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.

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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.

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