Is your product covered by Section 232? Scope by HTS line and the metal content rules

Short answer: A product is covered by Section 232 when its HTSUS (US Harmonized Tariff Schedule) classification appears in the annex or U.S. note that implements one of the Section 232 proclamations, and when it also meets any extra condition written there, such as a product description, a metal-weight test, a technical parameter or an end use. As of October 2026 the Section 232 tariff products are steel, aluminum and copper articles and their derivatives, passenger vehicles and parts, medium- and heavy-duty trucks, buses and parts, softwood lumber and certain wooden furniture and cabinets, certain advanced chips, patented pharmaceuticals, and drones, at rates from 10% to 100%. For the metals, the duty has applied to the full customs value since April 6, 2026; metal content now counts only for the 15% weight floor, the 10% rate for US-melted or US-smelted metal, the UK rates and the melt and smelt countries reported on the entry.

Below: where each action writes its scope, how to read an annex against a 10-digit line, the classification calls that move a product in or out, the value the rate is charged on, and what to weigh, ask suppliers for and keep when a metal-content test applies. Rates and dates in this article were checked against the Federal Register proclamations and the U.S. Customs and Border Protection (CBP) CSMS messages listed under Sources on October 23, 2026.

What is Section 232?

Section 232 of the Trade Expansion Act of 1962 (19 USC 1862) lets the President adjust imports, usually with an additional ad valorem duty, after the Commerce Department finds they threaten to impair national security. Each action is a proclamation with annexes of HTSUS provisions, which CBP turns into Chapter 99 headings and filing instructions in CSMS (Cargo Systems Messaging Service) messages.

The February 2026 IEEPA ruling did not touch Section 232, but its scope changes by proclamation: the metals regime was rewritten on April 6 and again on June 8, 2026.

How does each current action define its scope?

Every Section 232 action starts from a list of HTSUS numbers, but the lists are drawn at different levels and several add a second test. Rates below are headline rates as of October 2026; country rates and zero-rate headings sit underneath them.

Two things in that table decide most coverage questions: the level of the list (the chip action names 6-digit subheadings, the timber action 8-digit lumber lines and 10-digit furniture and cabinet lines, the metals annexes both) and the extra condition, which can send a listed line to a zero-rate heading. Treat the list as open. The newest Section 232 proclamation, signed October 22, 2026, covers wind turbines and their components; it directs Commerce and USTR to negotiate with trading partners, sets no new tariff and leaves the metals duties on turbine components unchanged.

Which steel, aluminum and copper articles are covered?

Steel, aluminum and copper coverage is set by the annexes to Proclamation 11021 and Proclamation 11032, and the annex a line sits in sets its rate. Proclamation 11021 also ended the old derivative inclusion processes and lets Commerce and the U.S. Trade Representative (USTR) add derivatives on a rolling basis.

• Annex I-A: all aluminum and steel articles, most copper articles and certain derivatives, at 50% (heading 9903.82.02), or 25% for qualifying UK goods (9903.82.04).
• Annex I-B: other copper articles and derivatives, at 25% (9903.82.09), or 15% for qualifying UK goods (9903.82.05).
• Annex I-C: certain aluminum and steel articles added on June 8, 2026 by Proclamation 11032, at 25%, or a 15% total with column 1 for goods of 10 listed economies and the EU (heading 9903.82.22), through 2027.
• Annex III: certain industrial and power equipment, plus agricultural equipment and certain residential HVAC since June 8, 2026, where column 1 plus Section 232 equals 15% until December 31, 2027 (9903.82.10 and .11), then the Annex I-B rates.
• Annex II: products removed from the steel and aluminum duties.

Aluminum from Russia stays at 200% under 9903.85.67 and 9903.85.68, and a good listed as an article of two or three metals is charged the metals duty only once (Proclamation 11021, clause 9). Lines still get added: Proclamation 11032 brought aluminum lithographic plates and steel racks into scope, which CBP implemented by adding 3701.30.00, 9403.20.0075, 9403.20.0082 and 9403.99.9040 (CSMS 68855869).

How are timber, vehicles, chips, drugs and drones scoped?

Timber and wood products are scoped by named lines: listed 4403, 4406 and 4407 subheadings for softwood lumber, four 9401.61 statistical lines for upholstered wooden furniture and three 9403 lines for kitchen cabinets and vanities (CSMS 66492057). Proclamation 11000 postponed increases to 30% and 50% until January 1, 2027. The furniture side is worked through in our Chapter 94 guide to chairs, cabinets and Section 232.

Vehicles split into two actions. Auto parts are on the parts list or certified for US vehicle production or repair; trucks, buses and their parts are defined in U.S. note 38, and parts of Chapters 72, 73 and 76 cannot use the certification route (CSMS 66665333).

Semiconductors, pharmaceuticals and drones each add a test beyond the HTS number. The chip action covers logic integrated circuits, or articles containing them, under 8471.50, 8471.80 or 8473.30 only inside two narrow performance windows, with seven zero-rate end-use headings such as US data centers and research (CSMS 67400472). The pharmaceutical action asks whether the product is patented and who made it. The drone action asks about take-off weight and thermal imaging (CSMS 69738151).

How do you read an annex against your HTS code?

Reading an annex against your HTS code takes six steps, in this order. Skip step 1 and every later step inherits the error.

1. Confirm the 10-digit HTSUS number for the product as imported, using the General Rules of Interpretation (GRI) and the legal notes, and write down why.
2. Open the U.S. note in subchapter III of Chapter 99 for each action (note 16 for metals, 38 for trucks, 40 for pharmaceuticals, 43 for drones) and the HTS list attached to CBP’s latest CSMS, and match at the level the list uses: a 6-digit subheading covers every line under it, a 10-digit line covers only itself.
3. Read the conditions beyond the number: description, metal weight and origin, technical parameters, end use, country of origin.
4. Pick the Chapter 99 heading, including zero-rate headings such as 9903.82.01 (no metal content), 9903.82.03 (under the weight floor), 9903.76.04 or 9903.79.02. A zero-rate heading is still reported.
5. Check the interactions: the metals duty does not apply to goods under the vehicle, truck or semiconductor actions, and Section 232 goods in the categories of U.S. note 52(f) are exempt from the 2026 forced-labor Section 301 duty under 9903.05.90, though China Section 301 list duties can still apply. Our guide to how tariffs stack on one HTS line covers the rest of the line.
6. Date the answer. Coverage depends on the date of entry, so record which CSMS and HTSUS revision you used.

Where does classification move a product in or out?

Classification moves a product in or out whenever two defensible codes fall on different sides of an annex line. Four patterns come up most.

The first is the same line split by description. CBP’s timber guidance puts 9403.40.9060, 9403.60.8093 and 9403.91.0080 under two headings: 9903.76.03 (25%) for completed kitchen cabinets and vanities and their parts, and 9903.76.04 (0%) for other products in those lines. Your product description has to say what the goods are; a copy of the HTS text is not enough.

The second is chapter choice for metal goods. The 15% metal-weight floor applies only to listed goods outside Chapters 72, 73, 74 and 76, so a steel bracket in Chapter 73 pays the annex rate however light it is, while a mostly plastic appliance in Chapter 84 or 85 may not. Section XVI Note 1 excludes parts of general use, as defined in Note 2 to Section XV, so a plain steel fastener or spring stays in the base-metal chapters even when it is shipped for a machine; our Section XVI parts guide covers that decision.

The third is which action a part belongs to. A forged steel component classified as an 8708 part on the auto-parts list pays the vehicle-parts duty, not the metals duty; classified in Chapter 73, it goes back to the metals annexes.

The fourth is end use. Headings 9903.82.23 to 9903.82.26 give lower rates to Chapter 84, 85 and 87 parts used exclusively in making agricultural, fixed industrial or mobile industrial equipment, and the chip action carves out seven end uses. Keep the end-use evidence on file before entry.

When a catalog has thousands of lines, these calls are hard to make consistently by hand, and most of them are settled at the heading and 6-digit level: Chapter 73 or Chapter 84, an 8708 part or not. TariffWolf returns the 6-digit HS code for each SKU with the GRIs, legal notes and CBP rulings behind it, and sends low-confidence items to a classifier for review. Your classifier or broker then picks the last four digits of the HTSUS line and matches that line against each annex.

What value does the Section 232 rate apply to?

For steel, aluminum and copper goods entered on or after April 6, 2026, the Section 232 rate applies to the full customs value of the article “regardless of metal content” (Proclamation 11021, clause 1). The other actions are also charged on full value, with three exceptions: USMCA-qualifying vehicles pay on non-US content, certain USMCA steel derivatives from Canada and Mexico report US content up to 40% of value on a separate zero-duty line (9903.82.21), and the Annex III, Annex I-C, pharmaceutical and capped drone headings work as combined rates with the column 1 duty.

A worked example, with invented figures: an importer brings in a $40,000 entry of a machine listed in Annex I-B, made in Vietnam from non-US steel, with $8,000 of steel content. Under the method used before April 6, 2026, the duty was charged only on the $8,000 of steel content. Now the 25% applies to the full $40,000, so the Section 232 duty is $10,000. If the machine were in Annex III with a 2.5% column 1 rate, the Section 232 rate would be 12.5% (15% minus 2.5%): $1,000 of column 1 duty and $5,000 of Section 232 duty. Either way the Vietnam forced-labor Section 301 duty does not apply, because Section 232 metals derivatives are exempted under heading 9903.05.90 (more in our Section 232 and Section 301 comparison).

When does metal content still matter?

Metal content still matters at five tests, each tied to a 9903.82 heading. Outside them, a covered article pays its annex rate on its whole value whether it is 95% steel or 20% steel.

Every test in that table is a share of weight except the last, where the 9903.82.21 line carries the US content at zero duty and the 9903.82.20 line carries the rest at 25% (CSMS 68855869). Russian aluminum cannot use the weight-floor heading (CSMS 68253075).

How is the 15% weight floor measured?

The 15% weight floor counts only the applicable metals for the HTS line, which Annex IV sets subheading by subheading. CBP’s example is 8302.10.60, where aluminum and steel count and copper does not (CSMS 68253075). A line that qualifies reports the aggregate weight of the applicable metals, in kilograms, as a second quantity.

A worked example, with invented figures: a listed countertop appliance classified outside Chapters 72 to 76 weighs 8.0 kg and contains 0.9 kg of steel, 0.2 kg of aluminum and 0.3 kg of copper winding. If Annex IV lists steel and aluminum for its subheading, 1.1 kg out of 8.0 kg is 13.75%; the line takes 9903.82.03 at 0% and reports 1.1 kg. If Annex IV also lists copper, 1.4 kg is 17.5%, and the appliance pays its annex rate on full value. Reclassified into Chapter 73, it would have no floor at all. Weigh from the bill of materials or a teardown (not a rounded supplier estimate) and keep the worksheet.

How do the US-melted and UK rates work?

A derivative article pays 10% instead of its annex rate when its metal content is “composed entirely” of steel melted and poured in the United States, or of aluminum or copper smelted and cast in the United States (Proclamation 11021, clauses 2(c) and 3(c)). “Entirely” is a defined threshold, not 100%: it was 95% from April 6, 2026, and Proclamation 11032 lowered it to 85% by weight for goods entered from 12:01 a.m. on June 8, 2026. For Annex III goods and for parts used only in agricultural or industrial equipment, the 10% is a combined rate with the column 1 duty.

The 85% test has a wording conflict. Clause 4 of Proclamation 11032 asks whether US metal is “at least 85 percent of weight of the aluminum, steel, and copper of the product”, which reads as one combined figure. CBP applies the test per metal by note subdivision and says the requirements “are cumulative”, so an article listed in more than one subdivision has to pass each one (CSMS 68855869). Entries are processed under CBP’s reading; document each metal separately and the file satisfies both.

Take a machine (invented figures) with 200 kg of steel, 180 kg of it melted and poured in Ohio, and 20 kg of aluminum smelted in Canada. The steel is 90% US-melted, which passes 85% (it would have failed the old 95%). If the line is in a steel subdivision only, it pays 10%. If it is also in an aluminum subdivision, it fails CBP’s cumulative test, and the combined reading fails too: 180 kg out of 220 kg is 81.8%.

The UK test stayed at 95%: at least 95% of the steel melted and poured, or of the aluminum smelted or most recently cast, in the UK (U.S. note 16(d)). CBP allows one exception: steel made by Tata Steel UK with a Netherlands melt-and-pour country may count toward the 95% for 9903.82.04 and 9903.82.05 until January 1, 2028 (CSMS 68554727).

What metal records should you collect and keep?

Entries of Section 232 steel and aluminum goods report the countries of melt and pour, or of smelt and cast (CSMS 68253075); steel origin here means where the steel was melted and poured, not where it was rolled. Four insulated copper conductor lines (8544.42.10, .20 and .90, and 8544.49.10) of non-US origin also carry the primary copper smelt country and the cast country under Additional Declaration Type Code 12 (CSMS 69252300), and since September 14, 2026 ACE rejects entry summaries without them (CSMS 69711865). “OTH” is allowed when a country is unknown, but an unknown country cannot support a US-metal claim.

Ask suppliers for these, once per part number, and again whenever they change mills:

• Net weight of the article and of the steel, aluminum and copper in it, from the bill of materials.
• For steel: the mill and country where each heat was melted and poured, with mill test certificates and heat numbers.
• For aluminum: the smelt country and the most recent cast country, with the smelter or casthouse certificate.
• For copper: the primary and any secondary country of smelt, and the country of cast.
• A signed statement tying the certificates to the purchase order or shipment.

Keep the certificates, heat or lot numbers tying them to the shipment, the weight worksheet, and the HTS line and Annex IV entry you used for 5 years (19 CFR 163.4). If CBP challenges a claim with real penalty exposure, involve a licensed customs broker or trade attorney before you answer.

What mistakes put the wrong Section 232 heading on an entry?

• Reusing a metal-content valuation after April 6, 2026; it understates the duty.
• Checking an 8-digit number against a list drawn at 10 digits, such as the timber lines or the steel rack additions.
• Treating a zero-rate heading as “not covered” and leaving the Chapter 99 number off the line.
• Assuming the US-metal 10% rate or a UK rate without mill or smelter evidence for the metal in that shipment.
• Weighing all three metals for the 15% floor when Annex IV lists only some of them for the line, or the reverse.
• Missing a line that was added after your last review, such as the June 8, 2026 additions or the 2027 drone components.

Related reading

• The forced-labor Section 301 tariff: 9903.05 headings by country, rates and exemptions
• Rely on an existing CBP ruling or request your own?
• Section 301 China tariffs: lists, rates, exclusions and how to lower the duty
• Is My Product ITAR or EAR?

Frequently asked questions

How do I know if my product is subject to Section 232?

Classify the product to its 10-digit HTSUS number, then look for it in the U.S. notes to subchapter III of Chapter 99 and the HTS list attached to CBP’s latest CSMS for each action. If it is listed, the extra conditions (metal weight, description, end use) pick the Chapter 99 heading; a failed condition usually means a zero-rate heading.

Is the Section 232 steel tariff charged on the steel content or the whole product?

For goods entered on or after April 6, 2026, the steel, aluminum and copper duties apply to the full customs value of the article, regardless of metal content, under Proclamation 11021. The rate depends on the annex: 50% for Annex I-A, 25% for Annex I-B, or a combined 15% for Annex III through 2027, as of October 2026. Metal content, measured by weight, still decides the 15% weight floor and the US-metal and UK rates.

Does USMCA exempt Canadian or Mexican goods from Section 232?

Mostly not. USMCA-qualifying vehicles pay only on non-US content, qualifying auto and truck parts can be exempt, and certain USMCA steel derivatives report US content up to 40% of value at zero duty. Otherwise the actions apply to Canadian and Mexican goods at the normal rates as of October 2026.

Is the 85% US-metal test per metal or combined?

Proclamation 11032 words it as a combined share of aluminum, steel and copper, but CBP’s guidance applies it per metal and says the tests are cumulative. Because entries are processed under CBP’s guidance, keep weights and melt or smelt records for each metal separately. As of October 2026, an article that passes pays 10% instead of its annex rate.

The coverage decision comes down to facts you control: the 10-digit HTSUS number, a description that shows which side of a split the goods fall on, and weights and mill records for any metal condition. Put them in the product master, note the CSMS each answer relied on, and re-run the check when CBP publishes a new Section 232 message.

If you need the classification settled across a whole catalog, TariffWolf’s bulk classification service works from your product file in the web interface or the Google Sheets and Excel add-on and returns each SKU’s 6-digit HS code with the notes and rulings behind it. Your team or broker then sets the last four digits and checks the line against the Section 232 annexes from a documented starting point. Start with a sample of your metal and machinery SKUs.

Sources

• Proclamation 11021 on aluminum, steel and copper, 91 FR 18201 (April 9, 2026)
• Proclamation 11032 (June 1, 2026)
• CBP CSMS 68253075, metals guidance (April 3, 2026) and CSMS 68855869 (June 5, 2026)
• CBP CSMS 66492057, timber and lumber (October 10, 2025) and Proclamation 11000 (December 31, 2025)
• CBP CSMS 66665333, trucks, buses and parts (October 29, 2025)
• CBP CSMS 67400472, semiconductors (January 14, 2026), CSMS 69395344, pharmaceuticals (July 30, 2026) and CSMS 69738151, unmanned aircraft systems (September 2, 2026)
• CBP CSMS 69252300, copper smelt and cast reporting (July 15, 2026), CSMS 69711865, error code update and CSMS 68554727, technical corrections (May 6, 2026)
• CRS Insight IN12545 on Section 232 auto tariffs (May 11, 2026) and the wind turbine proclamation (October 22, 2026)
• 19 CFR 163.4, record retention and Section XVI notes (2026 Schedule B, same HS legal text)