Section 232 Tariff Update: New 15% De Minimis Threshold Details for U.S. Importers

Executive Summary

A new Section 232 rule has created a real savings opportunity for some importers, but it is not a blanket exemption. For entries on or after April 6, 2026, certain derivative goods outside Chapters 72, 73, 74, and 76 may avoid Section 232 duties if the applicable steel, aluminum, or copper content is less than 15% of total product weight. At the same time, many covered derivatives now face duty on the full entered value, raising the cost of mistakes.  

Intro

Your latest shipment probably contains more regulated metal than you think. A steel bracket inside a medical device housing. An aluminum frame under a consumer electronics shell. A metal fitting buried in an industrial assembly.

None of these are “steel imports” in the way most people picture it. But under the updated Section 232 rules, they might owe duties anyway.

The new 15% de minimis threshold determines whether a finished good with incidental metal content gets hit with a Section 232 tariff or clears without it. And no, this has nothing to do with the low-value shipment de minimis rule you already know. The threshold here is about metal content by weight.

What follows is the operational breakdown for getting it right.

What Changed on April 6 Under Section 232?

First and foremost, the April 6 proclamation changed several things at once:

• Duties Now Apply to Full Entered Value: Customs used to assess Section 232 duties on the metal content alone. Now they hit the full customs value of the good. For products where metal is a small percentage of total cost, that difference stings.
• Some Derivative Products Lost Their Coverage: Many previously covered downstream goods no longer trigger Section 232 duties at all. Your broker should already be checking your classifications against the updated lists.
• A New 0% Pathway Exists for Low-Metal-Content Goods: HTS provision 9903.82.03 created a de minimis threshold: if steel or aluminum content falls below 15% by weight, the good may qualify for 0% Section 232 duty. Mixed-material importers across electronics, medical devices, fixtures, and consumer goods should pay close attention.

One distinction worth flagging early. The proclamation also created a separate Annex III framework granting temporary 15% tariff treatment to certain metal-intensive industrial and grid equipment through the end of 2027. 

Different products, different criteria. Don’t confuse the two.  

Which Products Can Qualify for the 15% Threshold?

The 0% pathway sounds generous until you read the fine print. Not every product with a little metal qualifies. The threshold applies only to goods listed under Annex IV/U.S. Note 16, and it completely excludes articles classified in HTS Chapters 72, 73, 74, or 76. 

For everything else, your product still needs to fall within the listed scope. If it does appear on multiple Annex IV lists, CBP requires you to use the aggregate weight of all applicable metals when calculating against the 15% threshold. 

Filing under HTS 9903.82.03 with a 0% duty rate doesn’t prove itself, either. CBP requires that the aggregate weight in kilograms be entered as a second quantity on the entry summary line. Without that documentation, the classification won’t hold.

So, what kinds of products can qualify in the first place? More than you might expect.

Electronics and Mixed-Material Components

Housings, enclosures, and assemblies where a steel or aluminum element supports a primarily nonmetal product. Think circuit board housings or device frames where metal sits well below 15% of total weight.

Retail Fixtures and Hardware

Shelving units, display racks, and store fixtures built from composite materials with minor metal framing or fasteners.

Consumer Goods With Incidental Metal

Packaged products where a small bracket, clasp, or internal support adds metal content without defining the good. Appliance accessories, furniture components, and household items often land here.

Industrial Equipment Parts

Subassemblies and replacement parts where metal plays a structural but minor role by weight relative to plastics, composites, or other materials.

Packaging and Finished Goods

Products shipped with metal closures, reinforcements, or protective elements that represent a fraction of the total package weight.

How Come the 15% Threshold Is a Documentation Rule as Much as a Tariff Rule?

Qualifying for the 0% rate under the Section 232 de minimis threshold is only half the job. Proving you qualify is the other half, and CBP will not take your word for it.

Every claim under HTS 9903.82.03 needs a defensible proof package behind it. That means having these ready before your entry hits customs:

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• Bill of Materials: A complete breakdown of every component and material in the finished good.
• Total Product Weight: A verified, consistent figure for the entire article as imported.
• Applicable Metal Weight: The specific weight of all covered steel and/or aluminum content, calculated in kilograms.
• Supplier Attestations or Technical Specs: Documentation from your manufacturer or supplier confirming metal content and composition.
• Internal Methodology for Repeat Use: A documented, repeatable process for calculating metal percentages across SKUs, vendors, and shipments.

Having the Documents, Though, Is Not Enough if They Don’t Agree

CBP can and does issue Requests for Information after entry. If your substantiation is incomplete or inconsistent, you’ve opened yourself up to duty reassessment and penalties. The agency looks for patterns. A claim that holds up on one entry but contradicts another entry for the same product raises immediate red flags.

Your Methodology Must Also Hold Up Across Every Shipment

Consistency matters just as much as accuracy here. Your calculations need to produce the same answer whether the shipment originates from Supplier A or Supplier B, whether it arrives in January or June. If your supporting data lives scattered, your audit risk climbs with every filing.

Moreover, If Your Broker Never Gets That Data, You Pay Anyway

Here’s the pressure point most importers overlook: if you don’t provide your broker with timely, organized instructions, they may default to declaring Section 232 duties on the full entered value. That protects the broker from liability, but failure to confirm the weight content may result in delays to your shipment and/or your goods being entered at 25% per Section 232.

Where Are Importers Most Likely to Get Burned?

Even with the right documents, a consistent methodology, and a well-informed broker, importers still trip up. The biggest risk isn’t getting the rule wrong. It’s being confident that you got it right without checking.

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• Products Sitting Near the 15% Line: A product that weighs in at 14.6% metal today could tip over 15% with a minor supplier or design change. Close calls demand ongoing verification, not a one-time calculation.
• Mixed-Metal and Multi-Metal Goods: CBP requires aggregate weight across all applicable metals. Calculating steel and aluminum separately instead of together will produce the wrong number.
• Legacy HTS Classifications Never Retested: If your tariff codes haven’t been reviewed since the original Section 232 orders, you’re working with outdated assumptions on updated rules.
• Inconsistent Supplier Data: Your compliance team can only be as accurate as the product specs your sourcing team collects. Garbage in, duties out.
• Full-Value Duty Shock: Products that clearly remain in scope now owe duties on full entered value, not just metal content. Some importers will see higher bills than before, even without any classification change.
• Confusing Four Different Programs: The 15% de minimis threshold, Annex III temporary treatment, UK-specific reduced rates, and U.S.-metal reduced-rate rules are all separate frameworks. Mixing and matching them is a big mistake.  

A 5-Step Importer Action Plan for the Next 30 Days

Now that you know where the risks live, here’s how to get ahead of them. None of these steps requires a legal team or a six-month project. They require attention and a free afternoon.

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1. Pull Your Highest-Exposure SKUs First: Start with the products that generate the most duty spend or sit closest to the 15% Section 232 de minimis threshold. Those are your priority, not the full catalog.
2. Validate HTS Classifications Against Updated Annex IV Logic: Old codes built around old rules may no longer reflect how your products get treated. A ten-minute review now beats a six-figure correction later.
3. Calculate Metal Content as a Percentage of Total Product Weight: Get the applicable metal weight in kilograms for every SKU on your priority list. Do it once, document your method, and apply it consistently.
4. Build the Substantiation File Before Your Broker Asks for Confirmation: Bills of material, supplier specs, weight calculations, and attestations should live in one place. Your broker will thank you. Your auditor will too.
5. Update SOPs, Broker Instructions, and Landed-Cost Models: Bake the new rules into your standing processes and re-forecast your landed costs accordingly. Then set a quarterly refresh cadence, because CBP guidance and scope lists will keep evolving.

Why This Is Exactly the Kind of Trade-Compliance Problem Mallory Alexander Is Built to Solve

The Section 232 de minimis threshold is a real opportunity to reduce duty costs. But only for importers who can back up every claim with clean data, consistent methodology, and filings that hold up under CBP scrutiny. Waiting for your broker to flag the issue is the wrong operating model. The time to act is before your next entry, not after it.

Mallory Alexander connects the dots that most providers leave disconnected. Licensed customs brokerage, trade management and compliance support, ocean freight, domestic transportation, and more than 2 million square feet of U.S. warehouse space across 31 locations worldwide. Not to mention, our myMALLORY portal centralizes shipment visibility and documentation in one place, so your compliance decisions and your freight execution stay on the same page.

The point isn’t just classification. Mallory Alexander helps importers validate threshold eligibility, match filings with brokers, tie documentation to live shipments, and keep freight moving without unnecessary duty costs or customs holds.

‍Contact Mallory Alexander to review your affected SKUs, validate potential 15% threshold eligibility, tighten broker instructions, and build a cleaner Section 232 compliance workflow before avoidable duties and delays hit your next entry.