Legal basis:Section 232 of the Trade Expansion Act of 1962
Scope:All countries
Effective date: 1 August 2025
Tariff rate
- 50% tariff on all imports of “semi-finished copper products and intensive copper derivative products” as listed in the Annex to Proclamation 10962, effective as of 12:01 a.m. (EST) on August 1, 2025.
- The 50% tariff is additive; it applies in addition to any other applicable duties and charges, except as indicated. For example, the non-copper content of any imported articles is subject to the Reciprocal Tariffs and Fentanyl Tariffs, as applicable, in addition to the Copper Tariff.
- US Customs and Border Protection shall issue guidance requiring “strict compliance” with declaration requirements for copper content in imported goods and outlining penalties for non-compliance, eg, monetary penalties, loss of import privileges, criminal liability.
- The Secretary of Commerce will, within 90 days (by October 28, 2025), establish a process for including additional “derivative copper articles”; the designation of derivative articles is intended to combat attempts to circumvent the copper tariffs.
- The Proclamation contemplates the imposition of a “phased universal import duty” on refined copper, subject to further investigation and reporting by the Secretary of Commerce by June 30, 2026, as follows: 15% starting on January 1, 2027; 30% starting on January 1, 2028
Carve-outs
- The Proclamation excludes copper products that were investigated by the Secretary of Commerce in the Section 232 investigation, eg, refined copper. As a result, refined copper and copper input materials (such as copper ores, concentrates, mattes, cathodes, and anodes) and copper scrap are exempt from the 50% tariff.
- If a product is subject to both the Copper Tariff and the Automotive Tariff, then the tariff applicable to that product is the Automotive Tariff only.
- Public reports suggest that Apple, Inc. products made in India may not be subject to the Copper Tariff.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
