Section 232 Steel, Aluminum and Copper Tariffs Now Apply to Full Value: Recosting Tools, Lighting, Hardware and Appliances in 2026
From April 6, 2026, Section 232 duties on steel, aluminum and copper no longer apply only to the value of the metal content but to the full value of the goods: 50% for articles made essentially of these metals, 25% for derivatives, 15% for some equipment, 10% for goods made with U.S. metal, and nothing for goods with 15% or less metal by weight.
From April 6, 2026, Section 232 duties on steel, aluminum and copper changed method. Derivative products used to pay only on the value of their metal content; now duties apply to the full customs value of the goods. Articles made entirely or almost entirely of these metals pay 50%, derivatives made substantially of them pay 25%, some equipment pays 15% through 2027, and goods made abroad entirely with U.S. metal pay 10%. Goods with 15% or less of the relevant metal by weight are out. Importers of metal tools, lighting, hardware, shelving and appliances need to recost by HTS code.
How did it work before 2026?
In 2025, Section 232 duties on steel and aluminum rose to 50% on June 4, and copper and copper derivatives were set at 50% from August 1. For derivatives, the downstream goods that contain these metals, the duty applied only to the value of the metal content, which importers had to declare. Commerce also ran an inclusion process that added more codes to the derivative lists over time; many household appliances such as refrigerators and washers came in that way in 2025.
What did the April 2026 proclamation change?
The proclamation signed April 2, 2026 (Proclamation 11021) took effect at 12:01 a.m. Eastern on April 6. Based on the White House fact sheet and CBP's implementing guidance (CSMS #68253075):
Full value. The duty base is the full customs value of the goods; the metal content value is no longer split out.
Four tiers. Articles made entirely or almost entirely of steel, aluminum or copper pay 50% of full value. Derivatives made substantially of these metals pay 25% of full value. Certain metal-intensive industrial and electrical grid equipment pays 15% through 2027. Goods made abroad entirely with U.S. metal pay 10%. Russian-origin aluminum carries a separate, higher rate.
A 15% weight threshold. Goods outside the chapters for the metals themselves are excluded when the relevant metal is 15% or less of the article's weight. The threshold is by weight, not value.
One rate for multi-metal goods. A product containing steel and aluminum, or aluminum and copper, pays only one Section 232 rate; rates do not stack across metals.
No more inclusion requests. The derivative inclusion process ended; coverage is set by the proclamation's annexes and CBP's code lists.
What changed again from June 8?
A June 1, 2026 proclamation (Proclamation 11032) amended the April rules, with CBP guidance in CSMS #68855869 for entries on or after June 8. Highlights: several codes were added (including certain steel racks), a group of equipment codes (including some air-conditioning codes) moved to lower rates, the "entirely U.S. metal" threshold dropped from 95% to 85%, and certain goods from Japan, Korea, the UK, the EU and some other countries got a preferential 15% rate. Which code falls in which tier is listed code by code in CBP's attachments.
What it means for home improvement categories
Metal tools and hardware. Wrenches, pliers, saw blades, hinges and fasteners that are nearly all steel may fall in the 50% tier, on full value. For power tools in plastic housings, whether the metal exceeds 15% by weight and which code applies makes a large difference.
Lighting. Fixtures with aluminum housings or steel frames may be derivatives at 25% of full value; fixtures that are mostly plastic and glass, with 15% or less metal by weight, are outside Section 232.
Appliances. Refrigerators, washers and dryers were brought in as derivatives in 2025 and pay on full value from April 2026, where the cost change is most visible.
Shelving and storage. Steel racks were expressly added from June 8.
Cabinets and vanities. These carry a separate Section 232 wood-products duty: 25% from October 14, 2025, with the scheduled increase delayed to January 1, 2027.
How does it stack with Section 301?
Section 301 duties on Chinese-origin goods remain, generally 25% for Lists 1 to 3 and 7.5% for List 4A. The forced-labor Section 301 action adds 12.5% on Chinese-origin goods from July 24, 2026, but excludes Section 232 goods. So each product needs three checks: whether and in which tier it falls under Section 232, which Section 301 list it is on, and whether the 12.5% applies. IEEPA tariffs were stopped by the Supreme Court on February 20, 2026, and importers can claim refunds of amounts paid. Your customs broker's code-by-code determination controls.
An example: one shipment of steel tools, two methods
Example (hypothetical numbers, to show the method): a U.S. subsidiary imports steel hand tools from its Chinese parent with a customs value of $100,000, of which the steel is assumed to be worth $30,000, and the tools are assumed to be derivatives.
Under the 2025 method, the Section 232 duty is 50% of the $30,000 steel value, or $15,000. Under the method in force from April 2026, it is 25% of the $100,000 full value, or $25,000, which is $10,000 more. If the tools sit in the 50% tier, it is $50,000.
Section 301 at 25% adds $25,000 (the 12.5% does not apply to Section 232 goods). Duties on the shipment rise from about $40,000 to about $50,000 or $75,000, around half the goods' value.
Tax and pricing points
Duties are inventory cost. Duties, inbound freight and brokerage go into inventory and reach cost of goods sold when the goods sell, not as a deduction in the year paid.
The importer of record bears them. On direct import to Home Depot, delivered at the export port, Home Depot is usually the importer and the duty is its cost, though it shows up in price negotiations. If your U.S. company delivers duty paid, the duty comes straight out of your margin.
No "saving duty" by under-declaring. The Chinese parent's price to the U.S. subsidiary has to be arm's length under IRC §482, and under §1059A the subsidiary's income-tax cost for imported goods can't exceed customs value. Declaring low for customs and claiming a higher cost for income tax doesn't work. After a large duty increase, revisit whether the subsidiary's margin is still reasonable and adjust the pricing policy with documentation if needed.
Form 5472. A U.S. company 25% or more foreign-owned reports purchases from the Chinese affiliate on Form 5472 every year; each missed form starts at $25,000.
Contract terms. Who absorbs tariff changes and whether prices can be adjusted should be written into retailer supply agreements before signing; have a lawyer review the legal terms.
Next steps
Routes, compliance, entity choice and the full tariff layers for Home Depot suppliers are in the Home Depot guide; inventory costing for duties is in the Amazon FBA guide; parent-subsidiary pricing is in the U.S. subsidiary guide. Book a free 15-minute call or add WeChat YCLUSA.
Sources
White House fact sheet (2026-04-02)
Federal Register: Proclamation 11021 (published 2026-04-09)
CBP CSMS #68253075 (2026-04-03)
CBP CSMS #68855869 (2026-06-05)
IRS: Instructions for Form 5472
Last checked: November 9, 2026
This article is general tax information, not tax, legal or customs advice for any individual situation. Tariff rates are governed by the latest CBP and White House notices and your broker's code-by-code determination.
Questions this article answers
How are Section 232 steel and aluminum duties calculated after April 2026?
From April 6, 2026, they apply to the full customs value of the goods rather than the metal content value. Articles made entirely or almost entirely of steel, aluminum or copper pay 50%, derivatives made substantially of them 25%, some equipment 15% through 2027, and goods made abroad entirely with U.S. metal 10%.
Which goods are outside the Section 232 metals duties?
Under the April 2026 proclamation, goods outside the chapters for the metals themselves are excluded when the relevant metal is 15% or less of the article's weight. The test is weight, not value, so confirm by code and actual weight.
Do Section 232 and Section 301 duties stack?
Section 301 duties on Chinese-origin goods (generally 25% or 7.5%) still apply separately. The 12.5% forced-labor Section 301 action from July 24, 2026 does not apply to Section 232 goods. A product containing several metals pays only one Section 232 rate.
Can the Chinese parent lower its price to the U.S. subsidiary to offset higher tariffs?
Not freely. Related-party prices must be arm's length under IRC §482, and under §1059A the subsidiary's income-tax cost can't exceed customs value. The pricing policy can be revisited for the new duty levels, but it needs comparables and documentation.
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