Update on Refunds, Enforcement Trends, and What to Do Next
On June 1, the Trump Administration released a proclamation announcing adjustments to Section 232 tariffs on certain metal-based products, effective 12:01 a.m. ET on June 8, 2026.
The administration is lowering 232 tariffs on agricultural equipment, Industrial Equipment, and HVAC. Tariffs on agricultural machinery, such as combines and harvesters, as well as residential HVAC systems, will drop from 25% to 15% from certain countries of origin. The proclamation also introduces a new incentive tied to U.S. sourcing. As stated by the White House, it “encourages foreign companies to use more U.S. steel and aluminum” by allowing them to qualify for a reduced 10% duty rate if their equipment contains at least 85% down from 95% U.S. melted and poured steel or smelted and cast aluminum or U.S. copper by weight. These tariff changes are temporary and will remain in effect through December 31, 2027.
On the other hand, the proclamation also adds steel racks under subheadings 9403.20.0075, 9403.20.0082, and 9403.99.9040 and aluminum lithographic plates under subheading 3701.30.00 to the list of goods subject to 25% Section 232 tariffs on steel and aluminum derivatives, respectively. Those changes also take effect June 8.
Eligibility for a reduced or modified tariff rate depends on whether the product is specifically listed in the annexes to the proclamation, linked below.
Key Details
- Effective June 8, 2026, HTSUS provisions and product lists under prior proclamations will be modified as outlined in Annexes I‑A, I‑B, I‑C, II, III, and IV to the proclamation.
- Importers must review the annexes to determine whether their specific products and HTS numbers are affected.
- A 25% tariff remains at the baseline rate unless a lower rate applies.
- For certain countries (including the EU, UK, Japan, and others), imports of products listed in Annex I-C:
- If the chapter 1-97 HTS duty rate is below 15%, total duties will equal 15%.
- If the chapter 1-97 duty rate is 15% or higher, no additional Section 232 tariff applies.
- A 10% tariff applies where steel or aluminum content is entirely sourced and processed in the U.S. under the proclamation’s rules.
- For imports from Canada and Mexico under USMCA of products listed in Annex I-C:
- The 25% tariff applies only to non-U.S. content.
- Total effective duty cannot be less than 15%.
- CBP will issue guidance on calculating U.S. content.
- Penalties may apply for misrepresentation.
- If multiple tariff rates apply, the lowest applicable rate will be used.
- A product is considered U.S.-sourced for tariff purposes if at least 85% of its metal content by weight is produced in the U.S.
- Beginning January 1, 2028, tariff rates will revert to those established under prior proclamations.
What This Means for You
- These changes may impact your imports depending on product type, country of origin, trade agreement eligibility, and the percentage of U.S. steel or aluminum content.
- Additional guidance from CBP is expected, particularly regarding content calculations and enforcement.
We will continue to monitor this closely and provide updates as more information becomes available. If you have questions about how this may affect your imports, please reach out to your Deringer representative or consult your Customs Attorney.





















