What U.S. importers need to know about Section 232 tariffs in 2025

Few trade measures have had as much impact on U.S. imports as Section 232 tariffs.

What began as a targeted tariff on steel and aluminum has significantly changed in 2025, with increased rates, expanded coverage, inclusion of derivatives, and new duty calculations.

For U.S. importers, navigating this system is now a critical compliance challenge. 

To help you navigate this complexity, this article covers what Section 232 tariffs are, which products fall within their scope, how to report derivative content, and the considerations to keep in mind.

What are Section 232 tariffs?

First introduced in 2018, Section 232 tariffs give the U.S. government authority to impose duties on imports that are considered to threaten national security.

These tariffs are administered under the Trade Expansion Act of 1962 and remain in place until modified by a presidential proclamation, following an investigation by the U.S. Department of Commerce. 

Section 232 initially covered only steel and aluminum, but its scope has expanded over time.

In 2025, the program was updated to include new industries, derivative products, and revised tariff levels.

Furthermore, the way duties are assessed was significantly updated in 2025.

Duties are now calculated either on the full value of the goods or, for derivatives, only on the value of the Section 232 material they contain.

Products subject to Section 232 tariffs

Section 232 tariffs apply to a defined list of products. These are:

Steel products

As of 2025, steel imports are subject to a 50% ad valorem duty for most countries, while the United Kingdom faces a reduced rate of 25%.  

The scope covers both raw steel (flat-rolled, long products, pipe, tubular goods) and certain derivative items, such as nails, staples, wire, and automotive components.

Aluminum products

Aluminum imports now carry a 50% ad valorem duty, with the UK capped at 25%.

Covered products include unwrought aluminum, bars, rods, foil, wire, alloys, and certain derivative goods such as finished parts and conductors. 

Copper products

A 50% ad valorem duty applies to imports of semi-finished copper, such as pipes, wires, rods, sheets, and tubes.

The same duty rate applies to derivative copper products, such as cables, pipe fittings, connectors, and electrical components.

Auto and auto parts

The Section 232 tariffs on vehicles now cover two distinct categories:

1. 1. Passenger autos and parts: First imposed in March 2025, these tariffs set a 25% global tariff on passenger vehicles (like sedans, SUVs, and light trucks) and certain auto parts. This measure includes reduced rates for key partners, such as 15% for Japan and 10% for the UK.
      
      
   2. Medium/heavy-duty vehicles and buses: In an action signed on October 17, 2025, the tariffs were expanded to cover medium- and heavy-duty trucks, truck parts, and buses, effective November 1, 2025. The duty rates are as follows:

• • • 25% tariff on imports of medium- and heavy-duty trucks and key parts (including engines, transmissions, tires, and chassis)

• • • 10% tariff on imports of buses (including school buses, transit buses, and motor coaches)

Goods subject to these vehicle tariffs (both passenger and heavy-duty) are not subject to additional sectoral 232 tariffs on steel, aluminum, copper, automobiles and automobile parts, and lumber.

They are also not subject to reciprocal tariffs or the tariffs imposed on Canada, Mexico, Brazil, or India.

The Secretary of Commerce shall develop a process for adding additional auto parts to the scope of the established tariffs, and domestic producers may request the inclusion of additional parts.

Wood and furniture products

Section 232 also applies to timber, lumber, and derivative wood products. The rates are:

• • 10% for softwood timber and lumber
  • 25% for upholstered wooden products (rising to 30% in 2026)
  • 25% for kitchen cabinets and vanities (rising to 50% in 2026)

The UK has a reduced cap of 10% on these products, while the EU and Japan have a 15% cap.

For derivative products, the duty is assessed only on the value of their Section 232 content. When the content value is unknown or equals the total value, the full value must be used.

Steel and aluminum imports from Russia are subject to a 200% tariff.

Other products currently under Section 232 investigation

The U.S. Department of Commerce is actively conducting Section 232 investigations into several other industries.

Tariffs may be imposed on these imports if they are found to pose a threat to national security. 

The list of products under active investigation includes:

• Semiconductors and semiconductor manufacturing equipment
• Pharmaceuticals and their ingredients
• Critical minerals and their derivatives
• Commercial aircraft and jet engines
• Polysilicon and its derivatives
• Unmanned Aircraft Systems (UAS) and their parts and components
• Wind turbines
• Robotics and industrial machinery
• Personal Protective Equipment (PPE), medical consumables, and medical equipment

How to report the value for derivative products

For derivative products, the tariff applies only to the value of the Section 232 content.

However, for Russian steel and aluminum, the 200% duty is assessed on the entire value of the imported good.  

Importers must use a "two-line" entry method to report the customs value for their goods:

• Line 1 (non-subject content): Report the product's HTS code with the value of non-subject parts. Pay all duties to this value.
• Line 2 (subject content): Report the same HTS code but with the value of only the subject material. Apply the specific Chapter 99 duty to this value.

If the content value is unknown, the tariff must be paid on the entire value of the product.

Exclusions and inclusions

As of 2025, importers can no longer file new exclusion requests for steel and aluminum, but existing exclusions remain valid until they expire or their approved volumes are used up.

In place of exclusions, the U.S. Department of Commerce has introduced an inclusions process.

Rather than removing products from tariff coverage, this process allows stakeholders to request that new derivative products be added to the scope of Section 232.

This process runs three times a year (January, May, and September) and includes a public comment period, after which decisions are issued within 60 days.

Key considerations for U.S. importers

To avoid unexpected duties or compliance issues, we recommend keeping the following points in mind:

Confirm HTSUS classification

Correct tariff classification is the foundation of Section 232 compliance. Duties are assessed through specific subheadings in Chapter 99, and classification errors can result in incorrect duty rates or penalties. 

Ensuring your goods map to the correct subheadings is a critical first step towards compliance.

Check for derivative coverage

Many finished goods that use Section 232 products are now included as derivatives.

A careful review of finished goods is essential, as these items are easily overlooked and may represent a compliance risk.

Review country caps and exemptions

Tariff levels are not always similar for all countries of origin. Some trading partners are subject to reduced rates or are covered by negotiated caps.

Factoring these varying duty levels by origin into your sourcing strategy is key to ensuring you’re not paying more than you should.

How Cole International can help

Section 232 tariffs introduce an added layer of complexity to U.S. imports. With constantly updated rates and expanded coverage of derivative products, staying compliant requires close attention to detail. That’s where we come in.

At Cole International, we offer customs brokerage and trade consulting services to help U.S. importers navigate changing regulations with confidence and ensure compliance. 

Our team works with importers every day to:

• Verify HTSUS classification and ensure products are classified correctly under Chapter 99 provisions
• Monitor Section 232 coverage and new additions for both raw materials and derivative products
• Track partner-country arrangements and caps to identify opportunities for reduced rates
• Review all import documentation to ensure correctness, completeness, and full compliance

We don’t believe in guesswork. We get it right the first time.

If your imported goods may be subject to Section 232 tariffs, reach out to one of our trade professionals to determine their correct classification and ensure compliance.