New Section 232 Tariff Guidelines on Metals and Pharmaceuticals
We would like to inform you of recent regulatory developments impacting Section 232 tariffs. On April 2, the U.S. Administration issued a proclamation and Executive Order introducing revised tariff structures for steel, aluminum, copper, and certain pharmaceutical products. These changes will take effect at 12:01 a.m. on April 7.
Metals: Steel, Aluminum, and Copper
The updated tariff framework includes the following key provisions:
- Articles composed entirely or predominantly of steel, aluminum, or copper will be subject to a 50% tariff on the full declared value (e.g., steel coils, aluminum sheet). Please refer to Annex I for applicable classifications.
- Derivative products substantially made from these metals will incur a 25% tariff on full value of the item, not just the metal. (see Annex I-B).
- Certain metal-intensive industrial and electrical grid equipment will be assessed a 15% tariff through 2027 (Annex III).
- Products manufactured abroad using exclusively U.S.-origin steel, aluminum, and copper will qualify for a reduced 10% tariff.
- Goods containing 15% or less of these metals (aggregate) will no longer be subject to Section 232 tariffs.
- Annex II outlines classifications that are now exempt from Section 232 metals tariffs.
- Annex IV details updated tariff codes and their respective uses.
- A notable change includes the combined calculation of metal content, where the aggregate weight and value of steel, aluminum, and copper will determine duty applicability for products containing multiple metals.
Pharmaceuticals
New tariff measures for pharmaceutical products include:
- A 100% tariff on patented pharmaceutical products and ingredients. Implementation will occur in 120 days for large companies and 180 days for small companies.
- Products originating from the European Union, Japan, Korea, Switzerland, or Liechtenstein will be subject to a reduced 15% tariff.
- Imports from the United Kingdom will be assessed at a preferential rate in accordance with the recently concluded U.K. pharmaceutical agreement.
- Companies participating in both Most Favored Nation (MFN) pricing agreements with the Department of Health and Human Services and onshoring agreements with the Department of Commerce will receive a 0% tariff rate through January 20, 2029.
- Companies entering into onshoring agreements only will be subject to a 20% tariff.
- The Department of Commerce and HHS will provide guidance and pathways for companies seeking to participate in these programs.
CV International will continue to closely monitor these developments and provide timely updates as additional guidance becomes available.
For full details, please refer to the annexes associated with this announcement.
If you have any questions regarding how these changes may impact your business, please do not hesitate to contact us.
John Boomhover, LCB
Director of Compliance & Customs Services
CV International, Inc.
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