The Administration issued another update to the Section 232 steel, aluminum and copper tariff program on June 1. The program now reaches a growing list of derivative products and downstream imported goods where aluminum content is part of a larger product.
The June 1 action modifies several of the 232 product annexes and makes temporary adjustments for certain equipment categories. According to the White House fact sheet, certain agricultural equipment and other equipment will be adjusted from a 25 percent tariff to a 15 percent tariff. The action also expands the category of industrial equipment eligible for the temporary 15 percent tariff treatment to include certain mobile industrial equipment, such as bulldozers and forklifts, when imported from trade deal countries eligible for that treatment. These temporary changes are scheduled to remain in place through December 31, 2027.
There were also modifications to the HTS codes covered by the annexes. For aluminum derivatives, the updated list includes several HVAC-related parts, mechanical appliances, transformer and power supply components, and certain liquid crystal device parts. Examples include air conditioning evaporator coils and related parts under 8415.90.8010, 8415.90.8020, 8415.90.8045 and 8415.90.8085, mechanical appliances under 8424.89.90, machinery and parts under 8479.89.9599 and 8479.90.9596, transformer and power supply components under various 8504 subheadings, and parts and accessories for liquid crystal devices under 9013.90.80. The updated Annex list is available here.
Another important change is the threshold for products to qualify as made entirely from U.S. aluminum, steel or copper. That threshold has been modified from 95 percent to 85 percent by weight of the covered metal content.
For AEC members, the broader message is straightforward. Section 232 enforcement continues to expand into downstream products and derivative articles. That makes classification, country of origin, aluminum content, U.S. content and supporting documentation increasingly important.
The Office of the U.S. Trade Representative (USTR) has also announced proposed actions under the Section 301 forced labor investigations. USTR determined that 60 economies have failed to impose or effectively enforce prohibitions on imports of goods made with forced labor. As a result, USTR is proposing additional duties of 10 percent or 12.5 percent on products from those economies, depending on whether the economy has adopted or committed to adopt some form of forced labor import prohibition. Written comments are due July 6, 2026, and public hearings are scheduled for July 7, 2026. An additional 301 investigation on Excess Capacity is ongoing and a proposed action announcement is anticipated soon.
AEC has long supported strong and effective enforcement to ensure that U.S. producers are not forced to compete against dumped, subsidized, illegally transshipped or otherwise unfairly traded products.
Finally, the June 3 Executive Order on Strengthening Customs Enforcement should also be watched closely. The order directs U.S. Customs and Border Protection (CBP) and other agencies to tighten importer of record requirements, increase data and disclosure requirements, strengthen enforcement against forced labor, misclassification, undervaluation and illegal transshipment, and increase penalties for noncompliance.
Taken together, these actions point to a more aggressive enforcement environment. AEC will continue to monitor these developments, evaluate their impact on the aluminum extrusion industry and communicate with members as additional guidance, and details are released.
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