Effective April 6, 2026, U.S. Customs and Border Protection (CBP) has implemented new trade measures introducing additional duties on certain steel, aluminum, and copper articles, as well as their derivative products.

These changes significantly expand duty exposure across multiple industries and introduce new compliance requirements that importers must carefully navigate.

Overview of the New Duties

Under the updated guidance, covered products are now subject to additional duties ranging from 10% to 50%, depending on the material and origin.

These duties:

  • Apply to imports from all countries, with some country-specific variations
  • Are implemented under HTS Chapter 99 (9903.82.xx)
  • Apply to both primary metals and certain downstream derivative products

The new measures broadly apply to:

  • Steel, aluminum, and copper articles
  • Derivative products containing these metals

For products composed of multiple metals:

  • Only one applicable duty rate will apply (not cumulative)

Importantly:

  • Goods without steel, aluminum, or copper content are not subject to these additional duties

Key Exemptions & Special Provisions

CBP has outlined several important exceptions:

  • Low Metal Content Threshold
    Products containing less than 15% steel, aluminum, or copper by weight are exempt from the additional duties
    (Note: This exclusion does not apply to goods classified under HTS Chapters 72–76.)
  • Manufacturing Incentives
    Certain motorcycle parts used in U.S. manufacturing qualify for 0% duty treatment
  • Existing Trade Frameworks
    Current provisions related to:
    • Civil aircraft
    • Trade agreements
      remain unchanged under this update

Country-Specific Measures

While the duties apply globally, certain countries are subject to unique provisions:

  • United Kingdom
    Reduced duty rates (15%–25%) may apply where 95% production thresholds are met
  • Russia
    • Steel and copper products: 10%–50% duties
    • Aluminum products: continue to face 200% duties under separate regulations

New Compliance & Reporting Requirements

To remain compliant, importers must ensure accurate and detailed reporting, including:

  • Proper classification under HTS 9903.82.xx
  • Material-specific origin reporting:
    • Steel: Country of melt and pour
    • Aluminum: Country of smelt and cast
  • Declaration of metal weight (in kilograms) when applying the 15% exemption rule

Additional reporting requirements for copper products are expected and will be released in future CBP guidance.

Additional Considerations

Importers should also be aware of the following:

  • Certain provisions are currently set to remain in effect through January 1, 2028
  • Duty drawback remains available for qualifying claims
  • Goods entering Foreign Trade Zones (FTZs) must be admitted under privileged foreign status
  • Chapter 98 provisions may still apply, though additional duties are generally enforced
  • Existing antidumping (AD), countervailing (CVD), and other duties remain in effect and are not replaced by these measures

Business Impact

These new measures introduce a higher level of complexity across:

  • Product classification
  • Supply chain sourcing decisions
  • Landed cost calculations

Failure to properly classify goods or meet reporting requirements could result in:

  • Delays at customs
  • Increased duty exposure
  • Potential compliance penalties

How Radius Can Help

At Radius International, we work closely with our clients to:

  • Review product classifications and HTS applicability
  • Identify potential duty exposure and cost-saving opportunities
  • Ensure full compliance with evolving CBP regulations

If you have questions about how these new duties may impact your shipments, our team is here to help.