
How the duties interacted
- Section 232 goods excluded from the reciprocal tariff. The April 2025 reciprocal order excluded goods subject to Section 232 steel, aluminum, and auto duties, and goods that later became subject to Section 232.
- Steel and aluminum derivatives. From June 4, 2025, derivatives paid Section 232 duty on metal content and the reciprocal tariff on the rest. On August 18, 2025, 407 more HTS codes were added to the derivative list.
- Copper. A 50 percent Section 232 duty on semi-finished copper and intensive derivatives took effect August 1, 2025, applied to copper content. Non-copper content stayed subject to the reciprocal tariff.
- Timber and lumber. Section 232 duties took effect October 14, 2025, including 10 percent on softwood lumber and 25 percent on upholstered wooden furniture, kitchen cabinets, and vanities. Covered goods were excluded from the reciprocal tariff.
What this means for refunds
For each product, the refundable IEEPA duty depends on which side of these dates the entry fell and how the metal or wood content was reported. Section 232 duties are not refundable.
Records to have ready
- HTS codes by product with the dates each became subject to Section 232
- Metal content values reported per line
- ES-003 and ES-022 reports
Sources
- Executive Order 14257 (Federal Register, Apr 7, 2025)
- Thompson Hine: steel and aluminum at 50% and stacking (Jun 2025)
- Husch Blackwell: 407 derivative codes added effective Aug 18 (Aug 15, 2025)
- Federal Register: Proclamation 10962, copper (Aug 5, 2025)
- CBP CSMS #66492057: timber and lumber (Oct 10, 2025)
How we can help
We explain the general options for your situation in plain English, show you which ACE reports to pull, and email you a list of licensed customs brokers and attorneys who handle it. The review is free for importers. We do not file with CBP or give legal advice.
General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.
General information, not legal advice. Tariff refund rules and court rulings are changing. Deadlines depend on your own entries. Confirm your options with a licensed customs broker or attorney. TariffClarity is not a law firm or customs broker.