STRENGTHENING ACTIONS TAKEN TO ADJUST IMPORTS OF ALUMINUM, STEEL, AND COPPER INTO THE UNITED STATES

On April 2, 2026, President Trump issued a Proclamation further adjusting how the import of certain aluminum, steel and copper items are to be handled by the importing community. The changes set forth within the Proclamation and summarized below went into effect at 12:01am April 6, 2026.

Notable Changes

Tariff Assessment – Duties will now be assessed against the FULL entered value rather than the value of the specific metal.

Tariff Rates

• 50% – Applies to steel/steel derivatives, aluminum/aluminum derivatives and copper articles set forth in Annex I-A.
• 25% – Applies to steel and aluminum derivates and copper items set forth in Annex I-B.

Tariff Removal

• HTS codes listed in Annex II are no longer subject to aluminum, steel or copper tariffs.

Temporary Tariff Reduction – Items set forth in Annex III of the Proclamation will have reduced tariff rates from the 25%-50% rate to a 15% cap until December 31, 2027.

• Section 232 duties will be calculated based on the products MFN duty rate.
  • 15% = MFN Rate + 232 Rate
  • Ex: 15% = 2.5% MFN + 12.5% 232 duty
• Articles composed entirely of US melt/poured steel – This is determined the same way as above, but with a 10% cap.

Special Duty Rates

• United Kingdom – Reduced tariff rates from 25% or 50% to15% or 25% for articles for which the steel or aluminum is melted/smelted and poured/cast exclusively in the United Kingdom.
• US Steel, Aluminum and Copper– Reduce tariff rate of 10% for articles for which the imported article contains at least 95% of the steel, aluminum or copper that is melted/smelted and poured/cast in the United States.
• Russia – Tariff rate of 200% remains if imported item is a product of Russia is with made any amount of from primary aluminum is smelted or cast in Russia.

Weight Exclusion – For Steel, Aluminum and Copper items subject to 232 that are NOT classified in Chapters 72, 73, 74, 76 and the weight of the applicable metal is less than 15% the weight of the imported article, these Section 232 duties do not apply.

Copper – Information regarding countries of smelt and cast for copper used in copper products will soon be required.

Inclusion Process – The quarterly HTS inclusion process established in previous Proclamations has been terminated.

Importers will now have to adjust how certain steel, aluminum and copper information will be determined. Steel, aluminum and copper information shifts from specific metal values to a weight value within the imported article. Importers will still need to know the country(s) of melt/smelt and pour/cast for steel and aluminum but will now need to know it for copper. It’s important to review your classifications, country of origins and the material breakdowns of imported articles.

 

Consolidated Administration and Processing of Entries (CAPE)

CBP provided the Court of International Trade an updated Declaration on March 31, 2026 providing updates on the development of CAPE.

In the pervious court order issued by CIT on March 27, 2026, CBP was further instructed to include entries for which have finally liquidated to be included in the CAPE function. CBP responded that CAPE is being developed in Phases, and in order stick to the original timeline, CBP is unable to include finally liquidated entries into Phase I. According to the Declaration, “Phase 1 will only process unliquidated entries and entries within the 90-day voluntary reliquidation period”. It further explains “Phase 1 of CAPE will be capable of processing approximately 63% of entries for which IEEPA duties were paid or have been deposited.”

Phase 1, however, will now accept entries with liquidation status of Suspended, Extended or Under review. These were originally going to be addressed in later Phases. These types of entries, however, will not have refunds processed and liquidated as other liquidation statuses and will be refunded during the normal liquidation timeframe.

In addition, warehouse entries will now be included in Phase I. Just like the Suspended, Extended or Under Review liquidation statuses, the IEEPA duty refund will be processed during the normal liquidation timeframe.

Reconciliation entries, draw back claim entries, open protested entries and ADD/CVD entries with liquidation suspension orders from Commerce will not be accepted by CAPE in Phase I.

According to the Declaration CBP has provided the following updates.

• Claim Portal – 85% complete
• Mass Processing – 60% complete
• Review & Liquidation – 80% complete
• Refunds – 75% complete

These totals indicate an average completion change of about 10% from the March 19 update.

The next day on April 1, the CIT issued an updated order, stating that Customs has confirmed that CAPE development is still on track for April 20, 2026 completion of Phase I. It further orders CBP to provide another update on or by April 14, 2026, and another closed conference to take place that same day.

The court also reminds importers to sign up for CBP’s ACH refund process within ACE, as this will be the primary method for importers to receive any type of duty refund.

 

Section 232 Pharmaceuticals

On April 2, President Trump issued a Proclamation setting additional Section 232 duties on imported pharmaceutical and active pharmaceutical ingredients (APIs). An announcement was originally arranged for last October but was delayed. Much of the pharmaceutical industry has avoided many of the Trump administrations tariffs from last year as they’ve been exempt from IEEPA reciprocals, Fentanyl and secondary tariffs put on India. In addition, many imported drugs are unconditionally duty free when imported into the US base on MFN rates. However, starting in 120-180 days, a tariff as high as 100% will now be assessed on pharmaceutical and related ingredients imported into the US. Just like with other 232 cases, Free Trade Agreements will have no effect.

Implementation Dates

• July 31, 2026 – Companies mentioned by name in Annex III to the Proclamation.
• September 29, 2026 – All other importers.

Duty Rates

• 100% duty on import of patented pharmaceuticals and APIs in Annex I.
• 20% duty on import of patented pharmaceuticals and APIs for companies that are approved by the Secretary to onshore production.
  • 20% to increase to 100% after 4 years (4/2/2030).
  • 0% until 1/20/2029 if secretary approves AND has agreed to MNF pricing.
  • Further details about onshoring criteria will be published at a later date.
  • Onshoring plans must be approved by the Secretary of Commerce.
  • Companies will have to submit periodic reports to Commerce.
• 0% additional duty on generic pharmaceuticals and ingredients. Generic pharmaceuticals are not currently subject to Section 232 duties, however, will be re-evaluated in one yar.
• 15% duty on pharmaceuticals from Japan, the European Union, the Republic of Korea and Switzerland and Liechtenstein
• 10% duty on pharmaceuticals from the United Kingdom. Subject to reduced rates down to 0% to the extent required by any future agreement between the United States and the United Kingdom on pharmaceutical pricing.

0% additional duties imposed on patented pharmaceuticals and APIs made by companies that have fully executed agreements or are currently negotiating agreements with the Department of Commerce.