The Section 232 Overhaul Is Here: Are You Paying More Than You Have To?

The tariff landscape shifted again this week, and if your business imports any products containing steel, aluminum, or copper, this update affects you directly. We sat down with our VP of Trade Compliance, Shannon Dillinger, to break down the latest Section 232 changes and what they mean for your bottom line.

What Changed — and Why It Matters

On April 2, 2026, President Trump signed a proclamation overhauling how Section 232 tariffs are calculated for steel, aluminum, and copper imports. The changes took effect April 6.

The most significant shift: previously, importers could calculate Section 232 duties based solely on the metal content value within a product — meaning if a product was only partially made of metal, you only paid the tariff on that portion. That methodology is gone.

As Shannon explained: "Now it's required that the duty will be paid against the entire value of the item. So that certainly doesn't work in a lot of importers' favor with paying these tariffs."

The New Rate Structure

Here's how Section 232 duties are now assessed:

• 50% on articles made entirely or almost entirely of steel, aluminum, or copper — such as steel coils or aluminum sheet
• 25% on derivative articles substantially composed of those metals
• 15% through 2027 on certain metal-intensive industrial equipment and electrical grid equipment
• 10% on products manufactured abroad using at least 95% U.S.-origin steel, aluminum, or copper
• Exempt if your product contains 15% or less by weight of steel, aluminum, or copper — a brand new exemption that did not previously exist
• Monitor your liquidation dates for entries closing in on the 180-day protest window
• File protests for anything approaching the closing window — this is time sensitive
• Set up your CBP refund account if you haven't already: ACH Refund | U.S. Customs and Border Protection
• Don't wait — the more proactive you are now, the better your chances of securing your refunds

Two Silver Linings Worth Knowing

While the full-value assessment adds cost for many importers, there are two meaningful upsides.

First, the new 15% by weight exemption is an entirely new category of relief. If the metal content in your products is relatively low compared to total weight — think footwear with metal eyelets, apparel with hardware, furniture, or consumer goods — you may qualify for a full exemption from Section 232.

"If there is a 15% or less by weight steel, aluminum, or copper content, then you're exempt," Shannon noted. "That again did not exist before. So if there is a low content of metal in comparison to the item by weight, then there's an exemption you can take advantage of today that didn't previously exist."

Second, the stacking rule has been eliminated. Under the old framework, if your product contained both aluminum and steel, you were required to pay a separate 232 tariff on each metal component. That requirement has been removed — a single tariff now applies to the article as a whole, which in some cases could actually reduce your overall duty costs.

Could You Qualify for the Exemption?

If your HTS classifications include products with any metal component — even minor hardware, fasteners, or structural elements — it's worth auditing the metal content by weight against the new 15% threshold. You may have more relief available than you think.

What We're Doing for Our Clients

Our compliance team began processing entries under the new rules on April 6. As Shannon shared: "We just got this through our first entry today. We're working to begin sending new entries this way, and we'll also be going through previous shipments that were handled and getting those adjusted appropriately."

If you're a current UWL brokerage customer, our team is already reviewing your impacted entries.

A Note on IEEPA Refunds

Separately, if you haven't already taken steps to prepare for potential IEEPA duty refunds, the clock is still ticking. The 180-day protest window is actively running on liquidating entries, and CBP's CAPE refund portal is nearing completion.

Shannon's advice: "What we're doing is trying to just feed data to our clients right now so that they can focus on protesting anything that needs to be protested. And then as soon as we have instruction from the Court of International Trade, we'll already have all the data pulled and the importer will already have it in hand."

Immediate Next Steps:

Our Recommendation: Act Now

Between the Section 232 restructuring and the approaching IEEPA refund window, this is a moment that rewards being proactive. Audit your metal content classifications, understand where the new exemptions apply, and make sure your entries are documented and protests filed where needed.

Not currently using UWL for customs brokerage? This is exactly the kind of situation where having the right partner makes a difference. Reach out to our team at compliance@worldgrouplogistics.com — we'll be happy to walk through your exposure and make sure you're prepared for what's ahead.