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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On June 1, 2026, President Donald Trump issued a <a href="https://www.govinfo.gov/content/pkg/FR-2026-06-04/pdf/2026-11314.pdf" target="_blank" rel="noreferrer noopener">Proclamation</a> amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products.&nbsp;Section 232 of the Trade Expansion Act of 1962 authorizes the president to adjust duties on goods imported in quantities or under circumstances that threaten U.S. national security following an affirmative finding from a Department of Commerce investigation.
In recent modifications to these same Section 232 tariffs, an increasing number of these metal derivatives were scoped into the existing duty rates implemented under past Proclamations.&nbsp;For example, see Thompson Hine <a href="https://www.thompsonhinesmartrade.com/2026/04/president-trump-makes-major-changes-to-section-232-tariffs-on-aluminum-steel-and-copper/">Update of April 7, 2026</a>.&nbsp;This affected domestic industries that use agricultural equipment, industrial equipment and machinery, and other related products that tend to be predominantly composed of aluminum or steel.&nbsp;To address this concern, the Secretary of Commerce recommended temporarily reducing the tariffs on certain products imported into the United States. According to the White House, the purpose of the temporarily modified tariff rates is &ldquo;to more effectively address national security threats, spur investment in American agriculture, housing, and manufacturing, and facilitate U.S. production of related products.&rdquo;&nbsp;The modified tariff rates went into effect on June 8, 2026, and will expire on December 31, 2027.
Accordingly, the June 1, 2026 Proclamation (i) adjusts the tariffs on certain agricultural equipment, as well as certain other equipment, from 25% to 15%; (ii) temporarily modifies the scope of 15% tariffs on certain industrial equipment and machinery; and (iii) creates a 10% rate for certain foreign-made capital equipment that contains at least 85 percent U.S.-origin steel or aluminum by weight, provided the steel is US &ldquo;melted and poured&rdquo; or the aluminum is U.S. &ldquo;smelted and cast.&rdquo;
<ul class="wp-block-list">
<li>The Proclamation includes the lists of products (identified by the Harmonized Tariff Schedule of the United States (HTSUS) subheading) covered by these tariff modifications, as provided in the following annexes
<ul class="wp-block-list">
<li>Annex I-A &ndash; 50% Section 232 tariff remains in place and is applied to the full value of the covered steel, aluminum or copper articles for the identified HTSUS subheadings.</li>
<li>Annex I-B &ndash; 25% Section 232 tariff remains in place and is applied to the full value of the covered steel, aluminum or copper articles.</li>
<li>Annex I-C &ndash; Twenty-eight HTSUS codes under Chapters 84 and 87 covering industrial equipment and machinery are identified in this annex that will receive temporarily reduced tariff rates.</li>
<li>Annex II &ndash; Steel and aluminum derivative articles removed from the scope of Section 232 tariffs.</li>
<li>Annex&nbsp;III &ndash; Steel and aluminum derivative products whose Section 232 tariff rate is temporarily reduced for certain agriculture and HVAC equipment.</li>
<li>Annex IV &ndash; Subchapter III of chapter 99 of the HTSUS listing the changes for these modified tariff rates.</li>
</ul>
</li>
<li>For Annex I-C, certain products of Canada and Mexico that qualify for preferential tariff treatment under the United States&ndash;Mexico&ndash;Canada Agreement (USMCA), a duty of 25 percent shall apply only to the non-U.S. content of the product.</li>
<li>For Annex I-C, the Proclamation also provides preferential tariff treatment of 15% for certain products from other countries, including Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union.</li>
</ul>
Companies will need to carefully review the Proclamation and the Annexes to determine whether their articles or derivatives fall within the listed HTSUS subheadings. On June 5, 2026, CPB issued a Cargo Systems Message (<a href="https://content.govdelivery.com/bulletins/gd/USDHSCBP-41aa83d?wgt_ref=USDHSCBP_WIDGET_2" target="_blank" rel="noreferrer noopener">CSMS # 68855869</a>) offering guidance on the implementation of this June 1, 2026 Proclamation.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

Partner

David M. Schwartz

Francesca M.S. Guerrero

Samir D. Varma

International Trade

President Trump Modifies Section 232 Tariffs on Aluminum, Copper and Steel Imports