Section 232 Investigation of Copper | Sandler, Travis & Rosenberg, P.A.

On July 30, 2025, President Trump issued a proclamation imposing tariffs of 50 percent on copper and its derivatives. The tariff was effective as of 12:01 am eastern daylight time on August 1, 2025.

June 1, 2026 Presidential Proclamation

New! The proclamation makes the following modifications to the April 2026 framework.

lowering from 25 percent to 15 percent the tariff rate on certain agricultural equipment (e.g., combines and harvesters) and certain heating, ventilation, and air conditioning systems and components that are predominantly for residential use
expanding to mobile industrial equipment (e.g., bulldozers and forklifts) the types of industrial equipment subject to a lower 15 percent tariff when imported from countries eligible for preferential treatment under U.S. trade agreements
adding aluminum lithographic plates and steel racks to the list of derivative products subject to a 25 percent tariff.
a 10 percent tariff applied to products manufactured abroad using at least 95 percent U.S.-melted and -poured steel or U.S.-smelted and -cast aluminum or copper. The new proclamation lowers this threshold to 85 percent.
providing that for products of Canada and Mexico that qualify for preferential tariff treatment under the U.S.-Mexico-Canada Agreement, a 25 percent tariff will apply only to the non-U.S. content of the product; i.e., the total value of the product minus the value attributable to parts produced in the U.S. However, the total effective tariff assessed on such goods will not be less than 15 percent.

ST&R offers a three-pronged approach for avoiding, mitigating, and/or recovering these and other tariffs. For more information on which of these strategies might be most effective for your business, please contact ST&R.

April 2, 2026 Presidential Proclamation

Effective April 6, 2026, tariffs on copper and their derivative products are changing as below:

A flat 50 percent tariff will be imposed on the full value of articles made entirely or almost entirely of copper. Tariffs will no longer be imposed on just the metal content of goods also containing non-metal content.
A flat 25 percent tariff will be imposed on the full value of derivative articles substantially made of copper.
A 15 percent tariff will be imposed through 2027 on certain metal-intensive industrial equipment and electrical grid equipment.
Products made abroad but containing at least 95 percent U.S. smelted and cast copper will be subject to a 10 percent tariff.
Products made of 15 percent or less by weight of copper (except those classifiable in HTSUS Chapters 72, 73, 74, or 76) will no longer be subject to Section 232 metals tariffs.

Goods listed as articles or derivatives of more than one of these metals will only be subject to one of the tariff rates specified above (i.e., no tariff stacking).

Section 232 Investigation

These tariffs result from a Section 232 investigation initiated on February 25, 2025. The investigation assessed the national security risks related to imported copper in all its forms, including raw mined copper, copper concentrates, refined copper, copper alloys, scrap copper, and derivative products. The Secretary of Commerce concluded the investigation on June 30, 2025, by transmitting a report with recommendations to the President.