REPORT: Revised Section 232 — Steel, Copper, Aluminum: The Tariff Wall Is Becoming More Refined

Maxime Marquette

2026-06-24 13:09:14

Agricultural Equipment and Residential HVAC Systems: The Biggest Beneficiaries

The most talked-about provision of Proclamation 11032 is the expansion of Annex III to include agricultural equipment and certain heating, ventilation, and air conditioning (HVAC) systems used primarily for residential purposes. Until June 7, 2026, these products were treated as ordinary steel or aluminum products, subject to the standard 25% tariff rate. Effective June 8, they are subject to a temporary reduced ad valorem duty rate of 15%, or even 10% for products in which U.S.-sourced metal content accounts for at least 85% by weight of the relevant metals.

Specifically, according to details provided by Green Worldwide Shipping, the agricultural equipment covered includes combine harvesters, harvesters, mowers, plows, agricultural tractors, tractor bodies, transmissions, mufflers, exhaust pipes, clutches, agricultural trailers and carts. For residential HVAC, eligible products include wall-mounted and window air conditioners, other air conditioning units, air conditioner parts, air conditioning evaporator coils, and heat pump parts. For U.S. farmers who source equipment manufactured in Canada or Mexico, the 10-percentage-point difference represents a substantial cost savings on already tight margins.

Annex I-C—The New Home for Mobile Industrial Equipment

Alongside the expansion of Schedule III, Proclamation 11032 creates an entirely new Schedule I-C, grouping twenty-eight HTSUS codes under Chapters 84 and 87, corresponding to mobile industrial equipment and machinery. These codes were transferred from Annex I-B. According to the law firm Holland & Knight, this list notably includes bulldozers, forklifts, construction and material-handling equipment, as well as certain motor vehicle components.

The tariff treatment under Annex I-C is more complex than that under Annex III. The base rate remains at 25%, but a four-tier structure applies depending on origin: a maximum combined rate of 15% for partner economies covered by a trade agreement (EU, United Kingdom, Japan, South Korea, Argentina, Ecuador, El Salvador, Guatemala, Liechtenstein, Switzerland, Taiwan); a maximum combined rate of 10% for products manufactured entirely from U.S. steel or aluminum; USMCA treatment for Canada and Mexico, with the 25% tariff applied only to non-U.S. content, subject to an effective minimum of 15%. The lowest-rate rule applies in the event of a conflict between multiple tiers.

What I find fascinating—and concerning at the same time—is the growing sophistication of this tariff architecture. It is too complex to be improvised. Someone, behind the scenes at the White House or the Department of Commerce, is giving serious thought to the structure of the U.S. manufacturing economy. Even Trump’s critics should acknowledge this, because it changes the nature of the debate.

U.S. Content Threshold Lowered to 85% — Scope and Limitations

An Incentive for Downstream Manufacturers

One of the most subtle but potentially most significant changes in Proclamation 11032 is the lowering of the U.S. content threshold required for a product to be considered “entirely” manufactured with U.S. metals. This threshold has been reduced from 95% to 85%, measured by the weight of the metals in question. The operational definition is precise: aluminum must have been smelted and cast in the United States; steel must have been smelted and cast in the United States; copper must have been smelted and cast in the United States.

This change paves the way for a reduced 10% tariff rate for products that were close to but did not meet the 95% threshold. According to Diaz Trade Law, it may help products that narrowly missed the former threshold to now qualify for the lower rates. The logic is clear: to encourage manufacturers to incorporate more U.S.-sourced steel, aluminum, and copper into their production chains by offering them a tariff advantage starting at 85% domestic content rather than 95%. This is a form of incentive-based industrial policy, more nuanced than blunt tariff penalties.

Practical Limitations and Risks of Non-Compliance

But this lowered threshold is not a gift without strings attached. U.S. Customs and Border Protection (CBP) published implementation guidelines on June 5, 2026 (reference CSMS #68855869), explicitly warning that any fraud or deliberately misleading declaration regarding U.S. content will result in penalties to the fullest extent of the law. The traceability requirements are cumulative: a product falling under multiple subcategories must meet each applicable threshold separately. The documentation burden—metal content declarations, supplier certifications, verifiable calculation methodologies—is considerable.

The Mallory Group had already warned, as early as April 2026, that classification errors under this regime are not mere rounding errors: they can cause the customs duty to jump from 0% to 50% of the full customs value. With Proclamation 11032, this risk is amplified, as the rate categories have become even more fragmented. A Canadian forklift importer who fails to correctly declare the U.S. content of their equipment not only misses out on tariff relief but also risks penalties, liquidated damages, and lengthy, costly prior disclosure proceedings.

I find it hard not to see this framework as a mechanism for creating information asymmetry. Large companies with well-established trade compliance teams will capitalize on these reductions. Small and medium-sized importing businesses, on the other hand, risk missing out or, worse, finding themselves in the crosshairs of U.S. Customs and Border Protection (CBP) due to a lack of adequate documentation. This may not be intentional—but the effect is real.

The USMCA Agreement for Canada and Mexico — A Delicate Balance

The principle: tax foreign content, exempt U.S. content

For products qualifying under the United States-Mexico-Canada Agreement (USMCA), Proclamation 11032 maintains and clarifies differential treatment. The 25% tariff applies only to the non-U.S. content of the product, defined as the total value of the product minus the value attributable to parts produced in the United States. The minimum effective rate applicable to the product as a whole remains set at 15% of the full ad valorem value. This mechanism is designed to preserve North American industrial integration while maintaining tariff pressure on non-U.S. components.

For steel-derived articles covered by Annex I-C, an additional restriction applies, as noted by Holland & Knight: only 40% of the U.S. value is eligible for the exemption. Non-U.S. content and U.S. content exceeding 40% of the product’s total value remain subject to the 25% tariff. This limitation is significant: it means that highly integrated mobile industrial equipment containing U.S. components remains partially subject to the Section 232 tariff, even if it qualifies for duty-free treatment under the USMCA.

Implications for Continental Supply Chains

The USMCA process is administratively complex, as detailed by Diaz Trade Law. Eligible Canadian and Mexican importers must file two separate lines on their entry declaration with CBP: a first line (under HTSUS code 9903.82.20) for the total value of non-U.S. content plus U.S. content exceeding 40%, with the 25% tariff and SPI code “S”; a second line (under code 9903.82.21) for the value of the U.S. content capped at 40% of the total value entered, at a 0% rate, also with the SPI code “S.” Customs procedures are demanding and leave little room for error without risking penalties.

For the Canadian manufacturing industry—which produces a significant portion of the mobile agricultural and industrial equipment sold in the U.S. market—these rules represent both an opportunity and a challenge. The opportunity is real: equipment manufactured in Canada with 45% U.S. components, imported under the USMCA, can have its effective tariff capped at 15% overall, compared to 25% without the USMCA. The challenge is just as real: accurately tracing the value of U.S. components, line by line and SKU by SKU, requires a sophisticated documentation infrastructure that few manufacturing SMEs possess off the bat.

The paradox of the USMCA in this context is that it is supposed to preserve continental free trade—and it does—but it does so within a framework where “free” now means “less taxed than others, under strict conditions.” The gap between this version of free trade and what the architects of NAFTA envisioned in 1994 is staggering. Canadians and Mexicans are right to be frustrated by this—but they would be wrong not to adapt.

New taxable products—lithographic products, racks, and related items

Aluminum lithographic plates and steel racks—new targets

While media attention was focused on tariff reductions, Proclamation 11032 quietly expanded its scope. Two specific products have been added to the Section 232 regime: aluminum lithographic plates and steel racks. These two categories are now treated as aluminum and steel derivatives, respectively, and are subject to the tariff applicable to derivatives under Proclamation 11021.

The selection of these two products reflects an anti-circumvention strategy. Aluminum lithographic plates are essential inputs for the commercial printing industry. Steel racks are ubiquitous in logistics, warehousing, and retail. These sectors had previously benefited from a de facto exemption, as their products were not listed in previous Section 232 schedules. Proclamation 11032 closes this loophole. According to the logistics firm Green Worldwide Shipping, certain importers of furniture parts are now also subject to the tariffs for the first time.

Anti-circumvention logic as the guiding principle

This expansion of coverage is part of a consistent strategy. Every revision of the Section 232 framework since 2018 has gradually broadened the scope of subject products, particularly to include downstream derivatives that could be used to import steel or aluminum in a processed form in order to avoid tariffs on raw materials. The logic is simple: if coiled steel is taxed at 50%, an importer might be tempted to import steel racks at a zero rate and uncoil them once they reach U.S. customs. By subjecting the racks to tariffs, this loophole is closed.

This approach has its own unintended consequences. It makes the regime more comprehensive, but also more difficult for bona fide operators to navigate. An importer of steel racks for a distribution warehouse will now have to factor the Section 232 tariff cost into its cost calculations, adjust its supply contracts, verify the origins of its suppliers, and document the metal composition of its products. These compliance costs, which are invisible in official statistics, are real and significant for small and medium-sized enterprises that do not have dedicated trade compliance departments.

There is something slightly absurd about the spectacle of an administration that, on the one hand, proclaims its desire to reduce bureaucracy and ease the regulatory burden on businesses, and on the other, is building the most complex trade regulatory framework the United States has seen in decades. I’m not saying that’s wrong—I’m saying it’s a tension that no one in Trump’s inner circle seems willing to acknowledge openly.

The complete pricing structure—the five tiers involved

From 10% to 200%—a multi-tiered structure

To fully understand the scope of Proclamation 11032, it is important to keep in mind the comprehensive tariff structure that now applies to metals and their derivatives in the United States. At the top of the pyramid is the 200% tariff on all aluminum products and derivatives that are produced in Russia or in which any portion of the primary aluminum was smelted or cast in Russia. This rate, established by Proclamation 10522 of February 2023 and maintained unchanged, is an economic sanction disguised as a trade tariff: its stated objective is to completely isolate Russian aluminum from the U.S. market.

Below that, the standard 50% rate applies to aluminum, steel, and copper articles composed almost entirely of these metals (Annex I-A). The 25% rate covers derivative articles listed in Annex I-B and new articles listed in Annex I-C (base rate). The 15% rate is the effective floor for partner economies and products listed in Annex III. Finally, the 10% rate is reserved for products whose metal is composed entirely of steel smelted and cast in the United States or aluminum smelted and cast in the United States, subject to the 85% by weight threshold now in effect.

Exceptions and Exclusions That Shape the Regime

Certain exclusions are worth noting. Civil aircraft and their parts are exempt under reciprocal trade agreements with the United Kingdom, the European Union, South Korea, and Japan. Parts imported for the manufacture of motorcycles classified under HTSUS Chapters 84, 85, and 87 are also exempt. Products containing no steel, aluminum, or copper that appear on the lists in Annexes I-B and III are exempt. Finally, products with an aggregate metal content of less than 15% by weight—provided they are not classified under chapters 72, 73, 74, or 76—qualify for the de minimis rule and are not subject to Section 232 tariffs.

This network of exclusions also creates considerable operational complexity. For foreign trade zones (FTZs), the rule is that any item entering a U.S. FTZ after April 6, 2026, may only be admitted under “privileged foreign goods” status, unless it is eligible for domestic status. This provision, maintained by Proclamation 11032, closes off the use of FTZs as a means to defer or circumvent Section 232 duties by processing the goods before they enter consumption.

Every time I read a U.S. regulatory text of this level of complexity, I wonder how many years of legal and economic training it takes to truly master it. And I also wonder how many medium-sized companies—those that form the backbone of the North American manufacturing economy—actually have the resources to navigate this maze without costly outside assistance.

The industries most affected—agriculture, HVAC, construction, and energy

U.S. Agriculture: Between Protectionism and Pragmatism

According to Holland & Knight, the industries most directly impacted by Proclamation 11032 are agriculture and agricultural machinery, construction and mining equipment, energy and power supply equipment, and residential HVAC. For agriculture, the stakes are particularly high. The U.S. agricultural sector is both a major producer of steel and aluminum through its ties to domestic manufacturers and a major importer of heavy equipment often manufactured in Canada, Mexico, or partner countries such as Germany and Japan.

The reduction of tariffs on agricultural equipment from 25% to 15% was explicitly justified, in the preamble to Proclamation 11032, by the recognition that such equipment “plays an important role in productive domestic economic activity.” This wording is noteworthy: it implicitly acknowledges that imposing excessively heavy taxes on agricultural inputs creates a contradiction with the goal of strengthening U.S. competitiveness. The Secretary of Commerce himself had recommended expanding Annex III to include agriculture and residential HVAC, demonstrating sensitivity to pressure from the affected industries.

HVAC and Residential Construction—Targeted Relief

For the residential HVAC sector, the tariff reduction comes amid pressure on new construction costs in the United States. Heating and air conditioning systems account for a significant portion of the cost of building a home, and any tariff increase on their components directly impacts the final price of new homes—a politically sensitive issue for an administration that has made housing affordability a campaign platform.

The list of HVAC products eligible for the 15% tariff rate includes window and wall-mounted air conditioners (HTS 8415), other air conditioning machines, spare parts for air conditioning systems, evaporator coils, and heat pump parts. Commercial HVAC equipment is not covered by this extension—only systems “predominantly for residential use” qualify. This distinction between residential and commercial use is a dividing line that will likely be subject to interpretation and customs disputes in the coming months.

I note that the distinction between residential and commercial HVAC is exactly the kind of gray area that fuels customs disputes. Take an eight-story mixed-use building with retail spaces on the ground floor and apartments above—is its air conditioning system residential or commercial? Questions like this will keep specialized lawyers busy for years. Perhaps this is intentional. Maybe not. But there it is.

Business Partners in the New Pricing Structure

Priority Partner Economies—A Flexible List

Proclamation 11032 maintains and clarifies the list of partner economies eligible for the maximum combined rate of 15% for products covered by Annex I-C. This list includes: Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, and all member states of the European Union. For these partners, the mechanism is as follows: if the Column 1 duty rate is less than 15%, the sum of the Column 1 rate and the additional Section 232 duty is capped at 15%. If the Column 1 rate is greater than or equal to 15%, the additional Section 232 duty is zero.

This list of partners reveals the underlying geopolitical logic of the Trump tariff framework. Nations that have concluded reciprocal trade agreements or bilateral deals with the United States receive preferential treatment. Those that have not negotiated—or that are considered adversaries—pay the full tariff or, in the case of Russia, the punitive tariff. China, notably absent from the list of preferred partners, remains subject to the highest standard tariffs, in addition to anti-dumping and countervailing duties that are often imposed on top of them.

China Left Out of the Preferential Framework—An Unambiguous Signal

China’s absence from all categories of preferential treatment in Proclamation 11032 is in itself a political message. Beijing is not explicitly named in the text, but the tariff structure—with its benefits reserved for nations with which Washington has concluded or seeks to conclude agreements—de facto excludes China from any relief. Steel, aluminum, or copper products originating in China, or containing metals smelted and cast in China, do not benefit from any of the temporary reductions introduced by Proclamation 11032. They remain subject to the highest tariffs applicable to their category.

The European Union, on the other hand, fares relatively well under this regime. European exporters of agricultural equipment—led by Germany, France, and Italy—see their products potentially eligible for a combined rate of up to 15% under Annex I-C. This is an important distinction, reflecting the progress made in the ongoing transatlantic trade negotiations since the 2022 agreements on steel and aluminum tariffs—which the Trump administration had initially renegotiated and ultimately partially retained in a revised format.

China’s status as a permanent exclusion in every U.S. tariff regime comes as no surprise—but its cumulative effect, built up layer by layer since 2018, now constitutes the economic equivalent of a partial trade blockade. I’m not sure this will produce the expected reshoring effects, but I’m certain it’s accelerating the fragmentation of global trade into blocs—and that this fragmentation will ultimately cost everyone, including the United States.

The Implementation Timeline and the CBP on the Front Lines

From June 5, 2026, at 12:01 a.m. on June 8—a short window, major stakes

U.S. Customs and Border Protection (CBP) issued its implementation guidelines on June 5, 2026—just three days after the publication of Proclamation 11032 and three days before it took effect. This extremely short timeframe has been criticized by international trade professionals: it leaves little time for importers, customs brokers, and compliance teams to analyze the new requirements, update their classification systems, prepare the required documentation, and adjust entry declarations.

The CBP guidance (CSMS reference #68855869) specifies the applicable new HTSUS codes—subheadings 9903.82.20 through 9903.82.26—and the reporting requirements. It also notes that additional guidance will be needed for certain codes, particularly subheadings 9903.82.18 and 9903.82.19, for which a follow-up CSMS is expected. This indication of upcoming guidance adds further uncertainty for importers in the affected categories, who must operate within a regulatory gray area.

Classification Challenges and the Risk of Exposure

For Diaz Trade Law, the key message is unequivocal: importers must audit their HTS classifications now, before they are found in violation. The current Section 232 regime is such that a classification error can cause the customs duty rate to jump from 0% to 50% of the full customs value. This is not a minor distinction—it is a financial abyss. For $200,000 worth of industrial equipment, the difference between a 10% rate and a 25% rate amounts to $30,000 per unit in additional duties.

The risks of underpayment are also severe. Importers who fail to properly report newly subject products—such as steel racks and aluminum lithographic plates—face penalties for misdeclaration, retroactive assessment procedures, and prior disclosure requirements, which, if necessary, can result in disproportionate administrative and legal costs. CBP has made it abundantly clear that it has a zero-tolerance policy for manipulated U.S. content declarations.

I find myself thinking of all those small importers, regional distributors, and agricultural cooperatives that buy used harvesters in Canada or wall-mounted air conditioners in South Korea. These people don’t read CBP’s CSMS. They don’t know what an HTSUS code is. And in three months, some of them will receive a retroactive assessment notice they didn’t see coming. This is the part of trade policy that isn’t discussed nearly enough.

The “national security” aspect—the contested legal basis

Section 232 of the Trade Expansion Act of 1962—an outdated but formidable tool

The entire tariff framework described thus far rests on a single legal foundation: Section 232 of the Trade Expansion Act of 1962, codified in 19 U.S.C. § 1862. This provision authorizes the President to adjust imports if the Secretary of Commerce determines that they threaten to harm national security. The presidential decision must be based on a recommendation from the Secretary, who must have conducted a formal investigation.

In the recitals of Proclamation 11032, Trump reiterates the findings made in Proclamations 9704, 9705, and 10962—regarding aluminum, steel, and copper, respectively—that these metals are imported “in such quantities or under such circumstances” that they threaten U.S. national security. This wording, repeated verbatim since 2018, has been the subject of legal challenges that have not fundamentally undermined the regime. The Court of International Trade and the U.S. Court of Appeals for the Federal Circuit have generally upheld the exercise of this presidential authority, although questions remain regarding the extent of the judicial deference applicable.

A Legal Framework at Odds with Industrial Reality

What makes Section 232 particularly powerful—and potentially dangerous for the balance of international trade—is that it is virtually immune to effective challenge before the World Trade Organization. The national security exception under Article XXI of the GATT is widely recognized as self-justifying by the states that invoke it, and WTO dispute settlement panels have only limited capacity to challenge sovereign decisions regarding national security. The United States’ trading partners—the European Union, Canada, Mexico, and Japan—have all attempted WTO or multilateral remedies, with limited success.

Proclamation 11032 perpetuates this framework. It invokes national security to justify not only high tariffs on raw metals but also tariff adjustments on agricultural equipment and residential air conditioners. This is a far cry from the core of national security in the strict sense. But U.S. case law and the international institutional architecture offer no effective mechanism to challenge this broad interpretation. It is a gray area that the Trump administration exploits deliberately and with formidable effectiveness.

Under Trump, Section 232 has become what NATO’s Article V is to the Atlantic Alliance—a provision whose interpretation can be stretched at will by whoever has the power to invoke it. I am not saying that protecting the U.S. steel industry is illegitimate. I am saying that using “national security” as a catch-all justification for any trade policy is slowly but surely eroding the distinction between economic policy and defense policy. And this erosion has consequences for everyone in the West.

Reactions from the industry and trade associations

Satisfied beneficiaries, silent new entities subject to the regulation

Official industry reactions to Proclamation 11032 have been generally positive among those benefiting from tariff reductions, and muted among the newly subject categories. The Recreational Vehicle Industry Association (RVIA), which represents manufacturers of recreational vehicles and related equipment, quickly released an analysis noting that the tariff reduction from 25% to 15% on certain equipment provides welcome relief for an industry that relies on imports of steel and aluminum parts.

Manufacturers and importers of steel racks, on the other hand, have not publicly commented on their sudden inclusion under the Section 232 regime. This discretion is understandable: aggressive lobbying against a decision that has already been published and is in effect could draw further attention to tariff optimization practices that these players would prefer not to have scrutinized too closely. Importers of aluminum lithographic plates—primarily commercial printers and their suppliers—are in the same situation.

Specialized analysts break down the practical risks

Among international trade consulting firms and specialized attorneys, Proclamation 11032 has sparked an avalanche of newsletters and client alerts. White & Case, Holland & Knight, Diaz Trade Law, Sandler, Travis & Rosenberg, Crane Worldwide Logistics, and C.H. Robinson all published analyses in the days following June 1, 2026. The prevailing message: understand the new categories, audit existing classifications, prepare U.S. content certifications, and update supply contracts to reflect the new tariff charges.

GHY International, a specialist in North American customs compliance, noted that CBP is expected to issue additional guidance and that importers should not consider CSMS #68855869 to be exhaustive. This caution proved relevant, as entire product categories—notably subheadings 9903.82.18 and 9903.82.19—have not yet received definitive guidance. The implementation environment is therefore, at least in its initial phase, characterized by significant residual uncertainty.

There is something slightly dizzying about the fact that the most useful analyses of a U.S. presidential proclamation come not from the relevant government agencies, but from private international trade firms whose clients pay to stay ahead of the regulations. Access to an understanding of the law itself becomes a competitive advantage. This is effective for those who can afford it. It is profoundly unfair for everyone else.

The Sunset Clause — December 31, 2027: A Return to the Status Quo?

A Temporary Horizon in a Permanent Tariff Landscape

Proclamation 11032 is explicitly temporary. All of the reduced rates it introduces—for the expanded Schedule III and for the new Schedule I-C—expire on December 31, 2027, at 11:59 p.m. Eastern Standard Time. Effective January 1, 2028, the affected products will revert to the rates set forth in Proclamation 11021—that is, the standard rates for their respective categories. For agricultural equipment and residential HVAC, which have just been added to Schedule III at a 15% rate, this reversion generally means a return to the 25% rate.

This sunset clause is a double-edged sword. On the one hand, it provides importers with a clear planning window. On the other hand, it creates uncertainty about the post-2027 period, which complicates long-term investment decisions. A Canadian manufacturer investing today in a production line for agricultural equipment destined for the U.S. market must factor into its financial model the risk that the tariff rate will rise from 15% to 25% in January 2028—unless the administration in power at that time renews the temporary provisions, as has been seen before with comparable programs.

The Probability of Renewal—A Political Variable

The likelihood of renewing the temporary provisions will depend largely on the U.S. political landscape in late 2027. At that time, if economic data confirms a measurable benefit for the covered domestic industries without an excessive negative impact on end users, there will be strong pressure for renewal. If, on the other hand, inflation in residential HVAC or agricultural equipment remains high and is attributed to Section 232 tariffs, there will be calls to let the provisions expire.

The Secretary of Commerce and the United States Trade Representative (USTR) are mandated by Proclamation 11032 to continuously monitor imports of metal products and inform the President of any circumstances that might warrant further action under Section 232. This monitoring requirement means that a new round of adjustments—upward or downward—is always possible even before the sunset clause expires. The Section 232 tariff landscape is, by its very nature, in constant flux.

The sunset clause set for December 31, 2027, reminds me of an old economic proverb that I’d rephrase as follows: nothing is as permanent as the temporary. I would stake my reputation as a columnist on the fact that these provisions will be extended, in one form or another, beyond 2027. The industries benefiting from the reduction will not passively accept a return to the 25% rate. They will fight back. And in U.S. trade policy, organized interests almost always win.

The Impact on the West's Trade Alliances

A Policy That Divides What It Claims to Protect

It is difficult to analyze Proclamation 11032 without assessing its impact on the economic cohesion of the Western world. On the one hand, the United States treats its European, Japanese, Korean, and British allies differently from China and Russia—and that is legitimate. On the other hand, the mere fact that these allies are subject to tariffs of at least 15% on industrial equipment creates trade friction that their leaders must justify to their parliaments and domestic industries.

The European Union responded to the initial Section 232 tariffs in 2018 with retaliatory measures targeting iconic American products—Kentucky bourbon, Harley-Davidson motorcycles, and Levi’s jeans. Since then, transatlantic trade relations have oscillated between negotiated truces and latent tensions. Proclamation 11032, by maintaining residual tariffs on European industrial equipment even under preferential agreements, serves as a reminder to the EU that the United States does not view strategic allies as automatically exempt trade partners. This is a defensible position in terms of U.S. economic sovereignty. It is also a stance that, cumulatively, erodes confidence in the stability of the rules of the transatlantic trade game.

The United Kingdom after Brexit—a Textbook Case

The British case perfectly illustrates this ambivalence. Since leaving the European Union, the United Kingdom has negotiated a partial trade agreement with the United States that grants it preferential tariff treatment under Section 232. For steel, British products in which the steel was smelted and cast in the United Kingdom benefit from a 25% rate (compared to 50% for others) under Annex I-A. For steel products, they benefit from an alternative rate of 15% (compared to 25%). Proclamation 11032 maintains these provisions for mobile industrial equipment listed in Annex I-C and sets the maximum combined rate at 15% for eligible British products.

This preferential treatment is being touted in London as a success of the post-Brexit strategy of bilateral negotiations with Washington. In a sense, it is. But it also highlights the fact that access to the U.S. market is now a negotiable geopolitical variable that each country must secure individually, and that membership in a trading bloc—such as the EU—no longer guarantees, in and of itself, treatment equivalent to that obtained through direct negotiation. This trade realpolitik works well for Washington. It is destabilizing for the multilateralism that has shaped global trade since 1947.

I’ll take this line of thought to its logical conclusion: Trump is right about one thing that the liberal establishment refuses to admit. Global economic competition is not a positive-sum game where everyone wins if they follow the rules. It is also a competition for power, and the United States has long played the multilateral game while financing the rise of its competitors. Section 232 is a course correction. Abrupt, imperfect, sometimes counterproductive—but a correction nonetheless. Europe would do better to develop its own tools for trade reciprocity rather than complain about Washington’s.

Conclusion: The increasingly refined price barrier is here to stay

An increasingly sophisticated system that is becoming less and less reversible

Proclamation 11032 of June 1, 2026, is not a surprise move. It is another step in the methodical construction of a sector-specific tariff regime that, over the past eight years, has transformed U.S. trade policy regarding industrial metals. From Proclamation 9704 of 2018 to Proclamation 11032, each document has added a layer of complexity, closed a loophole, adjusted a rate, and expanded the scope. The result is a tariff structure whose very sophistication acts as a barrier to entry—no longer just for foreign metals, but for understanding and navigating the system itself.

The facts are clear: a reduction from 25% to 15% on agricultural equipment and residential HVAC systems; the creation of Annex I-C for mobile industrial equipment with a four-tier structure; a lowering of the U.S. content threshold from 95% to 85%; USMCA treatment maintained for Canada and Mexico with a minimum of 15%; and the inclusion of aluminum lithographic plates and steel racks. All of this has been in effect since June 8, 2026, and remains valid through December 31, 2027.

What This Reveals About U.S. Industrial Strategy

Beyond the technical details, Proclamation 11032 reveals a U.S. industrial strategy that is no longer merely protectionist—it is selectively incentivizing. It imposes a 50% tariff on importers of non-U.S. raw metals. It penalizes non-partner-country derivatives with a 25% tariff. It offers a narrow window of relief to those using U.S. metals (10%) or metals from allied nations under agreement (15%). And it imposes a 200% tariff on Russia for reasons that go far beyond trade policy. It is a complex industrial policy disguised as a customs tariff. It is not perfect, it is not fair, but it is consistent with a specific vision of what the United States wants to be economically in the 21st century.

For Western allies, the lesson is twofold. First lesson: the United States will not apologize for protecting its steel industry. It did so under Obama with anti-dumping duties, it is doing so under Trump with Section 232—and it will likely do so under the next administration in one form or another. Second lesson: In this new landscape, bilateral negotiations and “Made in America” agreements are the only paths to preferential access to the U.S. market. WTO multilateralism will not be enough. Those who adapt to this reality—such as the post-Brexit United Kingdom or Japan with its reciprocal agreements—retain a seat at the table. The others pay the full price.

By Maxime Marquette, columnist