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Section 232 Tariffs: Steel, Aluminum, Copper and Auto Duties Explained

Section 232 tariffs are import duties authorized by the Trade Expansion Act of 1962 when the U.S. Department of Commerce determines that imports threaten national security. The program covers steel, aluminum, copper, and autos. Rates run from 25% to 50% depending on the product and country of origin. For U.S. importers, these duties stack on top of Section 301 and Reciprocal Tariff Act rates, compounding landed cost pressure across multiple supply chains.

Under 19 USC §1862, the president can impose duties or quotas after a DOC investigation concludes that import volumes endanger domestic industrial capacity. The Bureau of Industry and Security (BIS) within the DOC administers the program and publishes all actions in the Federal Register.

Which Products Fall Under Section 232 in 2026

Section 232 coverage has expanded significantly since 2018. The four active product categories are below.

Steel and Steel Derivatives (HTS Chapter 72, 73)

A 25% tariff on steel mill products took effect March 23, 2018 (Proclamation 9705). HTS Chapters 72 and 73 cover hot-rolled coil, cold-rolled sheet, structural beams, pipes, tubes, and fabricated steel products. Several countries negotiated quota agreements in exchange for tariff exemptions. Those exemptions have been narrowed or eliminated for most trading partners in 2026. Work the steel and aluminum tariffs guide for current country-specific rates.

Aluminum and Aluminum Derivatives (HTS Chapter 76)

Aluminum entered the Section 232 program at 10% in March 2018 (Proclamation 9704). The rate was raised to 25% for most countries in 2026. HTS Chapter 76 covers primary aluminum, alloyed aluminum, plates, sheets, foil, tubes, and pipes. Derivative products (parts made primarily from aluminum) are also covered.

Copper and Copper-Intensive Products (HTS Chapter 74)

A 50% Section 232 tariff on copper was announced in 2026. HTS Chapter 74 covers refined copper, copper alloys, wire, rods, plates, and tubes. This is the highest Section 232 rate applied to any commodity. Importers sourcing copper wire, bus bars, or heat exchangers should recalculate landed costs immediately. Review the full copper tariff breakdown for HTS-level detail.

Autos and Auto Parts (HTS Chapter 87)

A 25% tariff on passenger vehicles and auto parts took effect in 2026. HTS Chapter 87 covers passenger cars, light trucks, and a defined list of auto parts. The parts list includes engines, transmissions, body stampings, axles, and suspension components. Vehicles qualifying under USMCA are subject to different treatment depending on regional content percentages.

Current Section 232 Rates and Duty Stacking

The table below shows the active Section 232 rates as of 2026:

  • Steel: 25% (most countries); higher for certain steel derivative products
  • Aluminum: 25% (most countries)
  • Copper: 50%
  • Autos and auto parts: 25%

Section 232 duties are additive. An importer bringing in Chinese steel pays the Section 232 steel duty (25%) plus Section 301 list duties (if the HTS code appears on a Section 301 list) plus the Reciprocal Tariff Act rate (145% for China). The combined rate can exceed 170% on affected steel products. Use the Captain tariff tracker to calculate stacked duties by HTS code and country of origin before each purchase order.

How the Section 232 Exclusion Process Works

BIS operates the Section 232 exclusion portal under 15 CFR Part 705. Importers, manufacturers, and other interested parties can request product-specific exclusions. An approved exclusion lets a named company import a defined product at zero Section 232 duty.

Eligibility Criteria

To qualify, the requester must show that the product is not produced in the U.S. in sufficient quantities, not produced in adequate quality, or not available in a timely manner from domestic sources. The request must identify the specific HTS subheading and describe the product in technical terms that match the actual import.

BIS Exclusion Portal Walkthrough

File the exclusion request through the BIS Section 232 exclusion portal. The submission requires a company profile, product description, quantity requested, domestic supplier objection process, and supporting documentation. After submission, domestic steel or aluminum producers can file objections within 30 days. BIS adjudicates the record and issues a determination published in the Federal Register. The USITC provides data support for BIS on many requests.

Common Rejection Reasons

BIS rejects exclusion requests when domestic availability is not adequately disproven, when the product description does not precisely match the HTS subheading, or when a domestic producer successfully objects with capacity evidence. Requests without specific mill certifications or technical specs are also frequently denied.

Section 232 vs Section 301 vs Section 122

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These three tariff authorities overlap but have different legal bases and triggers.

  • Section 232: National security threat to domestic industry. No expiration. Applies globally with country-specific carveouts. BIS administers.
  • Section 301: Unfair trade practices by a foreign government. China-specific in current application. USTR administers. See the full Section 301 tariffs on China analysis for list-by-list breakdowns.
  • Section 122: Balance-of-payments emergency. Maximum 15% rate. Maximum 150-day duration. Has not been used as a comprehensive surcharge in modern trade history.

The Reciprocal Tariff Act adds a fourth layer based on bilateral trade deficits. All four programs can apply simultaneously to a single shipment. The Trump tariff tracker shows live stacked rates for your HTS codes across all four authorities.

How Importers Reduce Section 232 Exposure

Three mechanisms reduce or defer Section 232 duties without changing the HTS classification:

  1. Foreign-Trade Zone (FTZ): Goods admitted to an FTZ before a rate proclamation takes effect enter at the pre-proclamation rate. FTZs also eliminate duties on goods re-exported without entering U.S. commerce.
  2. Customs bonded warehouse: Duties are deferred until withdrawal for consumption. If a rate drops or an exclusion is granted, the importer can withdraw at the lower rate.
  3. Section 232 exclusion: Company-specific exclusions eliminate the duty entirely for approved products and quantities.

A tariff consulting firm can identify which mechanism applies to your product and model the savings against setup costs. The trade advisory services team runs the landed cost comparison across all three options before recommending a strategy.

Frequently Asked Questions

Are Section 232 tariffs still active in 2026?

Yes. Section 232 tariffs on steel and aluminum remain fully active in 2026. Copper and auto parts were added in 2026. No sunset date applies. Congress can modify the program through legislation, but the executive orders implementing current rates remain in force.

What is the current Section 232 tariff rate on steel?

The base rate is 25% for most countries. Some country-specific agreements set different rates or quotas. Check the Federal Register for the most recent proclamation applying to your supplier’s country of origin.

Can I file a Section 232 exclusion request as an importer?

Yes. Importers, manufacturers, and purchasers of steel and aluminum products can file exclusion requests through the BIS Section 232 exclusion portal. The process requires product-specific documentation and a showing that domestic supply is insufficient.

Do Section 232 tariffs stack with Section 301 China tariffs?

Yes. If a Chinese steel product appears on a Section 301 list, both the Section 232 rate and the Section 301 rate apply. The Reciprocal Tariff Act rate also stacks. All three are cumulative on top of the base HTSUS Column 1 duty.

Is there a Section 232 refund mechanism?

There is no standalone refund program for Section 232 duties. However, Section 232 duties are generally eligible for duty drawback under 19 USC §1313, meaning importers who re-export finished goods can recover up to 99% of duties paid on the imported inputs.

What HTS codes are covered by Section 232 copper?

Section 232 copper covers HTS Chapter 74, which includes refined copper (7401-7403), copper alloys (7403-7407), copper plates, sheets, strip, and foil (7409-7410), copper tubes and pipes (7411), and copper wire (7408). Check the specific proclamation for the exact HTS subheadings covered.

How long does a Section 232 exclusion request take?

BIS targets 90 days for a determination, but complex requests with objections from domestic producers can take 6-12 months. Plan procurement timelines accordingly. An approved exclusion is retroactive to the date of filing, so duties paid during the review period can be recovered.

Section 232 exposure is predictable when you map it by HTS code before placing orders. The tariff consulting firm team runs HTS-level Section 232 analysis as part of every import cost review. The trade advisory services team then models exclusion eligibility, drawback recovery, and FTZ deferral to find the lowest landed cost path.

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Section 232 vs 301 vs 122: Which Tariff Authority Applies to Your Imports?

Three tariff authorities — Section 232, Section 301, and Section 122 — form the backbone of the remedial tariff environment U.S. importers face in 2026. Each derives from a different statute, targets different policy objectives, and covers different products and countries. Understanding which authority applies to a given import is the first step in any tariff analysis and the foundation of any mitigation strategy.

The Key Distinction Before Diving In

Section 232 is a national security tool. Section 301 is an unfair trade practices tool. Section 122 is a balance-of-payments emergency tool. They can and do coexist on the same customs entry — a Chinese steel part might simultaneously owe duties under all three relevant frameworks. Starting with this distinction prevents the common mistake of treating them as alternatives.

Section 232: National Security Tariffs

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Section 232 of the Trade Expansion Act of 1962 authorizes the President to impose import restrictions after the Secretary of Commerce and the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce (DOC) investigate and determine that an article is being imported in quantities or under circumstances that threaten to impair national security. BIS evaluates factors including domestic production capacity, the defense industrial base’s requirements, and the impact of imports on those requirements.

Current Section 232 Programs

  • Steel articles (HTS Chapters 72-73): 25% ad valorem from most countries. Country-specific tariff-rate quotas (TRQs) exist for Canada, Mexico, the EU, Japan, and others, allowing quota volumes at zero or reduced rates.
  • Aluminum articles (HTS Chapter 76): 10% from most countries, with TRQ arrangements for certain allies.
  • Copper and copper articles (HTS Chapter 74): 25%, announced in 2025 as part of the expanding national security review of critical minerals.
  • Autos and auto parts (HTS Chapter 87, specified subheadings): 25%, with a phase-in for USMCA-qualifying content.

Section 232 does not inherently target a single country. The current programs apply globally with country-specific exceptions negotiated as TRQs. The Federal Register publishes quarterly TRQ fill-rate data. Product exclusions are available for specific HTS subheadings where the product is not available in sufficient quantity, quality, or timeliness from domestic producers. Approved general approved exclusions (GAEs) are available for use by any importer. Working with a tariff consulting firm to identify applicable GAEs or pursue new exclusion requests often delivers measurable duty savings.

Section 232 Process

A Section 232 action requires a formal Commerce Department investigation, a report finding a national security threat, and a Presidential proclamation implementing the remedy. The process is more deliberate than IEEPA because it requires the BIS investigation step. Once proclaimed, Section 232 duties are indefinite.

Section 301: Unfair Trade Practice Tariffs

Section 301 of the Trade Act of 1974 authorizes the Office of the U.S. Trade Representative (USTR) to investigate foreign government acts, policies, and practices that are unreasonable or discriminatory and burden or restrict U.S. commerce, and to take appropriate retaliatory action. Unlike Section 232, Section 301 targets a specific country and a specific set of practices.

Current Section 301 Program: China

The active Section 301 action targets China based on USTR’s 2018 investigation finding that China engages in unfair practices related to technology transfer, intellectual property, and innovation. The tariffs are organized by “List”:

  • Lists 1 and 2: 25% on approximately $50 billion in goods (industrial equipment, aerospace components)
  • List 3: 25% (raised from 10% in 2019) on approximately $200 billion in goods (consumer electronics, furniture, machinery)
  • List 4A: 7.5% on approximately $120 billion in goods (consumer electronics, apparel, footwear)

USTR’s 2024 four-year statutory review resulted in targeted rate increases on strategic categories: electric vehicles (100%), solar cells (50%), lithium batteries (25%), ship-to-shore cranes (25%), and medical gloves (25%).

Section 301 and the Liberation Day IEEPA Stack

Beginning April 2025, the IEEPA Liberation Day rate stacked additively on Section 301 for Chinese goods. For a product subject to 25% Section 301 and 145% IEEPA, the combined remedial tariff is 170%, on top of the applicable MFN rate. Understanding Liberation Day tariffs is therefore inseparable from Section 301 analysis for Chinese-origin goods. See our review of Section 301 tariffs on China for the full product list and rate history.

Section 301 Exclusion Process

USTR has operated rolling exclusion request processes for Section 301. An exclusion removes the tariff for a specific HTS subheading and typically expires after one year. Exclusion requests must demonstrate that the product is not reasonably available from non-Chinese sources or that the tariff causes severe economic harm. The USITC publishes analysis supporting exclusion determinations.

Section 122: Balance-of-Payments Tariffs

Section 122 of the Trade Act of 1974 grants the President authority to impose a temporary import surcharge when the United States is experiencing “large and serious” balance-of-payments deficits or a significant depreciation in the exchange value of the dollar. This authority is less well-known because it has not been formally invoked since 1971 (under President Nixon as part of the Smithsonian Agreement framework). It received renewed attention in 2025 as a possible alternative legal basis for the Liberation Day tariff framework.

Key Constraints of Section 122

  • Rate cap: Section 122 limits the surcharge to a maximum of 15%.
  • Duration cap: The surcharge can last no more than 150 days without Congressional action.
  • Universal application: Section 122 does not allow country-specific differentiation; it applies to all imports equally.

These constraints explain why the Liberation Day framework used IEEPA rather than Section 122. IEEPA has no statutory rate cap, no time limit once an emergency is declared, and allows country-specific rate differentiation — all essential for the Annex II country-specific reciprocal rate structure with rates exceeding 100% for China. The USITC has published comparative analysis of IEEPA and Section 122 scope and limitations for interested parties.

Side-by-Side Comparison

Feature Section 232 Section 301 Section 122
Statute Trade Expansion Act 1962 Trade Act of 1974 Trade Act of 1974
Authority President after DOC/BIS investigation USTR (President may direct) President
Basis National security threat Unfair trade practices Balance-of-payments deficit
Country scope Global (with country TRQ exceptions) Country-specific (China currently) Universal (no country distinction)
Product scope Steel, aluminum, copper, autos Thousands of HTS codes from China All imports
Rate cap None statutory None statutory 15% maximum
Duration Indefinite until revoked Indefinite (4-year review cycle) Maximum 150 days
Current status Active: steel 25%, Al 10%, Cu 25%, autos 25% Active: 7.5-25%+ on Chinese goods Inactive (last used 1971)

Decision Tree: Which Authority Applies?

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  1. Is the product steel, aluminum, copper, or an auto/auto part? If yes, check for Section 232 applicability and any applicable TRQ for the country of origin.
  2. Is the country of origin China? If yes, identify the Section 301 List and applicable rate for the specific HTS subheading.
  3. Does the Liberation Day IEEPA rate apply? It applies to all origins: 10% Annex I for most countries, the applicable Annex II rate (145% for China as of mid-2026) for named countries.
  4. Is there an active AD/CVD order? Check ITA Enforcement and Compliance for any order covering the specific product and country combination.

The sum of all applicable rates is the effective composite tariff. Use the Captain tariff tracker to run this assessment for any HTS and origin combination. Our trade advisory services team provides authority-by-authority mitigation analysis for importers managing concurrent exposure across multiple programs.

Mitigation Strategies by Authority

Each tariff authority has distinct mitigation pathways:

  • Section 232: Product exclusion applications to BIS, reclassification to a non-covered subheading, sourcing from TRQ-exempt country volumes, FTZ use for melted-and-poured origin tracing.
  • Section 301: USTR exclusion requests for specific HTS subheadings, First Sale valuation to reduce the dutiable base, drawback on subsequent exports, sourcing diversification to non-China origins.
  • IEEPA (Liberation Day): Annex III product-level carve-out monitoring, bilateral deal memo tracking for country rate reductions, FTZ deferral pending exclusion rulings or court decisions.

Frequently Asked Questions

What is the difference between Section 232 and Section 301 tariffs?

Section 232 is a national security tariff under the Trade Expansion Act of 1962, currently applied globally to steel (25%), aluminum (10%), copper (25%), and autos (25%). Section 301 is an unfair trade practices tariff under the Trade Act of 1974, currently applied only to Chinese-origin goods at rates from 7.5% to 25%+. Both can apply to the same entry from China.

Does Section 301 apply to countries other than China?

No active Section 301 orders apply to countries other than China as of mid-2026. While Section 301 can be used against any country, the current action targets China specifically in response to USTR’s 2018 investigation findings on technology transfer and IP practices.

What is Section 122 and why is it not used?

Section 122 authorizes a temporary up-to-15% universal import surcharge for up to 150 days to address balance-of-payments deficits. It has not been formally invoked since 1971. The 15% rate cap and 150-day time limit make it unsuitable for the Liberation Day framework, which required country-specific rates exceeding 100% on an indefinite basis — capabilities IEEPA provides but Section 122 does not.

Can Section 232 and Section 301 both apply to the same Chinese steel shipment?

Yes. A Chinese steel fitting, for example, carries Section 232 (25%), Section 301 (25%), and IEEPA Liberation Day (145%) simultaneously. All applicable rates are calculated on the same customs value and summed. The combined effective rate on some Chinese steel products exceeds 200%.

How do I get a Section 232 product exclusion?

Submit an exclusion request to BIS through the Section 232 exclusion portal. The request must demonstrate that the product is not produced in the U.S. in sufficient quantity, quality, or timeliness. Approved exclusions become General Approved Exclusions (GAEs) available for any importer to use. Monitor the Federal Register for newly published GAEs that may cover your product.

Are Section 301 tariffs permanent?

Section 301 tariffs are indefinite but subject to mandatory four-year statutory review by USTR. Reviews can raise rates, reduce them, add product categories, or terminate the action. The 2024 review raised rates on strategic goods. The next review cycle is expected in 2028.

Authority-Specific Tariff Guidance

With three overlapping authorities and distinct mitigation pathways for each, the most efficient approach is a structured program review. Our tariff consulting team maps every applicable authority for your product portfolio and identifies priority mitigation actions by authority. Trade advisory services from CargoTrans cover Section 232 exclusion applications, Section 301 exclusion strategy, and IEEPA deferral planning.

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