The Administration’s Updated Section 232 Proclamation Introduces Several Changes to How Tariffs are Applied to Aluminum Imports

 

The Administration’s updated Section 232 proclamation introduces several changes to how tariffs are applied to aluminum, steel, and copper imports.  The revised framework changes both how duties are calculated and how products are categorized.

At a high level, the most important shift is straightforward: tariffs are now generally applied to the full customs value of the imported product, rather than only the value of the metal content.  That changes how duties are assessed on covered products.

The proclamation also organizes products into multiple annexes that determine applicable tariff rates, exclusions, and temporary treatment, which is where most of the detail sits.

For extruders, Annex I-A includes core aluminum products such as unwrought aluminum, bars, rods, profiles, and certain building products.  These products fall into the 50% tariff category, making this the highest-rate group under the new framework.

Annex I-B covers a broader range of downstream and derivative products.  This includes items such as trailers and trailer parts, aluminum ladders, and HVAC components.  These products are generally subject to a 25% tariff and reflect a wider set of end-use applications where aluminum is incorporated into finished or semi-finished goods.

On the other side, Annex II removes certain products from Section 232 coverage altogether.  This includes categories such as fitness equipment, lighting components, and certain furniture parts.  It also includes a carveout for certain motorcycle-related parts listed in Annex I-B when they are imported exclusively for use in U.S. motorcycle manufacturing.

Annex III is focused on production-related inputs, equipment, and machinery, including parts of dies, parts of furnaces, industrial robots, and machining centers.  Rather than applying a flat tariff, this annex establishes a temporary cap on the combined rate of normal duties plus Section 232 duties through December 31, 2027.  Beginning January 1, 2028, those products move to the Annex I-B rate structure.

There are also a few additional provisions to keep in mind.  The 15% by weight rule applies to many Annex I-B and Annex III products classified outside the core metal chapters.  In those cases, the additional duty applies only if the applicable metal makes up at least 15% of the total weight of the imported article.  If a product is covered under multiple material lists (for example, aluminum and steel), the combined weight of those materials is used to determine whether the 15% threshold is met.

The proclamation also provides a reduced 10% rate for qualifying aluminum products that meet the U.S. smelted and cast requirement for aluminum.

Separately, the existing 200% tariff on Russian primary aluminum remains in place and continues to apply alongside the updated framework.

With respect to stacking, the Section 122 surcharge does not apply on top of Section 232 tariffs.  Existing China Section 301 tariffs and AD/CVD duties continue to apply where applicable.  At this point, it is unclear how any future Section 301 actions may interact with the current structure.

Overall, the updated Section 232 framework changes how tariffs are calculated and places greater importance on product classification, sourcing, and where products fall within the annex structure.

Download the consolidated spreadsheet of the HTS codes for the combined annexes here.