U.S. President Donald Trump has reshaped the Section 232 tariff regime on aluminum, steel and copper through an executive order effective April 6, 2026. Under the new structure, 50% duty applies to the full value of semi-finished aluminum, steel or copper products (raw materials, coils, sheets), and 25% duty applies to the full value of metal-intensive derivative products (appliances, trucks, silverware, railway cars). Previously the tariff was levied only on the value of the metal content; the new regime expands the tax base to the entire value of the finished product, which the Cato Institute warns "will likely raise actual dollar costs for most importers of such products."
Two exemption mechanisms are embedded in the new framework: (i) the rate drops to 10% when at least 95% of the copper, steel and aluminum content in the product is U.S.-sourced; and (ii) goods are fully exempt if the metal content is 15% or less by weight. Items covered by Section 232 — levied on imports deemed critical to national security — remain exempt from the temporary global tariffs imposed under Section 122 of the Trade Act of 1974. The inclusion of copper is new this cycle: President Trump has asserted that "copper is the second most widely used material by the Department of Defense" and "indispensable" for critical U.S. infrastructure, an argument bolstered by copper's placement on the Department of Energy's 2023 critical materials list and the USGS 2025 critical minerals list.
Mark Herlach, an international trade lawyer and partner at Eversheds Sutherland (US) LLP, said Section 232 offers the president "a safe space if you want to exercise presidential discretion," but warned importers will now have to determine which new tariff annex applies to each product line: "In some cases this is a simpler approach, but you're still going to have to figure out which annex you're in. In some cases there's a temporary transitional regime that doesn't come into effect until the end of 2027. The takeaway is continuing complexity." Clark Packard, writing in an April 6 Cato Institute blog, was blunter: "Yes, the process has been simplified, but only through making many goods subject to heavier tariffs. Software can help with complexity, but no amount of computing power will get around this de facto tariff increase." The prior regime's content-based calculation was vulnerable to foreign-supplier content manipulation; the new full-value base closes that loophole but shifts cost onto importers.
From a supply chain perspective, three practical impacts emerge in procurement and customs operations: (1) the tariff base widens for importers of metal-intensive appliances, automotive aftermarket parts, transportation equipment and kitchenware — direct cost pressure of 10-25% on retail pricing is anticipated; (2) verifying whether U.S.-domestic metal content crosses the 95% threshold becomes a new compliance criterion in supplier selection — this effectively makes a "domestic content verification" line mandatory in supplier scorecards; (3) because designs below the 15% weight threshold are exempt, product engineering and packaging teams will be pushed to evaluate redesign opportunities that reduce metal usage. For Turkish exporters serving the U.S. market in aluminum/steel-content appliances, automotive and rail equipment, near-term order volumes are likely to soften, while a strong long-term scenario points toward regional production partnerships that meet the domestic-content requirement.
Key Takeaways:
1. New Section 232 regime in effect from April 6, 2026: 50% on semi-finished, 25% on derivatives, with tariff base expanded to full product value.
2. Rate drops to 10% if U.S.-sourced metal content >=95%; goods are exempt if metal content is <=15% by weight.
3. Copper is included for the first time, justified by DoD critical-material claims and the 2025 USGS critical minerals list.
4. Cato Institute: the process was simplified only by making many goods subject to heavier tariffs — net effect is a de facto tariff increase for importers.
5. Turkish exporters face near-term order softness and a medium-term shift toward regional production partnerships that meet U.S.-content requirements.
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