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Section 232: the metal in the product taxes the whole invoice

A gas hob leaves the factory with an invoice value of $40,000. The steel in it is worth $9,000. In March 2026 that shipment paid Section 232 duty of $4,500. In April 2026 the same shipment, unchanged in every respect, paid $10,000. The headline rate on it fell from 50% to 25% in between.

That is not a paradox or a rounding artefact. It is the direct result of a proclamation signed on 2 April 2026, which changed what the duty is calculated on. Since 6 April 2026 the metals regime charges its rate against the entire customs value of the article. Before that date it charged 50% against the value of the steel, aluminium or copper inside it. Move the base from one-fifth of the invoice to the whole invoice and halving the rate still multiplies the bill.

This is the most expensive misreading in US import duty right now, and it is not a classification error — the HTS code is usually right. It is a failure to understand that Section 232 is no longer a tax on metal. It is a tax on products that contain metal, charged against everything else in the product too.

What the statute actually authorises

Section 232 of the Trade Expansion Act of 1962, codified at 19 U.S.C. 1862, lets the President adjust imports of an article after the Commerce Department finds that the article is being imported in quantities or under circumstances that threaten to impair national security. The finding is product-based, not country-based. That distinction matters more than any other in this area: Section 301 asks where the goods came from, Section 232 asks what the goods are made of.

Three consequences follow, and all three catch importers out:

• There is no expiry. Section 122 gave the President 150 days. Section 232 has no clock, which is why the steel and aluminium measures have been running since 2018 and why the forced-labour replacement for Section 122 was built on Section 301 rather than 232.
• Origin is largely irrelevant. A steel derivative from Germany, Korea, Turkey or Vietnam is in the same programme. The exceptions are negotiated or punitive: the United Kingdom rates, the 200% rate on Russian aluminium, and the USMCA carve-outs inside the automotive programmes.
• It is collected as a chapter 99 line. The duty does not appear in the tariff schedule next to your HTS code. It is assessed under the consolidated metals headings in the 9903.82 series, as a separate line on the entry summary, which is why a broker's quote built from the HTS book alone can be right about the MFN rate and wrong about the total by 25 percentage points.

Section 232 also turned out to be the durable authority. The Supreme Court's 6–3 decision in Learning Resources, Inc. v. Trump on 20 February 2026 held that the International Emergency Economic Powers Act does not authorise tariffs, and the Section 122 surcharge that replaced those tariffs expired on 24 July 2026. What remains standing is Section 301, Section 232 and Section 338. The section that was supposed to be the narrow national-security exception is now one of the three pillars holding the system up.

The change that moved the base

Until 5 April 2026 the metals regime applied its rate to the declared value of the steel, aluminium or copper content of a derivative article. On 6 April 2026, at 00:01 Eastern, that ended. The proclamation directed that the ad valorem tariff apply to the full customs value of metal articles and of derivative products alike.

The commercial logic of the change was straightforward: valuing the metal slice required an allocation nobody could audit, and under-declaring the metal content was an easy way to shrink the base. Taxing the whole article removes the allocation and removes the incentive. What it also does is import the entire customs valuation fight into Section 232 — because the higher the customs value, the higher the 232 bill. Anything you leave in the invoice that should not be there is now charged at 25%, or 50%. That is the reason how customs value is built has become a Section 232 question and not only an MFN one.

The tier ladder: three questions, five rates

The rate is no longer a single number that applies to a programme. It is the output of a short decision tree, and the branches are defined by how much metal the article contains and what the metal is for.

Two features of that ladder deserve more attention than they get. The first is the 15% cliff. It is not a sliding scale; it is a step. An article at 16% metal content pays 25% of its entire value. An article at 14% pays nothing under this regime. That is a discontinuity worth roughly $10,000 on a $40,000 entry, and it turns the metal-share calculation into the single most valuable number in the file.

The second is that the threshold is measured by value, not by weight. A dense machined part can sit well under 15% of value while being mostly steel by mass, and a light fabricated frame with cheap steel and expensive finish can sit above it. If your team has been answering the question in kilograms, the answer is to the wrong question.

Where Section 232 sits in the stack

Section 232 is cumulative. It adds to the ordinary duty, to the Section 301 China lists and to any antidumping or countervailing deposit, and none of those are reduced to make room for it. The full mechanics of that accumulation are in the duty layers guide; what matters here is the one subtraction.

Run the arithmetic on a $40,000 Chinese steel derivative on a 2.5% MFN line with a 25% list rate: $1,000 of MFN, $10,000 of Section 301, $10,000 of Section 232. That is $21,000 on a $40,000 entry, an effective rate of 52.5%, and the 12.5% forced-labour layer is not among the components. The single largest line on that entry is a national-security measure that has nothing to do with the country it came from.

One more interaction worth knowing if you source from Canada: the Section 338 duties on listed Canadian goods took effect on 22 August 2026 and stack on Section 232 for two of their three lists. The interaction is worked through on the Canada to US page. For China-specific context across product categories, the tariff panorama prices the same stack category by category.

The programmes outside metals

Metals get the attention because they reach consumer goods. They are not the whole of Section 232, and treating the phrase as a synonym for steel is how importers of completely different products get surprised.

The open investigations matter more than a footnote suggests, because Section 232 does not require a new statute to expand. The April 2026 proclamation replaced the fixed inclusion cycle with a rolling mechanism run jointly by Commerce and the USTR, which means new derivative products can be added without waiting for a review window. It also removed roughly 250 lines from scope, including parts used specifically in motorcycle manufacture, so the list moves in both directions. A product that was outside the regime last quarter is not evidence that it is outside it now.

How to find out whether you are caught

Start with the entry, not with the tariff book. If CBP assessed a 232 line, it is on the entry summary as a chapter 99 heading in the 9903.82 series, and it will be visible as a separate duty amount. If there is no such line, that is not proof you are clear — it means nobody has challenged it yet.

Then work the four questions in order, per part number rather than per shipment:

• Is the article wholly or nearly wholly metal? If yes, it is bulk and the rate is 50%. Most importers know this about coil and plate and miss it on chain, tube fittings and simple stampings.
• If not, what is the metal share by value? Build it from the bill of materials at the value declared on entry, not from weight and not from the supplier's estimate. Above 15% is 25% of everything; at or below 15% is out.
• Is the line on the metal-intensive equipment list? The 15% rate is a named list, not a category, and it has an end date.
• Where was the metal melted and poured? If it was US steel, US aluminium or US copper throughout, the 10% rate applies and the saving is real — but it is only available if the mill records prove it.

That fourth question is now an entry-level obligation rather than a due-diligence nicety. CBP expects the country of smelt and cast to be declared, and its audit trail runs through it: a change in declared country of smelt without a corresponding change of supplier, or a smelt origin that does not match the entered origin, is one of the standard triggers for a Form CF-28 request for information. A CF-28 gives you 30 days to answer, and an inadequate answer escalates to a CF-29 notice of action proposing rate advances or penalties. The origin question underneath it is the same one described in the country of origin guide, applied to metal rather than to assembly.

Relief that still exists

The exclusion route is closed and it is worth being blunt about it: Commerce stopped accepting and issuing exclusions from the steel and aluminium tariffs at 11:59pm Eastern on 10 February 2025, and revoked the general approved exclusions and the country-level alternative arrangements on 12 March 2025. Exclusions granted before that date stayed valid until they expired or their volume ran out, and the portal survives in read-only form to administer them. If a consultant offers to file a new steel exclusion request for you, the offer is being made about a process that no longer exists.

What does still work, in descending order of how much money it moves:

• Drawback on re-export. Section 232 duty is drawback-eligible. If the goods leave the United States again, up to 99% of the duty paid can be recovered under 19 U.S.C. 1313, and unused-merchandise claims can reach back over a five-year window. AD/CVD is not drawback-eligible, but the 232 and 301 layers stacked above it are — which matters because a mixed entry is where claims get partially denied.
• Export or supervised destruction. Merchandise destroyed under CBP supervision, or exported, before liquidation can escape duty it would otherwise owe. For a high-tier derivative that cannot be sold at the loaded cost, this is a real mitigation route rather than a theoretical one, and it has to be arranged before the goods enter commerce.
• Post-summary correction. If the tier was applied wrongly — metal share miscalculated, a US-melt line available but not claimed, an out-of-scope article swept into the regime — a PSC filed before liquidation corrects it cheaply. After liquidation the route is a protest under 19 U.S.C. 1514, with a 180-day window from the liquidation date.
• FTZ admission, with new arithmetic. A foreign trade zone still defers duty until entry, but the April 2026 proclamation tightened how metal products are treated on admission. The old assumption that you could admit on privileged foreign status and pay on the raw metal needs to be re-checked against the current rule before it is used to justify a location decision.

None of those routes fixes a wrong HTS code, and none of them is a substitute for getting the classification right in the first place. Classification is the input that decides whether Section 232 applies at all: finding the right HS code explains the six-digit to ten-digit path, and the tariff calculator prices a code once you have it. Engineering a product to sit under a different code is legitimate if the product genuinely changed; changing the code without changing the product is a false statement, and it is the version CBP penalises.

Where this fits with everything else on the site

Section 232 is one layer of a stack, and a layer is only dangerous when the others are already in place. The full order of operations is in the duty layers guide. The China-specific lists that sit next to it are in the Section 301 guide, and the surcharge that briefly competed with it — and carved Section 232 goods out of itself — is documented in the Section 122 guide. Where a case-specific order runs alongside the 232 duty, the AD/CVD guide covers the deposit mechanics.

On the product side, auto parts and machinery both carry Section 232 exposure through their own programmes, and the import duty calculator shows the effect of a metal share on a real entry. If you want the total landed number rather than the duty line alone, the landed cost calculator adds freight, insurance, MPF and the brokerage fee. Current verification dates for every corridor on the site are in the rate update history.

Frequently Asked Questions

What is Section 232 and who pays it?

Section 232 of the Trade Expansion Act of 1962 lets the President adjust imports on national security grounds after a Commerce Department investigation. The duty is paid by the importer of record, not the foreign seller, and it is assessed on top of the normal MFN rate. Unlike the IEEPA tariffs that the Supreme Court invalidated in February 2026, Section 232 has no expiry date and no 150-day clock, so it is now one of the load-bearing parts of the tariff system.

Does Section 232 apply only to raw steel and aluminium?

No. Since the April 2026 restructuring the metals regime covers finished goods made mainly of steel, aluminium or copper. Articles wholly or nearly wholly of metal pay 50% on the full customs value; articles with more than 15% metal content by value pay 25% on the full value; articles at or below 15% are outside the scope. Separate programmes cover automobiles and parts, trucks, semiconductors, lumber, patented pharmaceuticals, polysilicon and drones.

What changed on 6 April 2026?

The duty base moved from the value of the metal in the product to the full customs value of the product. Before that date a derivative with a 20% metal share paid 50% on that 20% slice. After it, the same article pays 25% on its entire customs value, which includes the labour, engineering, electronics, packaging and freight embedded in the invoice. On a $40,000 entry with $9,000 of steel, that is the difference between $4,500 and $10,000.

Can I still apply for a Section 232 exclusion?

For steel and aluminium articles, no. Commerce stopped accepting and issuing exclusions at 11:59pm Eastern on 10 February 2025 and revoked the general approved exclusions and country arrangements on 12 March 2025. Grants issued before that date remained valid until expiry or until their volume ran out. Relief now runs through drawback, export or supervised destruction, post-summary correction and protest, rather than product exclusions.

Does Section 232 stack with Section 301 and anti-dumping duty?

Yes. Section 232 adds to the MFN rate, to the Section 301 China lists and to any AD/CVD deposit. A Chinese steel derivative can carry MFN plus 25% Section 301 plus 25% Section 232 at once, which reaches 52.5% on a 2.5% MFN line. The one layer that switches off is the forced-labour Section 301 action of 24 July 2026, which does not apply where Section 232 already does.

Are USMCA-qualifying goods exempt from Section 232?

Not generally. The metals regime is a global product measure, so qualifying for USMCA does not remove a steel or aluminium duty. The automotive and truck programmes do contain USMCA carve-outs, but they turn on regional value content and where the vehicle or part was assembled, not on the certificate alone. Treat a USMCA claim as irrelevant to Section 232 metals unless the specific proclamation provides otherwise.