US President Donald Trump has signed a proclamation introducing structural changes to Section 232 tariffs on steel, aluminium and copper, effective as of Monday (April 6, 2026).
The measures revise how tariff rates are determined and adjust which derivative articles are covered.
National Marine Manufacturers Association (NMMA), a trade association representing boat, marine engine and accessory manufacturers in North America, says it is reviewing the proclamation and its annexes. It is currently advising its members to work with suppliers to identify the Harmonized Tariff Schedule (HTS) codes for imported components, parts and products, and to assess the impact of the revised full-value tariff structure and any applicable exemptions.
Updated framework for Section 232 tariffs
Under the updated framework, additional tariff rates apply to the full customs value of imported articles. No Section 232 tariffs apply to steel, aluminium or copper articles listed in Annex II, which includes some marine products. A 50 per cent rate applies to steel and aluminium articles, certain derivative articles and copper articles listed in Annex I-A. A 25 per cent rate applies to derivative articles listed in Annex I-B.
A 10 per cent rate applies to articles with US-origin metal content, defined as steel, aluminium or copper that is smelted and cast in the USA.
Articles outside chapters 72, 73, 74 and 76 of the Harmonized Tariff Schedule are exempt where the aggregated weight of steel, aluminium and copper content is 15 per cent or less of the total article. Annex IV sets out the criteria for determining eligibility for this exemption.
A temporary reduced rate applies to certain industrial and electrical grid equipment listed in Annex III. This is set at 15 per cent through to 31 December 2027, after which it reverts to 25 per cent.
The proclamation also removes the Section 232 inclusion process for derivative products, which previously allowed domestic producers to request that additional articles be subjected to tariffs on aluminium and steel. However, the Department of Commerce and the US Trade Representative retain the authority to add derivative articles on a rolling basis where imports are determined to pose a national security risk.
Existing agreements remain in place. Products from the United Kingdom, the European Union, Japan and South Korea continue to receive reduced tariff rates under current arrangements with the US.
NMMA says it will continue to engage with the administration, US Congress and industry stakeholders on the implementation of the measures.
For further information, NMMA directs enquiries to Clay Crabtree, interim vice president of public policy & government affairs.
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