On Thursday, July 30, 2025, the White House released President
Trump's proclamation on adjusting copper imports due to the
threat to U.S. national security. The Secretary of the U.S.
Department of Commerce (Commerce) transmitted his report on the 232
investigation to the President on June 30, 2025. In addition to
finding that copper "is being imported into the United States
in such quantities and under such circumstances as to threaten to
impair the national security of the United States," the report
also recommends a minimum domestic sales requirement for copper
input materials starting at 25 percent in 2027, a domestic sales
requirement of 25 percent for high-quality copper scrap, as well as
export controls for high-quality copper scrap.1
As a result, the proclamation orders that all U.S. imports of semi-finished copper products and intensive copper derivative products, as set forth in the (yet to be published) Annex to the proclamation, will be subject to a 50 percent tariff on or after 12:01 a.m. eastern daylight time on August 1, 2025.2 Of note, copper input materials (such as copper ores, concentrates, mattes, cathodes, and anodes) and copper scrap are not subject to 232 or reciprocal tariffs. The proclamation also directs the Commerce Secretary to establish a process for including additional derivative copper products within 90 days of the proclamation date, and to review, in consultation with other government agencies, whether any modifications are necessary to the U.S. Harmonized Tariff Schedule.3
While the proclamation does not specify what constitutes copper semis, derivatives, or high-quality scrap, the related White House Fact Sheet released on the same day indicates semi-finished copper products include copper pipes, wires, rods, sheets, and tubes, while copper-intensive derivative products may include pipe fittings, cables, connectors, and electrical components.4 According to the fact sheet, Commerce also recommended: an export licensing requirement for high-quality copper scrap; that the 25 percent requirement for domestic copper inputs should increase to 30 percent in 2028 and 40 percent in 2029; and that the copper 232 tariffs should not be "stacked" with auto 232 tariffs.5
Accordingly, for those involved in the copper industry, this is potentially a watershed moment that requires additional attention and participation. Buchanan has a team of international trade and national security attorneys, economists, accounting analysts, and government relations professionals ready to help U.S. manufacturers with U.S. trade remedy laws and trade policy. Our dedicated team has decades of experience supporting clients across a range of industries – ranging from steel, nonferrous metals and critical minerals, chemical, rubber, and agricultural products – to protect U.S. companies against unfair trade.
Footnotes
1. Id. (Proclamation) at Sections 1 and 7.
2. Id. at (1)
3. Id. at (2) and (3).
4. See Fact Sheet: President Donald J. Trump Takes Action to Address the Threat to National Security from Imports of Copper, available at https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-president-donald-j-trump-takes-action-to-address-the-threat-to-national-security-from-imports-of-copper/
5. Id.
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