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What happened?
President Trump issued a Proclamation on June 1 further modifying the Section 232 tariff regimes applicable to imports of aluminum, steel, copper, and certain derivative products. The Proclamation establishes a temporary tariff framework, effective June 8, 2026 through December 31, 2027, for certain products identified in Annex I-C, including a generally applicable 25% duty rate, alternative tariff treatment for products from specified trading partners, and special rules for qualifying United States–Mexico-Canada Agreement (USMCA) products.
This Proclamation also lowers the threshold for qualifying US-origin steel or aluminum content from 95% to 85%, expands eligibility for the temporary 15% tariff treatment previously available for certain fixed industrial machinery and power equipment to include specified agricultural equipment, mobile industrial equipment, and certain predominantly residential HVAC systems and components, and adds aluminum lithographic plates and steel racks to the scope of existing Section 232 measures. The White House also released a fact sheet describing the administration’s rationale for the action and highlighting relief provided to certain downstream manufacturing sectors.
Why is it relevant?
This Proclamation could materially affect importers of agricultural equipment, HVAC systems and components, mobile industrial equipment, machinery, aluminum lithographic plates, steel racks, and other covered derivative products. The action also changes the threshold for products to be treated as made “entirely” from US-originating aluminum, steel, or copper from 95% to 85% by weight, which could create new opportunities for importers to qualify for lower tariff rates where sufficient US-origin metal content can be documented.
It also highlights the administration’s continued use of Section 232 authorities to modify US tariff policy. This Proclamation was issued as the Department of Justice pursues an appeal of recent court decisions involving certain tariffs imposed under the International Emergency Economic Powers Act (IEEPA), underscoring the growing importance of Section 232 as a mechanism for implementing the administration’s trade agenda.
Actions to consider
Companies should identify whether imported products are covered by the new annexes and assess whether the June 8 effective date affects open purchase orders, in-transit goods, or customs entries. Importers also should evaluate whether products could qualify for reduced rates based on country of origin, USMCA preferential treatment, Column 1 duty rates, or US-origin metal content. Companies seeking to claim US-content-based treatment should consider and maintain the appropriate documentation, particularly because the Proclamation directs US Customs and Border and Protection (CBP) to issue guidance regarding the determination of US content and authorizes penalties in cases involving fraud or deliberate misrepresentation.
For more details, read the full Tax Insight here.
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