Guide to Section 232 steel and aluminum tariffs affecting electronics: enclosures, heatsinks, connectors, transformer cores, and derivative articles under HTS codes.
Section 232 tariffs under the Trade Expansion Act of 1962 allow the President to restrict imports that threaten national security. The Trump administration applied 25% tariffs on steel imports (effective March 2018) and 10% on aluminum imports (effective March 2018, raised to 25% in 2025 for some categories). These tariffs apply to the base metals AND to certain downstream 'derivative' articles that contain significant steel or aluminum content — some of which are relevant to electronics.
The most common electronics-adjacent products subject to Section 232 are: metal enclosures and chassis (HTS 8537.10 and 8538.90 if steel/aluminum construction), aluminum heatsinks (HTS 7616.99 — aluminum articles), steel transformer cores (HTS 8504.90 — parts of transformers), and aluminum die-cast housings for power supplies and inverters (HTS 7616.99 or 8504.90). The tariff applies when the steel/aluminum content is substantial.
Section 232 and Section 122 can stack. A steel enclosure from China could face: 25% Section 232 (steel) + 25% Section 301 (China goods) + 10% Section 122 = 60% additional duty on top of MFN base rate. A steel enclosure from Germany faces: 25% Section 232 + 10% Section 122 = 35% additional. USMCA-origin steel/aluminum from Mexico/Canada is exempt from Section 232 under the May 2019 exclusion agreement.
Companies can file for Section 232 exclusions with the Department of Commerce if no comparable domestic product is available. Exclusion requests take 90–150 days and are product-specific. Additionally, quota/tariff-rate-quota (TRQ) agreements exist with the EU, Japan, UK, and others, where specific steel/aluminum products enter at 0% up to a quota volume. Electronics buyers with substantial heatsink or enclosure imports should evaluate exclusion filing.
No. Section 232 covers steel and aluminum. Copper (used in PCB traces) is not subject to Section 232 tariffs. However, copper can be subject to other tariff provisions.
Yes, aluminum heatsinks (HTS 7616.99) can be subject to Section 232 aluminum tariffs (25% in 2025). Country of origin and whether a quota agreement or exclusion applies will determine the actual rate. Mexico/Canada-origin heatsinks are exempt under USMCA.
25% on most steel mill products. Some countries have tariff-rate-quota arrangements (EU, UK, Japan) where quota volume enters at 0%. Steel from Canada and Mexico is exempt under USMCA. The rate stacks with Section 122 for non-USMCA countries.
Steel server racks (HTS 9403.10 — metal office furniture, or 8538.90 — parts of switchgear, depending on classification) may be subject to Section 232. Classification and origin determine the rate. Chinese-origin steel racks would also face Section 301 (25%) and Section 122 (10%), creating very high total duty.
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