Executive summary
On August 6, 2026, the Bureau of Industry and Security published Federal Register notice 2026-15961 proposing the addition of 14 further derivative articles to the existing Section 232 aluminum, steel, and copper tariff framework at a proposed 25 percent additional-duty rate. The public-comment window opened August 4, 2026, and closed at 11:59 PM Eastern on August 27, 2026 at regulations.gov docket BIS-2026-0331 (XRIN 0694-XC166). The final rule is expected within the 60-to-120 day historical BIS Section 232 rulemaking window that follows a comment-period close.
This page is the plain-English reference on every one of the 14 proposed articles: the plain-language description as it appears in the Federal Register notice, TariffWatch's best-effort 4-digit HTSUS heading mapping, the proposed 25 percent additional-duty rate, and the downstream-industry context that determines who ultimately pays. Every HTSUS mapping is flagged medium confidence because BIS has not yet published a definitive 8-to-10-digit HTSUS annex; when the final rule publishes, verify each code against the annex directly and coordinate the ACE entry-summary update with your customs broker.
The three highest-volume downstream categories in the 14 are insulated electric conductor cables at HTSUS 8544 (universal construction, industrial, and infrastructure consumption), heat-exchange-unit parts at HTSUS 8419 (industrial process cooling and HVAC aftermarket), and the three trailer sub-categories at HTSUS 8716 (trucking, agricultural equipment, industrial-gas logistics). The narrowest but highest-margin-impact category is aluminum powder at HTSUS 7603, which affects aerospace-grade coatings and additive-manufacturing feedstock supply chains.
What a Section 232 derivative article is
Section 232 of the Trade Expansion Act of 1962 at 19 U.S.C. § 1862 authorizes the President to adjust imports of an article the Secretary of Commerce finds threaten to impair national security. Presidential Proclamation 9705 (January 8, 2018) and Proclamation 9704 (January 19, 2018) invoked Section 232 to impose 25 percent tariffs on steel imports and 10 percent on aluminum imports, followed by rounds of adjustment and expansion. Presidential Proclamations 10895 and 10896, issued February 10, 2025, restructured the derivative-article inclusion process into the current rolling-cadence framework that Federal Register notice 2026-15961 operates within, at the 50 percent rate structure set by the June 1, 2026 rate modification.
A derivative article is an imported product that contains steel, aluminum, or copper as a material input or component, but which is not itself covered by the primary steel/aluminum/copper HTSUS chapters (72 iron and steel, 73 steel articles, 74 copper, 76 aluminum). The theory of derivative-article coverage is that if downstream articles are not subject to the same Section 232 duty as the primary metal, importers arbitrage the tariff by importing the derivative form instead of the raw metal, defeating the national-security rationale of the primary tariff. The 14 articles proposed in notice 2026-15961 are exactly this category: finished or semi-finished products in HTSUS chapters 74, 76, 82, 83, 84, 85, 87, 92 that contain material amounts of steel, aluminum, or copper.
The inclusion process itself is administered by BIS under 15 CFR Part 705, with the operational-guidance layer handled by CBP CSMS messages at the entry-summary level. Adding a derivative article to Section 232 coverage requires (i) BIS proposal via Federal Register notice, (ii) public comment, (iii) BIS final rule referencing the Presidential proclamation authority, and (iv) CBP CSMS operational message specifying the Chapter 99 HTSUS subheading (typically in the 9903.81 steel-derivative or 9903.85 aluminum-derivative series) that ACE entry summaries must include to trigger the additional duty at deposit.
The 14 proposed articles
Each of the fourteen entries below lists the plain-English article label as it appears in the Federal Register notice, the TariffWatch best-effort 4-digit HTSUS heading match, and the proposed additional Section 232 duty rate. The HTSUS mappings are medium confidence and are not authoritative until the final BIS rule publishes with its definitive HTSUS annex.
| # | Article | HTSUS heading(s) | Proposed rate |
|---|---|---|---|
| 1 | Aluminum powder Aluminum powders and flakes | 7603 | 25% |
| 2 | Brass-wind musical instruments and parts Brass-wind musical instruments (trumpets, trombones, etc.) and parts | 9205, 9209 | 25% |
| 3 | Welding-machine parts Parts of welding machines and apparatus | 8515 | 25% |
| 4 | Floor safes Floor safes and strong-boxes | 8303 | 25% |
| 5 | Electric conductor cables Insulated electric conductor cables | 8544 | 25% |
| 6 | Fire extinguishers Fire extinguishers, charged or not | 8424 | 25% |
| 7 | Heat-exchange-unit parts Parts of heat-exchange units | 8419 | 25% |
| 8 | Hydraulic engine parts Parts of hydraulic engines and motors | 8412, 8413 | 25% |
| 9 | Mobile lifting frames on tires and straddle carriers Mobile lifting frames on tires and straddle carriers | 8426 | 25% |
| 10 | Other self-propelled cranes and mobile lifting frames Other self-propelled cranes and mobile lifting frames | 8426 | 25% |
| 11 | Tanker trailers Tanker trailers and semi-trailers | 8716 | 25% |
| 12 | Agricultural trailers Self-loading or self-unloading trailers for agricultural purposes | 8716 | 25% |
| 13 | Other trailers Other trailers and semi-trailers not elsewhere specified | 8716 | 25% |
| 14 | Filled steel containers Filled steel containers/tanks (iron or steel reservoirs) | 7310, 7311 | 25% |
For the interactive equivalent that accepts full 10-digit HTSUS codes and returns a hit/no-hit against the 14, use the free HTS-code checker. For per-article inclusion-rebuttal templates to file directly with BIS, see the 14 inclusion-rebuttal templates.
HTS mapping caveats
Every HTSUS heading mapping shown above is TariffWatch's best-effort 4-digit heading match to the plain-English article descriptions in the notice. This is a medium-confidence signal, not high confidence, for three specific reasons. First, the Federal Register notice itself uses plain-English article labels rather than a definitive HTSUS annex; the final rule publishes the annex at the 8-to-10-digit subheading level and can include or exclude specific breakouts within a heading. Second, some proposed articles could plausibly fall under multiple headings depending on end-use, material composition, or specific technical characteristics that the plain-English description does not disambiguate. Third, the historical BIS Section 232 rulemaking pattern includes minor scope adjustments between the proposal and the final rule based on the public-comment record.
The safe operational posture for an importer with codes plausibly on the list is (a) identify every 4-digit heading match against the checker, (b) pull the current Column 1 MFN duty, Section 301 status, and any AD/CVD orders on each candidate 8-to-10-digit code from your customs broker's Entry Summary Query interface or the CBP HTS search on the USITC Harmonized Tariff Schedule site, (c) model the compound rate scenario for the 25 percent additional Section 232 duty on top of the current stack, and (d) revisit the model against the final rule annex the day it publishes. Steps (a) through (c) can happen now; step (d) is the operational trigger for cash-deposit ACE entry updates.
How the 25 percent rate stacks with MFN, Section 301, and AD/CVD
Section 232 duties are ad valorem and are applied on the entered customs transaction value under 19 U.S.C. § 1401a. The Section 232 duty is additive to the Column 1 MFN duty for the underlying HTSUS code, and further additive to any applicable Chapter 99 subheadings that impose Section 301 (China 7A/List 3/4A) duties, antidumping orders, or countervailing duty orders. On a Chinese-origin steel derivative under HTSUS 8544 (electric conductor cables), the compound rate at the port of entry can look like: 3.5 percent Column 1 MFN plus 25 percent proposed Section 232 additive plus 25 percent Section 301 additive plus any AD order on the specific product, for a compound total in the 55-to-80 percent range before AD/CVD.
The compound rate is not applied in a stacked-percentage-of-percentage sense; each Chapter 99 subheading applies to the same underlying transaction value. On a $100,000 entry the arithmetic works out to $3,500 MFN plus $25,000 Section 232 plus $25,000 Section 301, for a $53,500 duty deposit on the base rate stack before AD or CVD add-ons. The order of application matters for AD/CVD interaction on specific products; consult your customs broker for the entry-line arithmetic on your specific merchandise.
The 25 percent proposed rate on the 14 articles is the current-notice proposal. The final rule can retain, adjust, or vary the rate. The June 1, 2026 rate modification set the underlying Section 232 aluminum, steel, and copper rate at 50 percent, and BIS has the option in the final rule to align the derivative articles to the 50 percent rate rather than the proposal's 25 percent. Model both scenarios (25 percent and 50 percent) in your duty impact calculator run so the sensitivity is transparent before the final rule publishes.
Effective-date mechanics and in-transit treatment
The Federal Register final rule publishes a specific effective date for the new duty at entry summary. Historical BIS Section 232 practice has varied. The 2018 Proclamation 9705 steel tariff was effective on the March 23, 2018 date named in the proclamation, with no in-transit exemption. The February 8, 2020 Proclamation 9980 derivative-article expansion (fasteners, nails, tacks) was effective February 8, 2020 with a narrow exception for merchandise laden aboard vessel before the effective date. The current-framework rule can go either way and the final rule text itself is the controlling reference.
The operational path is: (i) the final rule publishes in the Federal Register with a named effective date; (ii) CBP publishes a CSMS message specifying the Chapter 99 subheading(s) applicable to each new derivative-article HTSUS code and the treatment of in-transit merchandise; (iii) your customs broker updates the ACE entry-summary filing template to include the new Chapter 99 subheading and to route the merchandise through the applicable cash-deposit posture. Coordinate this workflow with your broker in advance of the final-rule publication date so the operational lag between rule publication and updated ACE entries is measured in hours rather than weeks.
Downstream-industry impact by article
Not every one of the 14 articles carries equal downstream impact. Some categories affect near-universally consumed inputs (electric conductor cables, heat-exchange parts) and drive material construction, industrial, and infrastructure cost adjustments. Others are concentrated in specific vertical markets (aluminum powder, brass instruments, floor safes) and the pass-through is contained to a narrow customer base. The table below documents the primary downstream buyers and the expected impact pattern for each category, informed by the historical Section 232 pass-through-rate literature published by the USITC on prior tariff rounds and by BIS's own economic-impact analysis referenced in the notice.
| Article | Primary downstream buyers | Impact notes |
|---|---|---|
| Aluminum powder | Aerospace coatings, additive-manufacturing feedstock, thermite reactions, specialty pigments. | Specialty industrial input with narrow domestic substitute at aerospace-grade purity. |
| Brass-wind musical instruments and parts | Musical instrument retail (trumpets, trombones, tubas, French horns). | Consumer-facing pass-through likely; domestic manufacturing limited to a small number of premium U.S. instrument makers. |
| Welding-machine parts | MIG, TIG, and stick welding machine parts. | Downstream impact on shipbuilding, construction, structural steel fabrication, and pipeline welding. |
| Floor safes | Commercial and residential floor safes and strong-boxes. | Concentrated impact on jewelry retail, cannabis cash-management installations, hospitality security procurement. |
| Electric conductor cables | Insulated electric conductor cables (power, communications, building wire). | Broadest downstream footprint of the 14. Every construction and industrial installation consumes wire and cable under HTSUS 8544. |
| Fire extinguishers | Portable fire extinguishers for commercial, residential, and vehicle installation. | Small-business commercial installer market. Regulatory-mandated purchases are inelastic; pass-through near-total. |
| Heat-exchange-unit parts | Parts of heat-exchange units including shell-and-tube exchangers. | Industrial process cooling, HVAC commercial installations, data-center cooling. |
| Hydraulic engine parts | Parts of hydraulic engines, motors, pumps, and cylinders. | Aftermarket-parts pass-through to construction equipment, agricultural equipment, and industrial hydraulic press applications. |
| Mobile lifting frames on tires and straddle carriers | Mobile lifting frames on tires and straddle carriers. | Port-container terminal operators and intermodal-freight installations are the primary buyers. |
| Other self-propelled cranes and mobile lifting frames | Other self-propelled cranes and mobile lifting frames. | Construction general contractors, oil-and-gas services, industrial rigging operations. |
| Tanker trailers | Tanker trailers and semi-trailers for liquid transport. | Trucking-fleet capital-equipment cost increases. Delayed pass-through as fleets replace units. |
| Agricultural trailers | Self-loading trailers for agricultural purposes (grain carts, silage wagons). | Farm-equipment dealer channel. Pass-through into grain-hauling and dairy-forage operations. |
| Other trailers | Other trailers and semi-trailers not elsewhere specified. | Construction dump trailers, flatbeds, specialty industrial trailers. Broad small-business impact. |
| Filled steel containers | Filled steel containers and tanks (iron or steel reservoirs). | Industrial gas cylinders, chemical-storage totes, water-treatment vessels. |
The USITC's Publication 5405 Economic Impact of Section 232 and 301 Tariffs on U.S. Industries (March 2023) documented the historical downstream pass-through rate on prior Section 232 rounds. The report found near-total pass-through of Section 232 tariffs to U.S. downstream purchasers, and material downstream price impact on steel-and-aluminum-intensive manufacturing in the years following the 2018 tariff imposition. The 14 derivative articles in this notice are expected to follow a similar pass-through pattern in the categories where U.S. domestic production is not price- or volume-competitive with the imported alternative on the timeline the proposed rule contemplates.
Post-comment mitigation paths
The August 27, 2026 comment window has closed. The mitigation paths that remain available to a U.S. importer after the comment window closes are documented in detail on what happens if you miss the BIS comment deadline: (a) country-of-origin substantial-transformation restructuring under CBP's longstanding substantial-transformation test, which can shift origin off the Section 232 scope for prospective entries; (b) first-sale valuation under 19 CFR Section 152.103(a) on qualifying multi-tier transactions, which reduces the dutiable base against which the Section 232 duty is calculated; (c) duty drawback under 19 U.S.C. Section 1313 on exported or destroyed merchandise, generally at 99 percent of duties paid; and (d) narrowly, judicial review at the Court of International Trade under 5 U.S.C. Section 706, which has been historically unsuccessful but remains a channel for nine-figure duty exposure with a plausible procedural argument.
None of these is a quick fix. Country-of-origin restructuring is a 6-to-18 month commercial project. First-sale valuation is best set up in advance with a CBP advance ruling under 19 CFR Part 177. Drawback programs require year-round records discipline and a break-even at approximately $100,000 in annual recoverable duty. Judicial review costs six figures at a minimum. The right combination depends on the specific product line, the entry volume, and the commercial pass-through capacity to downstream buyers.
Frequently asked questions
What is Federal Register notice 2026-15961?
Federal Register notice 2026-15961 is the Bureau of Industry and Security Request for Public Comments on the Proposed Implementation of Duties on Additional Aluminum, Steel, and Copper Derivative Articles, published August 6, 2026. It proposes bringing 14 additional HTSUS derivative headings under the existing Section 232 tariff framework at a proposed 25 percent rate. The public-comment window closed at 11:59 PM Eastern on August 27, 2026 at regulations.gov docket BIS-2026-0331 (XRIN 0694-XC166). BIS is expected to publish a final rule within the standard 60 to 120 day post-close window.
What is the proposed tariff rate on the 14 derivative articles?
The proposed additional Section 232 duty is 25 percent ad valorem for all 14 articles in the notice, applied to the entered customs transaction value under 19 U.S.C. Section 1401a. This 25 percent is in addition to the existing Column 1 MFN duty for each HTSUS code, any applicable Section 301 duties for Chinese-origin merchandise, and any active antidumping or countervailing duty orders. On Chinese-origin steel derivatives the effective compound rate can exceed 80 percent.
Are the 14 HTS mappings on this page authoritative?
No. The HTS heading mappings shown here are TariffWatch best-effort matches to the plain-English article descriptions in the Federal Register notice. BIS has not published a final rule with a definitive 8-to-10-digit HTSUS annex as of publication. The mappings are 4-digit heading level and flagged medium confidence throughout. Verify every HTS code against the final rule when it publishes and consult your customs broker before making import decisions on the basis of the mappings.
When does the final rule take effect on the 14 derivative articles?
BIS has not published the final rule as of the publication date of this page. Historical BIS Section 232 rulemaking practice runs 60 to 120 days from public comment close to final rule publication. The August 27, 2026 close places the anticipated final rule window between late October 2026 and late December 2026. The final rule itself sets the effective date; some rules take effect on publication and some carry a short in-transit transition period.
How do I check whether my HTS codes are on the list?
Paste your HTSUS codes into the free TariffWatch HTS checker at /tariffwatch/hts-checker for an instant match against the 14 proposed derivative headings at the 4-digit heading level. The checker returns a hit/no-hit per code and deep-links into any matching inclusion-rebuttal template.
Which of the 14 articles most affects downstream U.S. manufacturers?
The heaviest downstream-impact categories are electric conductor cables (HTSUS 8544), fire extinguishers (HTSUS 8424), and hydraulic engine parts (HTSUS 8412 and 8413). Aluminum powder at HTSUS 7603 has narrow but high-impact use in aerospace coatings and additive-manufacturing feedstock. The trailer categories at HTSUS 8716 flow through to trucking, agricultural, and industrial gas transport.
Are drawback and first-sale valuation available on the new derivative duties?
Drawback under 19 U.S.C. Section 1313 is generally available on Section 232 duties absent a specific carve-out in the operative Presidential proclamation. First-sale valuation under 19 CFR Section 152.103(a) is available to qualifying multi-tier transactions on all merchandise regardless of Section 232 status. Confirm both with your customs broker against the final rule and any applicable CBP CSMS operational guidance before relying on them.
What happens to entries already in transit when the final rule publishes?
The final rule itself specifies the treatment of in-transit merchandise. Historical BIS Section 232 rules on new inclusions have varied. Assume the earlier of the two treatments and plan cash-deposit ACE entry updates with your customs broker as soon as the final rule text publishes.
References and primary sources
- Federal Register notice 2026-15961, BIS request for public comments on proposed inclusion of 14 additional derivative articles, published Aug 6, 2026.
- Regulations.gov docket BIS-2026-0331 (XRIN 0694-XC166).
- Trade Expansion Act of 1962 Section 232, 19 U.S.C. § 1862.
- Customs transaction value, 19 U.S.C. § 1401a.
- BIS Section 232 regulations, 15 CFR Part 705.
- CBP Section 232 program page, cbp.gov/trade/programs-administration/entry-summary/232-tariffs-aluminum-steel.
- USITC Harmonized Tariff Schedule search, hts.usitc.gov.
- USITC Publication 5405, Economic Impact of Section 232 and 301 Tariffs on U.S. Industries (March 2023).
- Duty drawback statute, 19 U.S.C. § 1313.
- First-sale valuation, 19 CFR § 152.103.
- Country-of-origin advance rulings, 19 CFR Part 177.
- BIS Federal Register agency page, federalregister.gov/agencies/industry-and-security-bureau.
Related TariffWatch resources
- HTS-code checker — paste 10-digit HTSUS codes for an instant match against the 14.
- 14 inclusion-rebuttal templates — one template per article, with a $99 concierge drafting-plus-filing option per article.
- What happens if you missed the BIS comment deadline — post-comment mitigation paths in detail.
- US trade regulatory calendar — every US trade-regulatory deadline for the next 90 days including anticipated final rule dates.
- Duty impact calculator — model the 25 vs 50 percent scenarios and the country-of-origin restructuring alternatives.
- Glossary — HTSUS, Chapter 99, substantial transformation, first sale, drawback, and other terms used here.
Author
Andy Gaber is the founder of Digital Empire Holdings LLC and the author of the TariffWatch, EntryProof, and PixelProof compliance-intelligence tools. TariffWatch reference pages are written from primary-source review of Federal Register notices, regulations.gov dockets, CBP CSMS operational guidance, and USITC economic-impact publications. See the founder's /about page for background.
Editorial and corrections policy
This guide is maintained by the Digital Empire Regulatory Research Team and covers the current post-February-2025 U.S. Section 232 framework. State consumer-protection channels, non-U.S. customs frameworks, and Section 301 tariffs are out of scope. Every claim is cited to a primary source. Corrections are posted to /corrections within one business day of confirmation. Editorial standards are at /editorial-policy.
Nothing on this page is customs classification advice under 19 CFR Part 111 or legal advice. TariffWatch is a data and workflow tool, not a licensed customs broker and not a filer of record. Verify every regulatory citation against the linked primary source, and consult your customs broker or trade attorney before making import decisions on the basis of any content in this guide. Attorney review of the specific mitigation-path recommendations is pending as of publication; this guide is a v0 disclosure.