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

June 5, 2026 by Leave a comment

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!

Filed under Uncategorized Tagged with , , , , , ,

Aircraft Disassemblers May Wish to Sell their Scrap Aluminum From Fuselages

May 27, 2026 by Leave a comment

With the rising price of aluminum, and current constraints on aluminum production, this might be an ideal time to sell scrap aluminum from aircraft fuselage disassembly.

I’ve had law firm clients who will purchase an airframe for disassembly, remove the most valuable components, and then wait to scrap the remainder of the fuselage until metal prices look better.  If you are waiting for the right time to sell scrap aluminum from an aircraft fuselage, then now might be that time.  

The price of aluminum has been rising, and has recently hit four-year-highs.  Numerous industries are grappling with the rise and devising strategies for how to respond.

Data centers, and the cabling required to bring them power, have been putting a strain on the world’s aluminum supply.  This is in addition to all of the normal demands on the world’s aluminum supply.

One important factor in the near future aluminum supply is that one of the most significant aluminum producers is Emirates Global Aluminum (EGA).  EGA has suffered significant damage during the current U.S.-Iran conflict and experts estimate that it will take a year of restoration before the entire facility can be brought back online. 

EGA recently announced plans to build a $4 billion aluminum plant in Oklahoma, but that won’t be online for years.  

In addition, there are fears that China may curtail some of its Aluminum production.

So all of that adds up to increased demand and decreased supply.  The market has been responding with higher prices.  Aluminum prices may continue to rise, but now is a great time to be watching the aluminum market for opportunities to crush and sell aluminum fuselages. 

Filed under Uncategorized Tagged with , , ,

New Aluminum, Copper, and Steel Tariffs: Read Carefully Because They May Not Apply to Many Aircraft Parts Imports

April 6, 2026 by Leave a comment

If you are importing aircraft parts made from aluminum, copper and steel then the new aluminum, copper and steel tariffs that go into effect today could have drawn your attention. It is important to look at them carefully because they will apply to a small number of aircraft parts, but they will not apply to most aircraft parts.

Last week, the President issued a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States.” That proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective today (April 6, 2026). 

It is important to examine the tariff code for your goods, and compare it to the code listing for the tariff.  NOT ALL PARTS ARE SUBJECT TO THESE DUTIES!  Most bar stock and other non-finished products are covered.  Many wires and fasteners/hardware are covered. 

Many finished aircraft parts made from these materials are not covered; but some aircraft parts may be covered (like certain hydraulic fluid pumps under heading 8413, certain heat exchange units under 8419, and certain bearings under heading 8482 or 8483).  To be certain, it is important to check the annexes, which will be incorporated into the HTSUS.

Once you have identified your imports as being subject to one of these tariffs, then you still need to identify which of the annexes applies (based on tariff number) as well as the source of the material.  The actual calculation mechanism has gotten more complicated and is more fully described in the proclamation and annexes.  For more information, or if you need more guidance, then contact the Association.

Even if the tariff code for your import good is listed, you still need to check the metal content (by weight) because an additional exception may apply.  Goods specified in the annexes to the Proclamation, except those classifiable in Chapters 72, 73, 74, and 76, that contain less than 15 percent of the aggregate weight of the applicable metal(s) are not subject to the duties imposed by the Proclamation.  This is the sum of the applicable metals where there is more than one tariffed metal.  For example, since HTSUS is 8302.10.60 is identified in paragraphs (c)(vi) and (vii) of annex IV as both a derivative aluminum article and steel article in annex IV, the aggregate weight of both aluminum and steel (but not copper) should be included in the 15 percent calculation.  If you are able to use the “less than 15% weight” exception, then report it as HTSUS 9903.82.03, and include the aggregate weight of the applicable metal(s) in kilograms as a second quantity on the entry summary line.

Filed under Uncategorized Tagged with , , , , , , ,

Tariff Update

February 24, 2025 by 2 Comments

We’ve been answering a number of questions from our members about tariff status. This article is meant to summarize what we know about recent tariff activity, but the administration hasn’t maintained a uniform message about tariffs, so what we know could change at any time.

UPDATE: We have published more up-to-date information for products of Canada, Mexico and other Non-US sources and for steel and aluminum.

China

The United States has applied a 10% tariff in addition to any pre-existing tariffs that already applied to aircraft parts from China.

It is important to recognize that there is an existing list of products of China that were already subject to a 25% ‘additional duty’ provision. This is described under subheading 9903.88.01 and the description can be found under U.S. note 20(b) to sub-chapter III of chapter 99 of the US Harmonized Tariff System. Many aircraft parts are subject to a 25% duty under this provision, including those under (for example) headings 8409, 8411, and 8807. This means that the additional 10% duty of tariff 9903.01.20 brings the import duty on those aircraft parts to 35% (assuming they would have been otherwise subject to a zero-duty entry, but-for the ‘additional duty’ provisions, e.g. aircraft parts under headings 8409, 8411, or 8807).

Because of the peculiar way that the China tariffs had been drafted, it is possible that articles subject to a non-zero base duty may have that base duty doubled (see this article for a detailed explanation). This is a non-issue for most aircraft parts because most are subject to a zero percent base duty rate, but some aircraft parts (like certain fasteners) have a non-zero base duty and the peculiarities will need to be resolved for those imports.

Canada and Mexico

The United States is scheduled to impose 25% tariffs against substantially all products of Canada and substantially all products of Mexico. In each case the tariffs are currently schedule to apply to Canadian imports and Mexican imports as of 12:01 am March 4, 2025. The tariffs (which are the description of how the duty rates will be applied) were withdrawn when the Canada and Mexico tariffs were delayed, so the republished tariffs could change.

Typically, the 25% tariff would be applied to the import value of the goods (25% of the value is charged as a duty). When the goods are exported from the United States for the purpose of obtaining repair abroad, and then subsequently returned to the U.S., the dutiable value upon return is typically calculated based on the parts-and-labor-cost of the MRO work that was accomplished abroad (unless it is a no-charge repair, like a warranty repair, in which case it is based on the fair market value of the repair). This is covered under chapter 98 tariff subheadings like 9802.00.40 (for warranty repairs) or 9802.00.50 (for non-warranty repairs). The goods would be subject to a basic duty based on the repair value times the rate that applies to the underlying good. For example, if the repair cost was $20,000 and the underlying aircraft part was subject to heading 8807, then the old rate of duty would be zero percent so the duty would be zero dollars. Under the new tariffs with the 25% duty rates, though, if the repair cost was $20,000 and the tariff on products of the country in which the repair was performed is at a 25% duty rate, then the U.S. importer to whom the repaired part is returned (from Canada) would need to pay an import duty of $5,000 (in addition to the repair cost).

Steel and Aluminum

The Administration has also issued orders to apply and increase duty rates on steel and aluminum (including plates, sheets, strips, bars, rods, tubes and wires). The new duty rates for aluminum from most countries will be 25% (in addition to any other applicable tariffs). Derivative products made from aluminum or steel will also be subject to a 10% duty (in addition to any other applicable tariffs). The executive order that announced these is quite complicated, with different phase-in dates for different countries, and some higher duty rates for certain countries (for example Turkey will face a 50% duty rate on all steel articles imports and Russia will face a 200% duty rate on imported derivative aluminum articles).

If you think that the steel or aluminum tariffs may apply to your imports then please be sure to read the tariffs thoroughly (don’t just rely on this blog article because there are too many details to republish them all here).

Other Targets

In tomorrow’s Federal Register, we expect to see a new request from the U.S. Trade Representative (USTR). The new request will ask the American people to identify any unfair trade practices by other countries, with a discussion of the harm to the United States. The draft publication refers to these as non-reciprocal trade arrangements so it appears that the Administration (which has threatened to implement reciprocal tariffs) may be looking at such arrangements as justifications for tariffs on comparable products from these source countries. This investigation is a response to the “America First Trade Policy” Executive Order.

Filed under Uncategorized Tagged with , , , , , , ,