What changed about Section 232 on April 6, 2026?

The April 2, 2026 White House proclamation restructured Section 232 treatment for steel, aluminum, and copper derivatives. For entries on or after April 6, 2026, duties are assessed on the full customs value of derivative products rather than just the metal content. The proclamation also publishes two annexes: Annex I-A (50% rate, ~280 HTSUS codes covering primary metals and intensive derivatives) and Annex I-B (25% rate, ~410 HTSUS codes covering downstream derivatives like household articles, automotive parts, machinery, and insulated electrical conductors).

How do I know if my product is a derivative under Section 232?

Run the 5-step decision tree: (1) Is your HTSUS classification in Chapters 72, 73, 74, or 76? If yes, you're in scope. (2) Is your specific HTSUS subheading listed in Annex I-A or Annex I-B of the April 2, 2026 proclamation? If yes, you're in scope. (3) Does your product pass the 15% by-weight de minimis test (metal inputs less than 15% of total product weight AND not classifiable in 72/73/74/76)? If yes, you're exempt. (4) Document country of melt-and-pour for steel or smelt-and-cast for aluminum and copper. (5) Watch BIS inclusion windows quarterly for new codes.

What is the 15% by-weight rule?

A derivative product can qualify for the de minimis exception if the aggregate weight of applicable steel, aluminum, and copper inputs is less than 15% of the total weight of the imported product, AND the product is not classifiable within HTSUS chapters 72, 73, 74, or 76. The calculation is by weight, not by value, using the same units shown on your commercial invoice. Document the calculation — CBP is authorized to request it.

What is country of melt and pour vs. smelt and cast?

Country of melt and pour applies to steel and steel-derivative products and refers to where the steel was originally melted and poured into its first solid form. Country of smelt and cast applies to aluminum and copper derivative products and refers to where the metal was smelted from ore (or scrap) and cast. Both are reported at entry via HTS Chapter 99 codes and substantiated by mill test certificates or certificates of analysis from your supplier.

Can I get a reduced 10% Section 232 rate?

Yes — derivatives whose metal content is at least 95% melted-and-poured (steel) or smelted-and-cast (aluminum/copper) in the United States qualify for a reduced 10% rate instead of the 25% or 50% rate. This is the highest-ROI savings lever in the new framework. Coordinate with your supplier upstream: by the time the entry is filed, it's too late to retroactively certify origin.

What is Annex I-A vs Annex I-B?

Annex I-A covers primary metal articles and intensive derivatives (structural steel, steel containers, wire, cable, pipe fittings, fasteners) at a 50% rate on the full customs value, spanning roughly 280 HTSUS codes primarily in chapters 72-74 and 76. Annex I-B covers downstream derivatives (household articles, cutlery, door hardware, certain automotive parts, vehicles, trailers, bearings, machinery, insulated electrical conductors) at a 25% rate on full customs value, spanning roughly 410 HTSUS codes.

Does the HTS flag in ACE automatically mean Section 232 applies?

No. The HTS flag indicates that a code may be subject to Section 232 — it does not automatically trigger the duty. Filers must independently confirm whether the specific subheading is on Annex I-A or I-B and apply the 15% by-weight test. Treating the flag as automatic leads to over-payment; ignoring the flag leads to under-payment and liquidated damages.

How often does BIS add new HTSUS codes to Section 232 derivative coverage?

The Bureau of Industry and Security runs inclusion windows several times a year, typically running 2 weeks each, where industry can petition to add HTSUS codes to Annex I-B. Newly added codes go live approximately 30 days after the window closes. The April 2026 window ran April 1-14 and added several 8708 auto-parts codes effective May 2026. Run your derivative analysis at least quarterly to stay current.

Is Your Product Subject to the New Section 232 Derivative Tariff? A 5-Step Decision Guide (April 2026)

The April 2, 2026 proclamation rewrote how Section 232 applies to derivative products — finished and semi-finished goods that contain steel, aluminum, or copper. For entries on or after April 6, 2026, the duty is no longer assessed on the metal portion of a derivative — it is now assessed on the full customs value of the imported product.

That single change quietly reclassified thousands of importers from "we don't really do metals" to "we owe Section 232 duties on every shipment." If you sell furniture with metal hardware, packaged food in metallized bags, electronics with insulated copper wiring, machinery with steel housings, or vehicles with bumpers — you may now be in scope.

This is the practitioner decision guide: five steps to determine whether your specific product is covered, what rate applies, what country-of-origin documentation you need, and which entries qualify for the 10% reduced rate for U.S.-sourced metal.

⚠️ Why this matters: Misclassifying a covered derivative is now a liquidated-damages event. CBP began entry-level enforcement on April 6, 2026. If you self-classified before that date and haven't re-checked, do this exercise this week.

The 5-step decision tree

Run your product through these five questions in order. The first "yes" that lands you in scope determines your treatment.

Step 1 — Is your HS classification in Chapter 72, 73, 74, or 76?

These are the four chapters where primary metal products live:

Chapter 72 — iron and steel
Chapter 73 — articles of iron or steel
Chapter 74 — copper and articles of copper
Chapter 76 — aluminum and articles of aluminum

If your product is classified anywhere in these chapters, you are in scope. Stop here and skip to Step 4 to determine your rate.

If you are not in Chapters 72/73/74/76, your product can still be in scope as a derivative listed in Annex I-B. Continue to Step 2.

Step 2 — Is your HTSUS subheading on Annex I-A or Annex I-B?

The April 2, 2026 proclamation publishes two annexes:

Annex	Rate	Coverage	Codes
Annex I-A	50%	Primary metal articles + intensive derivatives — structural steel, steel containers, wire, cable, pipe fittings, fasteners	~280 HTSUS codes
Annex I-B	25%	Downstream derivatives — household articles, cutlery, door hardware, automotive parts, vehicles/trailers, bearings, machinery, insulated electrical conductors	~410 HTSUS codes

Look up your specific 8- or 10-digit HTSUS subheading in both annexes. The annexes are appended to the White House proclamation PDF.

If your code appears on either annex, you are in scope. Skip to Step 3 to apply the 15% by-weight test (which can exempt some Annex I-B products).

If your code is not in any of those four chapters and not on either annex, you are likely outside Section 232 scope for now. But check Step 5 — BIS expansions are continuous.

Step 3 — Does your product pass the 15% by-weight de minimis test?

This is the exception that keeps many incidental-metal products out of scope. Your derivative qualifies for the de minimis exception if both of the following are true:

The aggregate weight of applicable steel, aluminum, and copper inputs is less than 15% of the total weight of the imported product
The product is not classifiable within HTSUS chapters 72, 73, 74, or 76

A few worked examples:

A 5-pound packaged food product in a metallized polypropylene bag where the aluminum layer is 0.05 oz → metal weight is well under 15%, classified in Chapter 19/20/21 → exempt
A 50-pound steel tool chest classified under 7326 → in Chapter 73 → fails second prong, in scope regardless of metal percentage
A 12-pound electric motor where copper windings weigh 2.5 pounds (~21% of total weight) → fails 15% test, in scope

📐 How to calculate: total weight of metal inputs ÷ total product weight, by weight (not by value). Use the same weight units used on your commercial invoice. Document the calculation — CBP can request it.

Step 4 — Where was the metal melted and poured (steel) or smelted and cast (aluminum/copper)?

Country-of-origin is now a duty-rate determinant, not just a documentation field.

For each shipment of a covered product, importers must report:

Country of melt and pour — for all subject steel and steel-derivative products
Country of smelt and cast — for all subject aluminum and copper derivative products

This is reported via specific HTS Chapter 99 codes at the line level. Mill test certificates and certificates of analysis from your supplier are the primary substantiation documents. CBP doesn't require them at entry but is authorized to request them — and is doing so on a sampling basis.

Key consequence: if you can certify ≥95% of the metal content was melted-and-poured (steel) or smelted-and-cast (aluminum/copper) in the United States, you qualify for the 10% reduced rate instead of 25%/50%. This is the single biggest savings lever in the new framework. Lock in supplier certifications upstream — by the time the entry is filed, it's too late.

Step 5 — Is your product on a pending BIS inclusions petition?

The Bureau of Industry and Security runs inclusion windows several times a year where industry can petition to add HTSUS codes to Annex I-B. Each window typically runs 2 weeks. Once added, codes go live ~30 days later.

If your product sits adjacent to current scope (e.g., metal furniture frames that are not in 73, but are aluminum-heavy), watch the BIS Federal Register notices. The April 2026 inclusions window for auto parts ran April 1–14 and added a number of 8708 codes effective May 2026.

If you only run this analysis annually, you will be retroactively wrong by ~6 months. Quarterly is the right cadence.

Quick reference: the 5 questions on one page

1. Is HS chapter 72, 73, 74, or 76?           → Yes: in scope, go to Step 4
2. Is HTSUS in Annex I-A or I-B?              → Yes: in scope, go to Step 3
3. Metal weight < 15% AND not in 72/73/74/76? → Yes: exempt
4. Country of melt/pour or smelt/cast?        → US ≥95%: 10% rate
                                              → Annex I-A: 50% on full value
                                              → Annex I-B: 25% on full value
5. Watch BIS inclusion windows quarterly      → New codes added ~30 days post-window

Where the costliest mistakes happen

After two weeks of CAPE-era enforcement, three patterns dominate the rejection and post-summary-correction logs we're seeing in r/CustomsBroker and from broker contacts:

Mistake 1 — Treating the HTS flag as the trigger

CBP's ACE system flags HTSUS codes that might be subject to Section 232. The flag is not the rule. It tells you to check Annex I-A/I-B and apply the 15% test. Some flagged codes will be in scope; others won't be once you run the test. Filers who treat the flag as automatic over-pay; filers who treat the flag as ignorable under-pay and incur liquidated damages.

Mistake 2 — Confusing classification with content

A 4-ounce chocolate bar in a metallized aluminum wrapper is classified as chocolate (Chapter 18), not aluminum. The container is incidental and stays with the food classification. The 15% by-weight test then exempts the wrapper. But a 4-ounce chocolate bar packed in a 30-gram aluminum tin classified separately from the chocolate could fail the test if the tin gets its own classification and is in Chapter 76. Read the GRI rules carefully on packaging-vs-contents.

Mistake 3 — Missing the U.S. melt/smelt 10% rate

Many importers are paying 25% or 50% on derivatives that could qualify for the 10% reduced rate because their supplier can document U.S.-origin metal but never did. Asking for the certification adds a one-time 1–2 week supplier process and saves 15–40 percentage points of duty per entry. This is the highest ROI conversation an SMB importer can have right now.

Where TariffCenter can help

Duty Calculator — model the rate impact across the 10% / 25% / 50% scenarios for your HTSUS
HS Code Lookup — confirm whether your subheading sits in Chapters 72/73/74/76 or appears in Annex I-A/I-B
Refund Estimator — for entries filed on the wrong basis since April 6, 2026
Section 232 April 2026 Update — the policy explainer companion to this decision guide
Tariff Stacking Visual Examples — how Section 232 stacks with Section 122, IEEPA, and AD/CVD
AI Tariff Assistant — ask "is HTSUS X.XX.XX.XX subject to Section 232 derivative treatment?" and get an answer grounded in the current annexes

Bottom line

Section 232 is no longer a steel-and-aluminum-only conversation. After April 6, 2026, it's a derivative conversation — and the derivative rules turn on three questions: which annex, what's the metal weight share, and where was the metal melted or smelted. Get those three right and you'll classify entries correctly. Get any one wrong and you'll either over-pay (avoidable cost) or under-pay (liquidated damages event).

Run the five-step decision tree on every covered SKU before your next shipment lands.