| TRUMP ADMINISTRATION TRADE ALERT – IMPORTS | |
| HEADLINE | Trump Administration Issues Proclamation Imposing 50% Section 232 Tariffs, Export Controls on Some Copper Scrap |
| DATE | July 30, 2025 |
| AGENCY | Department of Commerce; United States International Trade Commission; U.S. Customs and Border Protection (CBP) |
| EFFECTIVE DATE | August 1, 2025 at 12:01 a.m. Eastern Time |
| BACKGROUND | After initiating an investigation into the national security impact of copper imports into the United States, the Secretary of Commerce provided a report on June 30, 2025, detailing findings and recommendations. In early July, the Trump Administration announced it would soon impose a 50% tariff on certain copper imports in response. Today's action implements many of the Secretary's recommendations and additional actions determined to be necessary to address the Administration's assessment of threats to national security. |
| DETAILS | IMPORTS – TARIFF ACTIONS: The primary effect of the Proclamation is to impose a 50% tariff on all imports of semi-finished copper products (e.g., copper pipes, wires, rods, sheets, and tubes) and intensive copper derivative products (e.g., pipe fittings, cables, connectors, and electrical components), as outlined in an Annex not published with the EO. However, a list of HTS classifications was attached to the CBP CSMS Message related to the EO, and is included at the end of this Alert. This 50% tariff is in addition to other duties, fees, exactions, and charges, except: " The additional 50% duties apply only to the copper content of articles subject to the Proclamation. Non-copper content of all articles subject to the Proclamation is only subject to the reciprocal tariffs (Executive Order 14257 of April 2, 2025) and, as applicable, IEEPA Canada (Executive Order 14193 of February 1, 2025), IEEPA Mexico (Executive Order 14194 of February 1, 2025), and IEEPA China tariffs (Executive Order 14195 of February 1, 2025). " Products subject to the auto tariffs (Proclamation 10908 of March 26, 2025) will be subject only to the auto tariffs, not the copper tariffs. " Copper input materials (such as copper ores, concentrates, mattes, cathodes, and anodes) and copper scrap are not subject to the copper or reciprocal tariffs. The Proclamation instructs CBP to issue "authoritative guidance mandating strict compliance with declaration requirements for copper content in imported articles" and to outline penalties for noncompliance. Refined products are not currently subject to the 50% duties, but the Proclamation asks the Secretary to report by June 30, 2026, whether a "phased universal import duty" on refined copper (15% January 1, 2027; 30% January 2, 2028) is warranted. The Proclamation directed the Secretary to establish within 90 days a process to add derivative copper articles to the tariff scope, similar to the process established for steel/aluminum derivatives under Proclamation 10895 of February 10, 2025 (Adjusting Imports of Aluminum Into the United States) and Proclamation 10896 of February 10, 2025 (Adjusting Imports of Steel Into the United States). Products subject to the copper tariffs (unless eligible for admission under domestic status) must be admitted as "privileged foreign" status as described in 19 CFR 146.41, and will be subject to the applicable duty rate in effect upon entry for consumption. EXPORT CONTROL ACTIONS: The Proclamation authorized the Secretary to take "all appropriate action" to implement a 25% domestic sales requirement for copper input materials in 2027, a 25% domestic sales requirement for high-quality copper scrap, and export controls for high-quality copper scrap. |
| BASIS | Section 232 of the Trade Expansion Act of 1962, as amended, 19 U.S.C. 1862 (section 232); International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.); section 101 of the Defense Production Act of 1950 (DPA), as amended, 50 U.S.C. 4511; section 301 of title 3, United States Code; and section 604 of the Trade Act of 1974, as amended, 19 U.S.C. 2483 |
| HTS/ PRODUCTS |
Articles specified in the Annex (unpublished). CBP published a list of articles subject to the EO, which includes several provisions of Chapter 74 HTSUS (7406, 7407, 7408, 7409, 7410, 7411, 7412, 7413, 7415, 7418, 7419) and four subheadings to heading 8544 of the HTSUS (8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10). |
| COUNTRY | All |
| CITE | Proclamation: Adjusting Imports of Copper into the United States
– The White House Fact Sheet: Fact Sheet: President Donald J. Trump Takes Action to Address the Threat to National Security from Imports of Copper – The White House CBP: CSMS #65794272 – Guidance: Section 232 Import Duties on Copper and Copper Derivative Products |
CSMS # 65794272 – GUIDANCE: Section 232 Import Duties on Copper and Copper Derivative Products
LIST OF COPPER HTSUS
Effective August 1, 2025.
See the Harmonized Tariff Schedule of the United States for the authoritative list.
9903.78.01 and 9903.78.02: Applies to all imported semi-finished copper and intensive copper derivative products
| 7406.10.00 | 7409.19.90 | 7413.00.10 |
| 7406.20.00 | 7409.21.00 | 7413.00.50 |
| 7407.10.15 | 7409.29.00 | 7413.00.90 |
| 7407.10.30 | 7409.31.10 | 7415.10.00 |
| 7407.10.50 | 7409.31.50 | 7415.21.00 |
| 7407.21.15 | 7409.31.90 | 7415.29.00 |
| 7407.21.30 | 7409.39.10 | 7415.33.05 |
| 7407.21.50 | 7409.39.50 | 7415.33.10 |
| 7407.21.70 | 7409.39.90 | 7415.33.80 |
| 7407.21.90 | 7409.40.00 | 7415.39.00 |
| 7407.29.16 | 7409.90.10 | 7418.10.00 |
| 7407.29.34 | 7409.90.50 | 7418.20.10 |
| 7407.29.38 | 7409.90.90 | 7418.20.50 |
| 7407.29.40 | 7410.11.00 | 7419.20.00 |
| 7407.29.50 | 7410.12.00 | 7419.80.03 |
| 7408.11.30 | 7410.21.30 | 7419.80.06 |
| 7408.11.60 | 7410.21.60 | 7419.80.09 |
| 7408.19.00 | 7410.22.00 | 7419.80.15 |
| 7408.21.00 | 7411.10.10 | 7419.80.16 |
| 7408.22.10 | 7411.10.50 | 7419.80.17 |
| 7408.22.50 | 7411.21.10 | 7419.80.30 |
| 7408.29.10 | 7411.21.50 | 7419.80.50 |
| 7408.29.50 | 7411.22.00 | 8544.42.10 |
| 7409.11.10 | 7411.29.10 | 8544.42.20 |
| 7409.11.50 | 7411.29.50 | 8544.42.90 |
| 7409.19.10 | 7412.10.00 | 8544.49.10 |
| 7409.19.50 | 7412.20.00 |
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.
