House fact sheet, the United States became the third-largest steel-producing nation in 2025, and over four million tons of new crude steelmaking capacity are expected to come online within the next two years. Planned facilities in West Virginia, Arkansas, and South Carolina are cited alongside what the administration describes as the first new aluminum smelter announced in decades, a joint venture in Oklahoma.
The proclamation builds on a series of prior Section 232 actions, including the original steel and aluminum duties under Proclamation 9704 and 9705 in March 2018, and the extension of Section 232 authority to copper imports under Proclamation 10962 in July 2025.
Compliance Implications
Importers will need to adapt to new documentation requirements under the revised framework. According to KPMG’s analysis, businesses must now provide percentage metal composition data, country of metal origin documentation, supplier certifications, bills of materials, and melt-and-pour statements to customs authorities.
The Department of Commerce and the U.S. Trade Representative retain authority to add derivative articles to the tariff schedule on a rolling basis when they jointly determine that imports of those products threaten national security, though the proclamation formally ends the prior Section 232 inclusion process for derivative products.
The new rules take effect at 12:01 AM ET on April 6 for all goods entered into the United States after that time.