Section 232 Steel & Aluminum Derivatives in 2026: Why Auto Parts, Bearings, and Valves Got Caught in the Net

Section 232 now reaches a broad range of products across the manufacturing supply chain. More than the expanded steel and aluminum derivative-product measures now cover hundreds of HTSUS classifications across categories, including auto parts, bearings, valves, fasteners, appliances, and industrial equipment. 

A major change took effect on April 6, 2026. For many covered products, duty calculations shifted to the full customs value of the imported good rather than the value of the steel or aluminum content within it. The change affects how importers calculate duty exposure, evaluate sourcing decisions, and manage compliance across large product portfolios. The impact becomes more significant when Section 232 interacts with other trade measures. Depending on the product and country of origin, duties may also be affected by Section 301 tariffs and AD/CVD orders, increasing the importance of accurate classification and tariff analysis.

What Changed on April 6, 2026, and Why Every Section 232 Program Needs to Be Rebuilt? 

The April 2026 Section 232 restructuring changed how duties are calculated, which products are covered, and how importers determine tariff exposure.

Three changes had the biggest impact:

1. Duty calculations moved to full customs value: Many products that previously required a metal-content calculation are now assessed on the full value of the imported good.

2. A new annex structure was introduced: Core metals and closely related derivatives fall under Annex I-A, downstream manufactured products fall under Annex I-B, and certain industrial machinery and grid equipment fall under Annex III.

3. Some products were removed from scope: Annex II excluded approximately 144 product categories from Section 232 coverage, reducing the number of products subject to the derivative tariffs.

Additional rules were introduced as well. A de minimis exception applies to certain products where metal accounts for less than 15% of total product weight, while products made primarily from U.S.-melted and poured steel or U.S.-smelted and cast aluminum may qualify for reduced rates. The practical impact depends on the product. Goods with a high proportion of steel or aluminum may see a smaller change in duty exposure, while products with relatively low metal content can experience a much larger increase because the tariff now applies to the full customs value rather than only the metal-content portion.

For importers, April 6, 2026 became a clear dividing line. Product classifications, tariff calculations, and landed-cost assumptions that were accurate before the restructuring may need to be reviewed against the current framework.

How Did Section 232 Get From Raw Steel to Bearings, Valves, and Dairy Products? 

Six waves over eight years drove the expansion, each via Presidential Proclamation or BIS Federal Register notice. The statutory hook is the phrase "an article and its derivatives" in 19 U.S.C. § 1862, with no statutory cap on how far downstream "derivatives" extend.

Wave 5 marked a major expansion of the Section 232 derivatives framework. Products that would not traditionally be associated with steel and aluminum tariffs, including certain packaged consumer goods, industrial components, and automotive parts, were brought into scope through the August 2025 inclusions process.

The expansion highlighted how far the derivatives framework had moved beyond raw metals and closely related products. While many of those additions were later removed during the April 2026 restructuring, the period between August 2025 and April 2026 created significant compliance challenges for importers managing large product portfolios.

For importers with entries that remain unliquidated from that period, duty calculations and valuation methodologies may still require review, particularly where Section 232 assessments were based on metal-content calculations rather than the current full-value framework.

How Do You Compute the Duty Under the Post-April 6, 2026 Regime? 

Most products covered by Section 232 fall into one of three categories:

Annex I-A: Core metals and closely related derivatives

Includes many products classified in Chapters 72, 73, 74, and 76. These products are generally subject to a 50% duty on the full customs value.

Annex I-B: Downstream manufactured derivatives

Includes products such as bearings, valves, fasteners, and many manufactured goods added through the derivatives framework. These products are generally subject to a 25% duty on the full customs value.

Annex III: Certain industrial machinery and electrical equipment

These products are subject to a temporary 15% duty floor through December 31, 2027, after which they may move into the standard Annex I-B framework.

A few exceptions can affect the final duty calculation:

• Products containing less than 15% metal by weight may qualify for a de minimis exemption.

• Products meeting U.S.-origin metal requirements may qualify for reduced Section 232 rates.

• Country-specific provisions can alter the applicable duty rate.

Importers should also maintain documentation showing the origin of steel, aluminum, or copper inputs, as eligibility for reduced rates often depends on where those metals were melted, poured, smelted, or cast. Effective dates matter as well, since Section 232 changes generally apply from the implementation date regardless of when goods were shipped.

What Product Categories Are Now Caught in the Section 232 Net? 

The architecture sweeps sectors practitioners do not historically associate with "steel and aluminum."

Auto parts run on a dual track

Track A covers automobiles and certain automobile parts subject to the dedicated automotive Section 232 measures. These products are generally assessed at 25% of full customs value and span a wide range of classifications across automotive, industrial, and manufacturing categories.

Track B covers steel and aluminum derivatives under the broader Section 232 framework. Motor vehicle parts that fall outside the automotive measures may still be covered under the derivatives annexes, depending on their HTS classification. Anti-stacking rules prevent the same product from being assessed under both Section 232 programs, while certain USMCA-origin auto parts remain eligible for separate treatment subject to applicable requirements.

Bearings, valves, and fasteners

The treatment of steel fasteners before April 2026 remains the subject of ongoing litigation. The dispute centers on how Section 232 duties should have been calculated under the previous metal-content framework. One interpretation uses the full customs value of the fastener, while the other uses only the value of the steel input used to manufacture it.

Although the April 2026 restructuring moved many fasteners into the full-value Annex I-A framework, the outcome of the case may still matter for importers with unliquidated entries filed before the rule change.

How Does Section 232 Stack With Section 301 and AD/CVD? 

Section 232 is rarely the only duty applied to an import. Depending on the product and country of origin, it may be added on top of existing tariffs and trade remedies.

In most cases:

• MFN duty continues to apply.

• Section 301 tariffs apply in addition to Section 232 for many China-origin products.

• AD/CVD measures also apply separately where an applicable order exists.

Some tariffs do not stack. Products already covered by one Section 232 program are generally not subject to a second Section 232 tariff on the same import. Section 232 also replaces the temporary Section 122 tariff where both measures could otherwise apply.

A Chinese-origin ball bearing illustrates how quickly duties can accumulate:

As a result, the total duty burden can exceed 50% before any AD/CVD is added.

The same principle applies across many industrial products. A Chinese-origin valve may be subject to MFN duty, Section 232, and Section 301 simultaneously, while a comparable product imported from Germany may only face MFN duty and Section 232. Understanding which tariff programs apply is often just as important as determining the correct HTS classification.

How Do You Keep Section 232 Compliance From Drifting Through the Next Investigation? 

Section 232 continues to expand into new industries, with active investigations covering areas such as semiconductors, pharmaceuticals, critical minerals, commercial aircraft, robotics, industrial machinery, and medical equipment. As new derivative-product lists emerge and annexes evolve, importers need to continuously reassess classifications, origin requirements, and tariff exposure. 

Gaia helps simplify that process by automating HTS classification, Section 232 applicability checks, tariff calculations, and origin-traceability reviews before entry filing. From Annex I-A and Annex I-B determinations to Section 301 stacking, de minimis eligibility, and U.S.-metal carve-out requirements, Gaia helps teams evaluate duty exposure faster and with greater confidence.

Explore Gaia for free to see how AI-powered trade compliance workflows can reduce manual review time and support more consistent Section 232 decisions across large product portfolios.

Frequently Asked Questions

How does the de minimis exception actually apply at the entry desk?

The de minimis exception applies to certain non-Chapters 72-76 products where metal accounts for less than 15% of total product weight. The threshold is based on weight, not value. Importers must maintain documentation supporting the weight calculation, as CBP may treat the product as in-scope if adequate records are unavailable. 

What happens to a steel article when the country of melt-and-pour is unknown?

Reduced-rate treatment depends on documenting where steel was melted and poured and where aluminum or copper was smelted and cast. When origin cannot be established, CBP may apply the highest applicable Section 232 rate. Maintaining supplier certifications and mill documentation is therefore an important part of compliance. 

Does Express Fasteners affect prospective entries under the April 6, 2026 regime?

No. The dispute relates to duty calculations under the pre-April 2026 metal-content framework. Products covered by the current Annex I-A structure are generally assessed on full customs value, making the litigation primarily relevant to certain unliquidated entries filed before the rule change. 

How do you reconcile Annex III with the existing Section 232 framework?

Annex III applies a temporary 15% tariff floor to certain industrial machinery and electrical grid equipment through December 31, 2027. After that date, affected products are generally expected to move into the standard Annex I-B framework unless another provision applies.