President Trump signed a proclamation on June 1, 2026 modifying the tariff treatment of imports of aluminum, steel, and copper and their derivative products imposed under Section 232 of the Trade Expansion Act of 1962 (see also the fact sheet accompanying the proclamation.)
The proclamation adjusts tariff rates and product coverage established under previous proclamations, including the April 2026 measures that introduced tiered ad valorem rates of 50%, 25%, and 15% based on product tariff code classification and country of origin/sourcing.
The main changes made by the proclamation are as follows:
- It lowers the tariff rates on certain aluminum and steel derivative products, including agricultural equipment, industrial equipment, and machinery (including certain heating, air conditioning (HVAC), and ventilation systems), from 25% to 15%, to mitigate the impact of “recent circumstances” on U.S. industries reliant on such inputs;
- It expands the scope of industrial equipment eligible for the reduced 15% duty rate to include mobile industrial equipment imported from countries that have trade deals with the U.S.;
- It adds two new categories of derivative products—steel racks and aluminum lithographic plates—to the list subject to a 25% duty rate to align with the broader Section 232 framework; and
- It lowers the 95% U.S.-origin threshold used to determine when the metal content of a product is considered to be made “entirely” from U.S. steel, aluminum, or copper to 85%, thus allowing foreign companies to be eligible for a 10% tariff rate and encouraging greater use of domestic steel, aluminum, and copper and downstream derivatives.
The tariff regime changes will apply from June 8, 2026 through December 31, 2027.
From a business planning perspective, the proclamation introduces both cost-relief opportunities and new compliance considerations for U.S. importers and manufacturers:
- Reduced duties on industrial and agricultural equipment may ease cost pressures for U.S. producers that rely on these inputs, particularly in sectors facing margin compression or supply chain volatility. Affected companies should reassess sourcing strategies and model potential savings under the temporary 15% rate;
- Expansion of the reduced rate category to mobile industrial equipment creates new incentives for importers operating in countries with U.S. trade agreements. Businesses may benefit from re-evaluating supplier networks to determine whether shifting production or assembly could unlock preferential treatment;
- New 25% duties on steel racks and aluminum lithographic plates may increase costs for industries such as warehousing, logistics, printing, and packaging. Impacted companies should review product classifications to confirm whether their imports fall within the new categories and consider mitigation strategies as needed;
- Lowering the U.S.-origin threshold may broaden the number of products eligible to qualify as “entirely” made in the U.S., potentially improving duty outcomes for manufacturers with mixed-origin inputs. Companies should revisit their origin determinations and update internal documentation and supplier certifications accordingly; and
- Because the reduced tariff rates are temporary, businesses should incorporate the December 31, 2027 expiration date into budgeting, long-term contracting, and supply chain planning.
Affected companies should evaluate the operational and financial implications promptly to capture benefits and manage new risks.
How BDO Can Help
BDO’s Customs & International Trade Services professionals have been closely tracking the Section 232 developments and are positioned to help your business navigate every dimension of this changing landscape. Our services include:
- Comprehensive product and HTSUS/Chapter 99 classification reviews;
- Tariff exposure modeling under full value Section 232 scenarios;
- Supply chain and sourcing strategy analysis to mitigate duty impact;
- Origin substantiation and melt-and-pour/smelt and cast documentation support;
- Foreign Trade Zone, duty drawback, and alternative duty management planning; and
- Ongoing monitoring of CBP guidance and Federal Register notices.