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On April 2, 2026, the White House issued two significant Presidential Proclamations under Section 232 of the Trade Expansion Act of 1962 that materially restructure existing US tariffs on imports of aluminum, steel, and copper products, and impose new tariffs on certain pharmaceutical products and ingredients. Together, these actions substantially change the tariff rates on a broad range of products and establish new country‑ and company‑specific frameworks that will have immediate and far‑reaching implications for importers, manufacturers, and global supply chains.
A New Framework for Section 232 Tariffs on Aluminum, Steel, and Copper Products
Effective April 6, 2026, the metals proclamation significantly increases Section 232 tariffs on aluminum, steel, and copper articles and derivatives. A 50 percent tariff now applies to the full value of covered aluminum, steel, and copper articles and derivatives listed in Annex I‑A, which includes products classified in Chapters 72, 73, 74, and 76 of the Harmonized Tariff Schedule of the United States (HTSUS). In addition, a 25 percent tariff applies to the full value of aluminum and steel derivatives and copper articles listed in Annex I‑B, including products classified in Chapters 73, 76, 82 through 87, and 94.
For products classified outside Chapters 72, 73, 74, or 76, the Section 232 tariff applies only where the applicable metal represents at least 15 percent of the weight of the imported article. Where a tariff classification is subject to more than one of the Section 232 metals tariffs, the aggregate weight of the listed metals must be used for purposes of determining whether the threshold is met.
The proclamation also removes Section 232 tariffs entirely from products listed in Annex II, which appears to include many products that were added in August 2025 pursuant to inclusion requests.
Products listed in Annex III receive temporary tariff relief through December 31, 2027, with rates reduced to 15 percent or the applicable Column 1 duty rate, whichever is greater, and to 25 percent for trading partners with whom the United States does not maintain normal trade relations. These temporary reductions affect products classified in Chapters 82, 84, and 85, as well as HTSUS subheading 9013.90.80.
Aluminum articles and derivatives from Russia remain subject to a 200 percent tariff.
The proclamation preserves lower tariff rates for certain products of the United Kingdom and a 10 percent rate where smelting and casting or melting and pouring occurred at least 95 percent in the United States.
The proclamation also eliminates the stacking of multiple metals tariffs and formally terminates the aluminum, steel, and copper derivatives inclusion processes.
Manufacturing drawback is now available only for Annex I‑B or Annex III products that are smelted and cast or melted and poured in the United Kingdom, the European Union, Japan, the Republic of Korea, Mexico, Canada, or any other country with which the United States has concluded a final reciprocal trade agreement.
New Section 232 Tariffs on Pharmaceuticals and Pharmaceutical Ingredients
The second proclamation establishes a new Section 232 tariff regime for patented pharmaceuticals and associated pharmaceutical ingredients. A 100 percent tariff applies to patented pharmaceutical products and ingredients identified in Annex I. These tariffs do not stack with the Column 1 duty rate; instead, the Column 1 rate applies where it is higher, except in the case of products from the United Kingdom.
Reduced tariff rates apply to products from certain trading partners. Pharmaceuticals from Japan, the European Union, the Republic of Korea, Switzerland, and Liechtenstein are subject to a 15 percent tariff, although those rates may increase if the relevant commitments are not fulfilled. Products from the United Kingdom are subject to a 10 percent tariff, with the potential for reduction to zero depending on the outcome of future United States–United Kingdom pharmaceutical pricing agreements.
The proclamation also provides incentives for onshoring pharmaceutical production. Patented pharmaceuticals and associated ingredients produced by companies with plans approved by the Secretary of Commerce to onshore production are subject to a 20 percent tariff, which will increase to 100 percent on April 2, 2030. Companies that enter into Most‑Favored‑Nation pharmaceutical pricing agreements, or agreements in principle, with the Secretary of Health and Human Services may qualify for a zero percent tariff through January 20, 2029, subject to compliance with those agreements.
Annex II identifies existing company‑specific agreements, while Annex III establishes staggered effective dates, with tariffs taking effect on July 31, 2026, for listed companies and September 29, 2026, for other companies. Annex IV provides broad exemptions for specified pharmaceutical products and ingredients, including orphan drugs, nuclear medicines, plasma‑derived therapies, fertility treatments, cell and gene therapies, antibody drug conjugates, certain medical countermeasures, specialty pharmaceutical products identified by the Secretary, and animal health pharmaceuticals, subject to specified trade framework or public health determinations.
Generic pharmaceuticals and associated ingredients, including biosimilars, are not subject to Section 232 tariffs under the proclamation, although this exclusion will be reviewed within one year. Duty drawback remains available for covered pharmaceutical products.
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.
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