New Section 232 Tariff Framework Takes Effect April 6
A new Presidential Proclamation signed April 2, 2026 introduces a significant restructuring of Section 232 tariffs on steel, aluminum, and copper, alongside a separate Executive Order targeting pharmaceutical imports.
The metals tariff changes take effect at 12:01 a.m. ET on April 6, 2026, while pharmaceutical tariffs will roll out over a 120 to 180 day timeline depending on company size.
The most significant shift is how duties are calculated — moving to full commercial value rather than prior valuation methods that allowed for lower declared pricing.
How Section 232 Metals Tariffs Are Changing
The updated framework closes longstanding valuation gaps and introduces stronger enforcement mechanisms, including the ability to audit and retroactively adjust duties.
Section 232 Metals Tariff Rates (Effective April 6, 2026)
| Product Category | Tariff Rate | Notes |
|---|---|---|
| Articles made entirely or almost entirely of steel, aluminum, or copper | 50% | Based on full commercial value |
| Derivative articles substantially made of steel, aluminum, or copper | 25% | Based on full commercial value |
| Metal-intensive industrial equipment & electrical grid equipment | 15% | Applies through 2027 |
| Products manufactured abroad using 100% U.S.-origin metals | 10% | Preferential rate |
| Products with 15% or less metal content | Exempt | Not subject to Section 232 tariffs |
These changes significantly increase exposure for importers with metal-heavy goods and place greater emphasis on accurate classification and valuation.
New Pharmaceutical Tariffs Under Section 232
A separate Executive Order introduces tariffs on patented pharmaceuticals and active pharmaceutical ingredients (APIs), with a baseline rate of 100%.
Pharmaceutical Tariff Structure
| Scenario | Tariff Rate | Timeline / Condition |
|---|---|---|
| Standard (all other countries) | 100% | 120 days (large companies); 180 days (smaller companies) |
| EU, Japan, Korea, Switzerland, Liechtenstein | 15% | Same staggered timeline |
| United Kingdom | TBD | Subject to separate agreement |
| Companies with MFN pricing + onshoring agreements | 0% | Through January 20, 2029 |
| Companies with onshoring agreements only | 20% | Pending Commerce/HHS guidance |
This introduces a new layer of strategic decision-making tied to pricing models and supply chain localization.
What Importers Should Do Now
Review Product Classification Immediately
Determine whether your goods fall into the new 50%, 25%, or 15% tiers or qualify for exemption. Misclassification risk is significantly higher under the new structure.
Audit Metal Content Across Supply Chains
Products near the 15% threshold require precise documentation to support exemption claims.
Evaluate U.S.-Origin Metal Opportunities
Products manufactured abroad using 100% U.S.-origin metals may qualify for reduced tariff exposure.
Prepare for Pharmaceutical Compliance Requirements
Pharmaceutical importers should begin evaluating:
- MFN pricing pathways
- Onshoring strategies
- Long-term tariff mitigation options
Strengthen Documentation and Audit Readiness
With expanded enforcement authority, importers should ensure:
- Valuation methodologies are defensible
- Records are complete and accessible
- Internal controls are aligned with CBP expectations
Increased Enforcement and Retroactive Risk
The Proclamation introduces external audit mechanisms and retroactive tariff authority, signaling a more aggressive enforcement environment.
Importers should expect:
- Greater scrutiny on declared values
- Increased likelihood of post-entry audits
- Potential reassessment of prior imports
How Alba Can Help
Alba Wheels Up is actively monitoring CBP implementation guidance, classification annexes, and Federal Register updates tied to these changes.
Our team can support with:
- Product classification reviews
- Tariff exposure modeling
- Supply chain and sourcing strategy
- Pharmaceutical compliance planning
- Audit preparedness and documentation review
Contact Alba to assess your exposure and build a mitigation strategy before enforcement ramps up.
References
- White House Fact Sheet: Strengthening Tariffs on Steel, Aluminum, and Copper Imports
- Presidential Proclamation on Section 232 Metals
- White House Fact Sheet: Pharmaceutical Tariffs
- Executive Order on Pharmaceutical Imports
- IN12519: Expanded Section 232 Tariffs on Steel and Aluminum
- IN12614: Section 232 National Security Tariffs on Copper Imports
