Changes to the Duty Rates and the Parts Lists for Aluminum, Steel and Copper Section 232 Tariffs

If your aluminum, steel and/or copper parts are subject to the special metal derivative tariffs, then the rules surrounding them may be changing.

History

Since April 2, 2026, when the President issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” certain parts made from aluminum, steel and/or copper have been subject to import duties under special chapter 99 tariffs. That provision imposed the import duties only on parts under certain tariff codes – many aircraft parts made from aluminum, steel and/or copper were not on that list and thus were not subject to these additional duties. But some parts, including some fasteners and other hardware, were subject to these tariffs. The tariffs were issued under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  As a consequence, they were not ruled as illegal with the IEEPA tariffs.

The April proclamation imposed 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles and their derivatives from all countries, effective April 6, 2026. As a base rate, metals were subject to the 50% rate and metal articles (“derivatives”) were subject to the 25% rate. Aircraft parts made from these metals could be considered affected derivatives, if they were listed on the list of affected HTSUS codes.

The Change

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States” amending the April Proclamation. The changes included addition of some new metal parts (“derivatives”) subject to the Section 232 duties, as well as some clarification about reduced rates of duty.

Generally speaking, the duty rate for metals (e.g. bar stock, tubes and pipes, etc.) will be 50%. The duty rate for metal articles will be 25% of the article’s value, except:

  • 15% for products of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union (the total rate of duty – base duty plus additional section 232 duty – shall be 15%);
  • 10 percent for derivative articles where the aluminum and/or steel content was smelted and cast/poured in the United States;
  • For products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement, a duty of 25 percent shall apply only to the non-U.S. content of the product.

A list of the 50% materials is found here.

A list of the 25% articles is found here.

There are technical details and exceptions in addition to what this article covers. If you think your import may be subject to these additional duties then please make sure you scrutinize the standards carefully to ensure you are following the correct compliance path, and are not overpaying your import duties..

The announcement can be found in yesterday’s Federal Register on Page 34085.

These new standards apply to imported parts entered into the United States on or after June 8, 2026.

Looking for more import guidance? Join us at the ASA/AFRA Annual Conference, on June 14-16, in Las Vegas, Nevada. Check out the conference agenda for full details on this and many other workshops available at the conference!

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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