Steel and Aluminum Tariffs: The Full-Value Rule Change

The steel and aluminum tariff most importers think they understand stopped existing on 6 April 2026. Until that date, a derivative article carrying a small amount of metal paid duty only on the declared metal content, so a machine housing or a furniture frame absorbed a manageable charge. Since Proclamation 11021 took effect, the same duty applies to the full customs value of the finished article, and for many downstream importers the bill multiplied without the rate on paper changing at all.

That single change matters more than the headline percentage. An importer bringing in an assembly worth $100,000 with $12,000 of aluminum in it used to face duty on $12,000. Today the same entry is assessed on the whole $100,000 unless the article qualifies for one of the narrow carve-outs. This guide covers the current Section 232 tariffs rate structure on steel and aluminum, how the annexes decide what you pay, and the origin rules that determine which rate applies. Rates verified against the Federal Register as of 26 August 2026.

Current Rates and Which Annex Your Product Falls Into

Proclamation 11021, published at 91 FR 18201 and effective 6 April 2026, reorganised the whole programme into annexes. The steel tariff an importer actually pays is now decided by which annex an HTSUS code sits in, because the annex fixes both the rate and the basis of assessment. Classification and annex placement have to be checked together rather than in sequence.

Annex I-A covers articles wholly or almost wholly of the metals, which is most of Chapter 72 and 73 for steel and Chapter 76 for aluminum. Annex I-B covers derivative articles that are substantially but not wholly metal. Annex I-C was added by Proclamation 11032 on 8 June 2026 and picked up agricultural equipment, residential HVAC and certain industrial machinery. Annex II lists exclusions, and Annex III caps duty on metal-intensive industrial and electrical grid equipment through 31 December 2027.

The Metal Content Rule Is Gone and Nobody Told the Supply Chain

Before April 2026 the arithmetic rewarded precision. An importer who could document that a pump assembly contained 9% steel by value paid the Section 232 rate on that 9% and the ordinary Column 1 rate on the rest. Entire compliance programmes were built around metal content declarations from suppliers.

Proclamation 11021 removed that. Duty now attaches to the full customs value of the article regardless of how little metal it contains, unless the article appears in Annex II or falls under the 15%-or-less by weight threshold. The declarations still get collected, but for Annex I-B goods they no longer reduce the assessment.

The practical consequence is that a duty model built in 2025 understates 2026 exposure on downstream goods by a wide margin, and the error compounds because the merchandise processing fee is calculated on the same entered value. Importers who have not rerun their landed cost since April are quoting customers from a number that no longer exists. Rebuilding the landed cost on the current basis is the first corrective step.

Melt and Pour, Smelt and Cast: Origin Is Not Where It Shipped From

Section 232 origin for steel is determined by where the metal was melted and poured, and for aluminum by where it was smelted and cast. This is a different test from the country of origin rules that govern marking and preference claims, and the two answers frequently diverge.

A coil melted and poured in one country, rolled in a second and fabricated into a part in a third takes its Section 232 origin from the first. That is why a supplier declaration naming only the country of shipment is not enough to support an entry, and why mill test certificates have become entry documents rather than quality paperwork.

The distinction has real money attached. UK-origin metal sits at 25% under Annex I-A against 50% for everyone else, and derivative articles composed of 85% or more US-origin metal drop to 10%. Two limits on that relief are routinely missed: it applies to derivative articles only, not to primary steel or aluminum, and the 85% figure only took effect on 8 June 2026. Before that the threshold was 95%, and 95% still governs the UK rates. Establishing the true melt origin is the same discipline as any other country of origin determination, with a narrower and more documentary test.

There Is No Exclusion Process Any More

The product exclusion process closed in stages. Proclamations 10895 for aluminum and 10896 for steel, both signed on 10 February 2025, barred Commerce from considering any new exclusion request from that date. The General Approved Exclusions then became ineffective on 12 March 2025. Exclusions already granted ran to their expiry or until their volume was exhausted. Proclamation 11021 closed the separate inclusions process on 2 April 2026.

This is the single most common piece of stale advice still circulating. There is no product exclusion application to file, no portal to petition and no domestic-supply argument to make. What remains is narrower and different in kind: appearing in Annex II, falling under the Annex III cap, meeting the 15%-or-less metal by weight threshold, or qualifying under one of two programme-based routes. Proclamation 11045 of 20 July 2026 lets Commerce-approved companies import primary aluminum at half the otherwise applicable rate under an onshoring plan, and separate provisions give Commerce-authorised reduced rates on limited quantities of Canadian and Mexican metal supplying US vehicle manufacturers.

What replaced petitioning is classification and structuring work done before the goods ship. Establishing that an article belongs in Annex II rather than Annex I-B, or that its metal content falls under the weight threshold, is a documentary and engineering exercise. Where the product can legitimately be redesigned to change that answer, it belongs in a documented tariff engineering programme rather than an undocumented sourcing decision.

• Product exclusion requests: barred from 10 February 2025, no successor process.
• General Approved Exclusions: ineffective from 12 March 2025.
• Inclusions process: terminated 2 April 2026 by Proclamation 11021.
• Remaining relief: Annex II, Annex III cap, the 15% metal-by-weight threshold, the Proclamation 11045 aluminum onshoring programme, or authorised auto-supply quantities.

How These Duties Stack With Everything Else

Steel and aluminum duties do not stack with each other. Proclamation 11021 states that goods listed as articles or derivatives of more than one metal are subject only once to the respective rate, so the highest applicable rate applies a single time rather than cumulatively.

The bigger change in 2026 is what sits alongside them. The Supreme Court struck down the IEEPA tariffs on 20 February 2026 in Learning Resources v. Trump, and CBP ended collection within days. The reciprocal and fentanyl duties that used to stack on steel entries are gone, and refunds are running through the CAPE process in ACE. Any duty model still carrying an IEEPA line is overstating exposure.

The Section 301 forced-labor tariffs that took effect on 24 July 2026 do not apply here either. USTR excluded articles and parts already subject to Section 232 from that action, so a steel derivative pays its Section 232 rate rather than the 10% or 12.5% forced-labor rate. The legacy China Section 301 lists are a different matter and continue to apply alongside Section 232 on Chinese-origin goods.

Antidumping and countervailing duties always stack, because they are a separate legal mechanism aimed at a separate harm. A Chinese steel product on a Section 301 list, inside the scope of an AD/CVD order and covered by Annex I-A carries all three, and the antidumping and countervailing duties component is often the largest of them.

USMCA Content and the Two-Line Entry

Canada and Mexico are not exempt, and the relief that exists is narrower than it is usually described. Proclamation 11021 applies duty to the full customs value regardless of metal content, with no general USMCA carve-out. What Proclamation 11032 added on 8 June 2026 is specific: for Annex I-C derivative steel articles, mobile industrial equipment and machinery, that qualify under USMCA, duty applies to the non-US content with a 15% floor, filed through a two-line method that splits US and non-US content. That relief runs to 31 December 2027 and does not reach Annex I-A or Annex I-B goods.

Getting it right requires the supplier to substantiate the US-origin portion, which is a bill-of-materials exercise rather than a certificate. Where the documentation is thin, the safe filing is the full rate, and the difference is recoverable later only through the ordinary post-entry routes.

Importers running Canadian or Mexican supply chains should read this alongside USMCA rules of origin, because the two questions are answered by different rules and neither answer implies the other. A good can qualify for USMCA preference on the ordinary duty and still carry the full Section 232 charge, because outside the Annex I-C category there is no content-based relief at all.

What to Do Before the Next Shipment Books

Start by rerunning the duty on the full customs value for every derivative article you import, then compare it to what your system currently calculates. If your ERP still applies a metal-content percentage, every quote and every accrual since April has been wrong in the same direction.

Next, verify melt-and-pour or smelt-and-cast origin for the top twenty lines by value, and get mill certificates into the entry file rather than the quality folder. That is where the 25% UK rate and the 10% US-content rate are won or lost.

Then check annex placement against Annex II and Annex III before assuming the full rate applies, and confirm the classification underneath it, because the annex follows the HTSUS code and an incorrect code produces a confidently wrong duty. Where the code is genuinely arguable, a binding ruling converts an internal opinion into a position CBP is bound to.

Importers who paid IEEPA duties on steel entries between February 2025 and February 2026 should also be working the refund side. Our IEEPA refund program covers the CAPE filing mechanics and the eligibility window, and the amounts involved are substantial for anyone who imported metals through that period.

Frequently Asked Questions