President Trump’s 2 April 2026 proclamation rewrites how U.S. Customs applies Section 232 tariffs on metals and introduces sweeping duties on patented pharmaceuticals. For goods entered on or after 6 April at 12:01 a.m. EDT, importers face higher costs, stricter documentation requirements and a tariff structure that applies to entire product values rather than metal content alone.
The changes affect steel, aluminium and copper articles listed across four annexes, with pharmaceutical tariffs rolling out in two phases through September. Freight forwarders must help clients navigate the new rules or risk costly surprises at the border.
Full Product Value Now Subject to Section 232 Duties
The most significant shift: tariffs now apply to the full customs value of imported products, not just the portion attributable to metal content. A product with 20% steel content and a $10,000 declared value previously faced duties on approximately $2,000. Under the new framework, the full $10,000 is subject to Section 232 tariffs.
This change applies to derivative products containing steel, aluminium or copper components. U.S. Customs and Border Protection began rate-advancing importers’ entries in late 2025 without formal notice-and-comment rulemaking, a practice now challenged in U.S. Court of International Trade litigation.
CBP’s Base Metals Centre of Excellence oversees classification and valuation enforcement. Importers must validate declared values and maintain detailed supporting records. The agency has increased scrutiny around documentation for metal origin and product composition.
Tiered Duty Structure Across Four Annexes
Annex I-A products face 50% ad valorem duties. This includes most steel and aluminium articles, copper products and certain derivatives. UK-origin steel and aluminium qualify for a reduced 25% rate if at least 95% of the metal is smelted, cast, melted or poured in the UK. U.S.-origin derivatives drop to 10%.
Annex I-B covers derivatives subject to 25% duties. UK steel and aluminium products meeting origin criteria receive a 15% rate. Copper remains at 25% regardless of UK origin. U.S.-origin articles again qualify for 10%.
Annex II lists products exempt from Section 232 tariffs. Importers should confirm current HTS classifications to determine if their goods appear on this exclusion list.
Annex III applies a temporary 15% compound rate through 31 December 2027 for metal-intensive industrial equipment and electrical grid components. After that date, the rate reverts to 25%. This window offers limited relief for capital equipment importers.
Russian-origin aluminium remains subject to a 200% duty regardless of annex classification.
De Minimis Exemption for Low Metal Content
Products containing less than 15% steel, aluminium or copper by weight qualify for exemption, but only if they fall outside HTS chapters 72, 73, 74 or 76. This de minimis provision requires precise weight documentation and clear HTS classification. Products within those four chapters remain fully dutiable regardless of metal percentage.
Pharmaceutical Tariffs Roll Out in Two Phases
Most patented pharmaceuticals and associated ingredients face 100% duties. Large companies listed in Annex III enter the regime on 31 July 2026. All other companies face the tariff from 29 September 2026.
Companies with Commerce Department-approved plans to relocate pharmaceutical production to the U.S. receive a reduced 20% tariff for four years, increasing to 100% on 2 April 2030. Onshoring commitments combined with most-favoured-nation agreements can secure 0% duties until 20 January 2029.
Generic pharmaceuticals, biosimilars and their ingredients are excluded from the new pharmaceutical tariffs. Specialty categories including orphan drugs, nuclear medicines, cell therapies and gene therapies also remain exempt.
Products from Japan, the European Union, Republic of Korea, Switzerland and Liechtenstein face 15% duties. UK pharmaceutical imports receive a 10% rate.
CBP Rolls Out CAPE System for IEEPA Refunds
CBP’s CAPE Phase 1 system processes refunds for International Emergency Economic Powers Act duties. Four integrated components handle claims, mass processing, review and liquidation-reliquidation, and refunds. As of 30 March 2026, the Claim Portal stood at 85% complete, Mass Processing at 60%, Review and Liquidation-Reliquidation at 80%, and the Refund module at 75%.
CAPE Phase 1 accepts declarations for entries liquidated within the previous 80 days. CBP has 90 days from original liquidation to initiate voluntary reliquidation and up to 45 days from acceptance of a CAPE Declaration to review and liquidate validated entry summaries.
Future CAPE phases will add enhanced features for reconciliation entries, drawback claims, complex interest calculations and entries with final liquidation status.
Manufacturing Drawback Offers Limited Relief
Section 232 tariffs may now qualify for manufacturing drawback in narrow circumstances. Importers can recover 99% of duties paid on articles meeting specific conditions, primarily products from Trade Agreement Partners with stringent metal origin requirements.
Drawback eligibility is limited. Products must meet strict metal sourcing criteria and undergo qualifying manufacturing operations in the U.S. before re-export. Freight forwarders should help clients evaluate drawback opportunities during the quoting process to provide accurate landed cost projections.
Foreign Trade Zones Lose Flexibility
Goods admitted into U.S. foreign trade zones on or after 6 April 2026 must enter under privileged foreign status. This restriction eliminates tariff planning strategies that previously allowed zone users to defer or reduce Section 232 duties through manufacturing or re-export.
Companies using FTZs for assembly, kitting or light manufacturing operations face immediate duty exposure on imported metal components. Zone strategies that worked before 6 April no longer provide tariff benefits for Section 232 goods.
Immediate Actions for Importers and Forwarders
Review HTS classifications product by product. The shift to full product value and expanded derivative coverage means goods previously outside Section 232 scope now face duties. Annex placement determines rate application.
Validate declared customs values. CBP scrutiny has intensified. Maintain detailed records showing how declared values were calculated, including breakdowns for materials, labour, overhead and profit.
Request metal origin certificates from suppliers. Products claiming UK or U.S. origin for reduced rates must prove at least 95% of the metal was smelted, cast, melted or poured in the qualifying country. Obtain these certifications before goods ship.
Calculate exposure on active purchase orders. Goods entering on or after 6 April face the new framework regardless of when the order was placed. Companies with containers in transit during the 5-6 April window should confirm entry timing with customs brokers.
Monitor for additional derivative product designations. The Department of Commerce and U.S. Trade Representative can jointly add new derivative articles on a rolling basis if import trends threaten Section 232 objectives. More than 400 derivative products were added in August 2025.
Why This Matters for Freight Forwarding
Section 232 changes ripple through every stage of the import process. Quote accuracy depends on correct annex classification and origin determination. Clients expect forwarders to flag duty exposure before goods ship, not after CBP issues liquidated damage bills.
The shift to full product valuation makes landed cost modelling more complex. A derivative product that previously cleared with minimal Section 232 impact now carries duties on 100% of its declared value. Forwarders who build these calculations into quotations protect client relationships and avoid disputes over unexpected costs.
Documentation requirements have tightened. Origin certificates, metal composition breakdowns and valuation support must accompany shipments claiming reduced rates. Missing or incomplete paperwork triggers rate advances to the highest applicable duty, with refund processes that can take months.
The pharmaceutical tariff rollout creates a second compliance deadline. Clients in pharma logistics need clear guidance on which products face 100% duties, which qualify for exemptions, and how onshoring commitments affect rates. These conversations should happen during the quotation phase, not at customs clearance.
Frequently Asked Questions
When do the new Section 232 tariff rules take effect?
The revised Section 232 framework applies to goods entered for consumption or withdrawn from warehouse on or after 6 April 2026 at 12:01 a.m. EDT. Goods entered before that date and time follow the previous tariff structure.
How is the new tariff calculated differently from the old system?
Section 232 duties now apply to the full customs value of imported products rather than just the value attributable to metal content. A product worth $10,000 with 20% metal content previously faced duties on $2,000. Now the entire $10,000 is subject to the tariff.
What documentation do I need to claim reduced rates for UK or U.S. origin metal?
Products claiming UK or U.S.-origin preferential rates must provide certificates showing at least 95% of the metal was smelted and cast, or melted and poured, in the qualifying country. Obtain these certifications from suppliers before shipment to avoid rate advances to higher duty levels.
Are all pharmaceuticals subject to the new 100% tariff?
No. The 100% tariff applies to patented pharmaceuticals and their associated ingredients. Generic pharmaceuticals, biosimilars, orphan drugs, nuclear medicines, cell therapies and gene therapies are exempt. Companies with approved onshoring plans receive reduced rates.
Can I recover Section 232 duties through drawback?
Manufacturing drawback is available for a limited set of products from Trade Agreement Partners that meet stringent metal origin requirements. Importers can recover 99% of duties on qualifying articles that undergo specific manufacturing operations in the U.S. before re-export. Eligibility is narrow and requires detailed documentation.
CSN Simplifies Complex Routing and Duty Planning
Section 232 changes add another layer to import cost modelling. Freight forwarders need tools that let them compare rates, calculate landed costs and present accurate quotes quickly. Cargo Solutions Network gives you access to global capacity, A2A and D2D options, and the workflow speed required to quote complex, multi-leg routes while accounting for the latest tariff structures. No subscription fees. No territory limits. Quote in minutes and keep the margin you earn.
