How Section 232 Tariffs Stack in 2026: Full Value, Exemptions and Caps

2026-11-12

Section 232 duties are the national-security tariffs. They started with steel and aluminum in 2018, and by late 2026 they cover a long list of product groups. Most people know the headline rates. What causes problems is how 232 duties stack with the base rate and with Section 301, and what changed in April 2026 about which value they're charged on.

DutyCite's calculator shows the 232 line on its own, citing the Chapter 99 heading and HTS note it came from. Below are those headings and notes, with a worked example.

Disclaimer: This is general information, not customs brokerage, legal advice or a binding classification. For a classification you can rely on, get a CBP binding ruling or use a licensed customs broker.

What Section 232 covers (as of Nov 12, 2026)

From the live HTS Chapter 99 heading text (USITC HTS):

Product group Example heading Additional duty
Articles of aluminum, steel, copper, and listed derivatives (note 16(c)(i)–(v)) 9903.82.02 + 50%
Other listed metal derivatives (note 16(c)(vi)–(viii), (xi)) 9903.82.09 + 25%
UK steel/aluminum articles meeting UK melt/smelt rules 9903.82.04 + 25%
Passenger vehicles and light trucks 9903.94.01 + 25%
Auto parts 9903.94.05 + 25%
Medium- and heavy-duty vehicles 9903.74.01 + 25%
Buses 9903.74.02 + 10%
Softwood timber and lumber 9903.76.01 + 10%
Upholstered wooden furniture; kitchen cabinets and vanities 9903.76.02 / .03 + 25%
Semiconductor articles 9903.79.01 + 25%
Patented pharmaceutical articles 9903.04.60 100%

Many of these have country-specific alternatives, mostly caps for partners with agreements (for example, Japanese auto parts: 9903.94.42/.43 for parts on the note 33(g) list, or 9903.94.54/.55 under note 33(r) for other automobile parts certified for US auto production or repair), plus onshoring and use-based exceptions. The table is a map, not a substitute for reading the note that applies to your product.

In 2026 the President also issued Section 232 proclamations on processed critical minerals, semiconductors, pharmaceuticals, commercial aircraft, polysilicon, unmanned aircraft systems, wind turbines, and robotics and industrial machinery (Federal Register document search). I haven't verified the rates from all of those proclamations for this post, so I'm not quoting them. Check the specific proclamation and its HTS note.

The April 2026 change: full customs value

Proclamation 11021 changed the base for metals duties. From 12:01 a.m. EDT Apr 6, 2026, the duties on aluminum, steel and copper articles and their derivatives "shall apply to the full customs value of the imported product, regardless of metal content." It set 50% for metal articles and listed derivatives, 25% for other derivatives, and a temporary 15% for a subset of machinery (Federal Register). A June 2026 proclamation widened that 15% group to include agricultural equipment and certain residential HVAC (Federal Register).

The current HTS U.S. note 16 puts this into practice (HTS Chapter 99):

How 232 interacts with other duties

With the base rate: it adds on top. A Free base rate doesn't change anything.

With China's 2018 Section 301 lists: they add together. Nothing in note 16 removes Section 301 duties, and note 16(b) keeps "other duties" in place. The stacked-rate post shows a China product carrying both.

With the July 2026 forced-labor Section 301 duties: they don't stack. U.S. note 52(f) and heading 9903.05.90 exempt articles of aluminum, steel or copper and derivatives under the 232 metal headings, and the same for 232 autos and parts, trucks, wood products, patented pharmaceuticals and semiconductors (USITC HTS). So for a product covered by 232, the 232 duty takes the place of the 10–12.5% forced-labor duty (Section 301 overview).

With caps: some partner arrangements turn the 232 add-on into a combined rate. For instance, note 16(e)–(f) use "the sum of the column 1 duty rate and the additional ad valorem rate" to reach 10% or 15% for certain derivatives that meet U.S.-content requirements (5).

Worked example: steel bolts from Vietnam

Assumptions: bolts, HTS 7318.15.20. Product of Vietnam. Customs value $50,000. Ocean freight. Formal entry. Not UK or Russian origin. No U.S.-melted steel claim. As of Nov 12, 2026.

Line Source Rate Amount
Base, 7318.15.20 USITC HTS, General (1) Free $0.00
Section 232, derivative steel, 9903.82.02 7318.15.20 is listed in note 16(c)(iv) (5) + 50% of full value $50,000 × 0.50 = $25,000.00
Section 301 forced-labor, Vietnam 9903.05.84 Excluded via note 52(f)(1) / 9903.05.90 (1) n/a $0.00
MPF 19 CFR 24.23 + FY2027 limits (6, 7) 0.3464% $173.20
HMF 19 CFR 24.24 (8) 0.125% $62.50
Total $25,235.70

If you'd applied Vietnam's 12.5% on top, you'd have overstated this entry by $6,250. The same bolts from China cost $12,500 more, because China's List 3 duty (9903.88.03, +25%) still applies. The stacked-rate post works through that case.

Before relying on these numbers, check for antidumping or countervailing duty orders on your specific fastener and producer (CBP AD/CVD). I didn't check those for this example. And re-verify every rate on your import date, because 232 proclamations have changed metals coverage several times this year.

A checklist for 232 products

  1. Is the 8-digit code (or the 4-digit heading) listed in the relevant 232 note? Metals are note 16, autos note 33, trucks note 38, wood note 37, semiconductors note 39 and pharmaceuticals note 40.
  2. If it's outside chapters 72/73/74/76, is the metal at least 15% by weight?
  3. Does a country-specific heading apply (UK, Japan, EU, Korea and others)?
  4. Does a content-based heading apply (U.S.-melted steel, U.S.-smelted aluminum)?
  5. Remove the forced-labor Section 301 line. Keep any China list duties.
  6. Add MPF/HMF (fees guide).

DutyCite's HTS lookup helps you find your code, and the calculator returns the Section 232 line alongside the base and Section 301 lines, each with an as-of date and source. The docs and pricing cover the developer side. See also CBP's Section 232 FAQs.

Checked Nov 12, 2026 against 2026 HTS Revision 23.

References

  1. USITC, Harmonized Tariff Schedule (live search; 2026 Revision 23). https://hts.usitc.gov/
  2. Federal Register, documents search. https://www.federalregister.gov/
  3. Federal Register, Proclamation 11021, "Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States," 91 FR 18201 (Apr 9, 2026). https://www.federalregister.gov/documents/2026/04/09/2026-06960/strengthening-actions-taken-to-adjust-imports-of-aluminum-steel-and-copper-into-the-united-states
  4. Federal Register, Proclamation 11032, "Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States," 91 FR 34085 (Jun 4, 2026). https://www.federalregister.gov/documents/2026/06/04/2026-11314/further-adjusting-the-tariff-regimes-for-imports-of-aluminum-steel-and-copper-into-the-united-states
  5. USITC, HTS Chapter 99, current release (U.S. notes 16 and 52). https://hts.usitc.gov/reststop/file?release=currentRelease&filename=Chapter%2099
  6. eCFR, 19 CFR 24.23. https://www.ecfr.gov/current/title-19/chapter-I/part-24/section-24.23
  7. Federal Register, CBP, FY2027 customs user fees, 91 FR 48398 (Jul 31, 2026). https://www.federalregister.gov/documents/2026/07/31/2026-15530/customs-user-fees-to-be-adjusted-for-inflation-in-fiscal-year-2027
  8. eCFR, 19 CFR 24.24. https://www.ecfr.gov/current/title-19/chapter-I/part-24/section-24.24
  9. CBP, Antidumping and Countervailing Duties. https://www.cbp.gov/trade/priority-issues/adcvd
  10. CBP, Section 232 Tariffs on Aluminum and Steel FAQs. https://www.cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-and-steel-faqs