Guides / Cost
How Tooling Adds to the Section 232 Duty Base on Stamped Steel Parts
November 7, 2026
Since April 6, 2026 the U.S. Section 232 duty on steel, aluminum and copper goods is charged on the full customs value of the imported article, not on the metal inside it. For a stamped steel part that usually means 50% of the value on the invoice if its HTS number is on the Annex I-A list, or 25% if it is on Annex I-B. Which list your part is on depends on its HTS number and nothing else, so classification is the first thing to settle. The rest of this post covers the rates, how to read the lists, and what the rule does to a quote that includes tooling. Everything below is as of October 2026, and the lists change by notice, so confirm with a customs broker before you commit to a price.
What changed in April and June 2026
Proclamation 11021 of April 2, 2026 restructured the earlier steel, aluminum and copper actions. It took effect for goods entered on or after 12:01 a.m. eastern time on April 6, 2026. CBP’s guidance (CSMS #68253075) describes the duty as 10% to 50% “on the full customs value” of the covered articles and their derivatives. A good listed under more than one metal pays only one of the rates.
A second proclamation of June 1, 2026 adjusted the lists again from June 8, 2026. It also lowered the U.S.-metal threshold from 95% to 85%, and set temporary rates that run through December 31, 2027 for some equipment lists. The stamped-part lines below are read from the June 2026 annexes.
The old method counted only the value of the metal. The new one counts everything, so a part with a lot of machining, plating or assembly value now carries duty on all of it.
Which list is a stamped part on
The proclamation sorts articles into annexes by HTS number. Read from the June 2026 annexes on whitehouse.gov, these are the lines that matter most for stamping:
| HTS | What it covers | Annex | Section 232 rate |
|---|---|---|---|
| 7326.19.00 | Iron or steel articles forged or stamped but not further worked | I-A | 50% |
| 7326.90.86.88 | Articles of iron or steel, not elsewhere specified | I-A | 50% |
| 7318 (most lines) | Screws, bolts, nuts and similar threaded articles | I-A | 50% |
| 7320 (most lines) | Leaf, helical and other springs of iron or steel | I-A | 50% |
| 7211 and 7212 | Flat-rolled carbon steel under 600 mm wide, the usual strip stock | I-A | 50% |
| 8302.50.00 | Brackets and similar fixtures of base metal | I-B, listed under aluminum derivatives | 25%, check for a steel bracket |
| 8302.10.60 | Hinges of base metal | I-B | 25% |
| 7323 (most lines) | Table, kitchen and household articles of iron or steel | I-B | 25% |
Two points follow from the table. First, a stamped part classified as a general steel article under heading 7326 is on the 50% list, which is the higher tier. Second, the same physical bracket can fall under different lines depending on what it is and what it is for, so the rate can differ by 25 points on classification alone. The 8302.50.00 line is a case in point: in the June Annex I-B text it appears under the aluminum derivative list and not under the steel list, so do not assume it puts a steel bracket at 25%. Ask your broker how a steel bracket under that line is treated. Do not pick the line that gives the lower number. Ask your broker to classify the part from the print and, for a long program, ask CBP for a binding ruling. CBP’s rulings page explains that these advance rulings bind CBP on classification.
CBP’s guidance also closes one common escape route. The low-metal-content provision, which sets the additional duty to 0% for goods with under 15% metal by weight, excludes goods in Chapters 72, 73, 74 and 76. A stamped steel article in heading 7326 is a Chapter 73 article, so its metal weight does not help.
Origin changes the rate in a few cases. CBP lists a separate heading, 9903.82.04, at 25% for U.K.-origin steel articles and derivatives. A 10% rate applies to derivatives whose steel was melted and poured in the United States, which since June 8, 2026 means at least 85% of the product’s steel by weight. The importer must hold documentation, so ask the shop what mill certificates it can supply.
Dies are on the lists too. Two die lines, 8207.30.6062 for metal-forming dies and 8207.30.6095 for parts of pressing and stamping tools, appear on Annex III, a temporary reduction list that runs through December 31, 2027. A die you import into the United States is its own entry with its own rate.
What it does to a quote with tooling in it
Customs value is the price actually paid plus the value of assists, apportioned as appropriate. U.S. law defines an assist to include “tools, dies, molds” supplied by the buyer free of charge or at reduced cost for use in making the imported goods (19 U.S.C. 1401a). So tooling is dutiable value whichever way you pay for it: amortized into the piece price, or paid separately as a die the shop uses for your parts.
Here is an illustration on a part entered under a 50% line. The numbers are made up to show the arithmetic, not quotes.
| Item | Per part |
|---|---|
| Piece price, FOB | $0.80 |
| Die amortized into the piece price | $0.20 |
| Customs value | $1.00 |
| Section 232 at 50% | $0.50 |
| Section 232 at 25% | $0.25 |
On a 300,000-piece-per-year program that is $150,000 of duty per year at 50% against $75,000 at 25%, before the regular HTS duty and freight. The die contributes $0.10 of that duty per part at 50%, so a $60,000 die spread over 300,000 parts carries $30,000 of additional duty. That is a cost that appears on no tooling quote. Whether your entry applies the percentage to the apportioned tooling value is a point to confirm with your broker, but plan as if it does. The same arithmetic matters when you compare amortized and paid-up-front tooling.
Duty is one line of the landed cost in our guide to how to source stamped parts.
Domestic stamping is not exempt
Strip steel in 7211 and 7212 is itself on the 50% list. A U.S. shop that buys imported coil pays the same Section 232 duty on it, and its quote reflects that. A domestic quote is not automatically the safe comparison. Ask every shop, foreign or domestic, which mill made the coil, where the steel was melted and poured, and whether the quote assumes imported or domestic strip. That answer decides whether the 10% U.S.-melt rate is even possible and what the shop’s own raw material cost looks like.
The grade question is separate. Strip grade, temper and thickness tolerance shape the die and the price, as covered in stamping steel grades and coil thickness and width tolerance.
Questions to put on the RFQ
- Which HTS number do you expect this part to enter under, and on what basis?
- Is the quote FOB, EXW or delivered duty paid, and does it include any Section 232 duty?
- Is tooling in the piece price or separate, and how will it be declared on the entry?
- Where was the steel melted and poured, and can you supply mill certificates?
- How will the price change if the proclamation lists change? The process allows Commerce and the U.S. Trade Representative to add derivative articles on a rolling basis, so write a tariff clause into the contract.
Put the target landed cost on the RFQ next to the print, material, thickness and annual volume, so shops quote the same basis. We match each RFQ with up to three stamping shops and reply within 24 business hours. We are a matching service, not a customs broker, so the classification itself stays with your broker. For the line items that sit before duty, see how to read and compare a metal stamping quote.
See also: the guide to buying metal stampings for the US market.
See also: the reference page on Section 232 steel and aluminum derivatives and the records behind a melt-and-pour claim.
Sources
- Proclamation 11021 of April 2, 2026, Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper (White House)
- Proclamation of June 1, 2026, Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper (White House)
- Annexes I-A, I-B and III of the June 2026 proclamation: Annex I-A, Annex I-B, Annex III
- CBP guidance CSMS #68253075, Section 232 Duties on Imports of Aluminum, Steel, and Copper
- CBP trade remedies page listing the Section 232 CSMS messages
- 19 U.S.C. 1401a, transaction value and assists (Cornell LII)
- CBP rulings program
- Customs broker summary of the April 2026 change to full customs value (directional)
Frequently asked questions
What is the Section 232 tariff on stamped steel parts in 2026?
It depends on the HTS number. Under the April 2026 proclamation the duty is charged on the full customs value of the part, not just the steel in it. Heading 7326 lines such as 7326.19.00 and 7326.90.86.88 sit on the 50% list (Annex I-A). Some other steel articles, such as hinges under 8302.10.60, sit on the 25% list (Annex I-B). Confirm the exact line with your customs broker.
Does tooling cost count toward the Section 232 duty?
Probably yes. Customs value includes the apportioned value of an assist, and a die you pay for separately and supply to the shop is an assist. A die amortized into the piece price is part of the price paid. Either way the tooling value tends to end up in the base that the percentage is charged on. Ask your broker how your entry will treat it.
Can a part with little steel in it escape the tariff?
Not if it is classified in Chapter 72, 73, 74 or 76. CBP's guidance applies the low-metal-content exclusion, under 15% of weight, only to goods outside those chapters. A stamped steel part in heading 7326 is a Chapter 73 article, so the weight test does not help it.
Is there a lower rate for parts made from U.S. steel?
Yes, a 10% rate exists for derivatives whose steel was melted and poured in the United States. Since June 8, 2026 the threshold is 85% of the product's steel weight, and the importer needs documentation to claim it. Ask the shop for mill certificates that show the melt country before you plan on it.
Need a quote for this part?
Send the print. We match you with up to 3 stamping shops and reply within 24 business hours.
Send my RFQ