Proclamation modifies Section 232 metals tariff framework
On 1 June 2026 President Trump signed Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” further modifying the § 232 metals tariff framework most recently overhauled by Proclamation 11021 of 2 April 2026, building on the original § 232 metals regime (Proclamation 9704 of 8 March 2018 for aluminum and Proclamation 9705 of 8 March 2018 for steel) and the § 232 copper regime added by Proclamation 10962 of July 2025.1234 The proclamation sets a 50 percent standard ad valorem duty on covered primary metals and a 25 percent rate on covered derivative articles, creates a 15 percent rate (or rate- equivalent tier) for specified industrial-equipment categories, and lowers the qualifying U.S.-origin metal threshold for preferential treatment from 95 percent to 85 percent.15 The proclamation comes after the U.S. Supreme Court held on 20 February 2026 in Learning Resources, Inc. v. Trump that IEEPA does not authorise tariffs and after the U.S. Court of International Trade held the § 122 surcharge unlawful on 7 May 2026 with an injunction limited to three plaintiffs.67 The instrument takes effect at 12:01 a.m. eastern daylight time on 8 June 2026; the framework runs through 31 December 2027, after which covered products revert to the rates set by Proclamation 11021.5
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The proclamation invokes § 232 of the Trade Expansion Act of 1962, 19 U.S.C. § 1862, with the Commerce Department investigation predicate at § 1862(b)(3)(A), presidential action authority at § 1862(c)(1), and subsequent modification authority at § 1862(c)(3)(A); § 604 of the Trade Act of 1974, 19 U.S.C. § 2483, is the companion authority for conforming amendments to the Harmonised Tariff Schedule.89 The proclamation’s Annexes I-A, I-B and I-C set out the covered primary-metal, derivative-article and industrial-equipment product groupings respectively; U.S. Customs and Border Protection collects under the unified HTSUS Chapter 99 subchapter III 9903.82.01 through 9903.82.26 series per CSMS # 68855869 of 5 June 2026.510 Modification of a prior § 232 action does not require a new Commerce Department investigation under § 1862(c)(3)(A); a Department of Commerce recommendation informed the 1 June 2026 modifications.5
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The Annex I-C industrial-equipment tier operates a four-tier country-of-origin rate structure: a 25 percent general rate; a calibrated 15 percent effective rate for products from Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom and European Union member states; a 10 percent rate for products incorporating U.S.-origin metals; and, for USMCA-qualifying Canadian and Mexican products, a 25 percent rate on the non-U.S. metal content with a 15 percent rate floor.5 The Secretary of Commerce will issue guidance to U.S. Customs and Border Protection on assessing U.S. content for USMCA products.5 Executive Order 14289 of 29 April 2025 establishes anti-stacking precedence for a closed set of five enumerated actions including § 232 steel and § 232 aluminum; the relationship between EO 14289 and the proclamation’s revised rate structure for derivatives and industrial equipment, and the treatment of the copper coverage, are to be verified against the proclamation’s coverage and stacking paragraphs.11
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The proclamation contains no exception for goods already in transit at the 12:01 a.m. EDT 8 June 2026 effective moment, consistent with prior § 232 actions.5 Industry and foreign-government responses to the modification follow established patterns: the American Iron and Steel Institute (a trade association for U.S. integrated steel producers), the Steel Manufacturers Association (electric-arc-furnace producers) and the Aluminum Association (U.S. aluminum producers) typically support § 232 expansions, while downstream-user trade associations (the Alliance for Automotive Innovation, National Association of Home Builders and others) and the Government of Canada and the European Commission (under Regulation (EU) 654/2014 enforcement-of-rights measures and Commission Implementing Regulation (EU) 2018/886 rebalancing measures) have opposed prior expansions.12 The Association of Equipment Manufacturers welcomed the 15 percent agricultural-equipment tier; no named on-record statements from the producer associations or foreign governments on the 1 June 2026 proclamation itself appear in the record as of publication.13
Footnotes
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Proclamation 11032 of 1 June 2026, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” 91 FR 34085 (June 4, 2026), FR Doc. 2026-11314. 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 ↩ ↩2
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Proclamation 11021 of 2 April 2026, “Strengthening Actions Taken To Adjust Imports of Aluminum, Steel, and Copper Into the United States,” 91 FR 18201 (April 9, 2026), FR Doc. 2026-06960; effective 6 April 2026. See Proclamation 11021 consolidates Section 232 metals framework. 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 ↩
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Proclamation 9704 of 8 March 2018, “Adjusting Imports of Aluminum Into the United States,” 83 Fed. Reg. 11619 (15 March 2018); Proclamation 9705 of 8 March 2018, “Adjusting Imports of Steel Into the United States,” 83 Fed. Reg. 11625 (15 March 2018). https://www.federalregister.gov/documents/2018/03/15/2018-05477/adjusting-imports-of-aluminum-into-the-united-states ↩
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Proclamation 10962 of 30 July 2025, “Adjusting Imports of Copper Into the United States,” 90 FR 37727 (Aug. 5, 2025), FR Doc. 2025-14893; effective 1 August 2025. See Proclamation 10962 imposes Section 232 copper tariffs. https://www.federalregister.gov/documents/2025/08/05/2025-14893/adjusting-imports-of-copper-into-the-united-states ↩
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Troutman Pepper Locke LLP, “President Trump Further Adjusts Section 232 Tariffs on Aluminum, Steel, and Copper,” client alert, 8 June 2026 (Tier 4 secondary source — law-firm client alert with named stake; corroborates the 1 June proclamation’s 50 percent primary / 25 percent derivative rates, Annex I-C four-tier country structure with 15 percent effective rate for specified countries, 95 percent → 85 percent U.S.-origin threshold, 31 December 2027 sunset with reversion to Proclamation 11021 rates, USMCA Secretary-of-Commerce guidance mechanism, and absence of in-transit exception). https://www.jdsupra.com/legalnews/president-trump-further-adjusts-section-9766800/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7
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Learning Resources, Inc. v. Trump, No. 24-1287 (consolidated with Trump v. V.O.S. Selections, Inc., No. 25-250), slip op. (20 February 2026). See Supreme Court holds IEEPA does not authorise tariffs. https://www.supremecourt.gov/opinions/25pdf/24-1287_4gcj.pdf ↩
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The State of Oregon v. United States and Burlap and Barrel, Inc. v. United States, Slip Op. 26-47 (Ct. Int’l Trade, 7 May 2026) (2-1; injunction limited to three plaintiffs). See CIT holds § 122 surcharge outside statutory authority; enjoins collection from three plaintiffs. https://www.cit.uscourts.gov/sites/cit/files/26-47.pdf ↩
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Trade Expansion Act of 1962, § 232, 19 U.S.C. § 1862; investigation predicate at § 1862(b)(3)(A); presidential action at § 1862(c)(1); subsequent modification at § 1862(c)(3)(A). https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title19-section1862&edition=prelim ↩
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Trade Act of 1974, § 604, 19 U.S.C. § 2483 (authority to embody in the Harmonised Tariff Schedule the substance of provisions of law affecting import treatment). https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title19-section2483&edition=prelim ↩
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U.S. Customs and Border Protection, CSMS # 68855869, “GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” 5 June 2026 (HTSUS 9903.82.01-9903.82.26; no separate CBP Federal Register implementing notice issued). https://content.govdelivery.com/accounts/USDHSCBP/bulletins/41aa83d ↩
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Executive Order 14289 of 29 April 2025, “Addressing Certain Tariffs on Imported Articles,” 90 Fed. Reg. 18907; anti-stacking precedence among five enumerated actions (§ 232 auto/parts, EO 14193, EO 14194, § 232 steel, § 232 aluminum). See EO 14289 sets anti-stacking precedence rules on certain tariffs. ↩
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American Iron and Steel Institute (https://www.steel.org/); Steel Manufacturers Association (https://www.steelnet.org/); Aluminum Association (https://www.aluminum.org/); Alliance for Automotive Innovation (https://www.autosinnovate.org/); National Association of Home Builders (https://www.nahb.org/); European Commission Regulation (EU) 654/2014 and Implementing Regulation (EU) 2018/886 (positions on prior § 232 expansions). ↩
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Association of Equipment Manufacturers, commentary welcoming the 15 percent agricultural-equipment tier of the 1 June 2026 proclamation. https://www.aem.org/ ↩