President Trump, on Thursday, April 2nd, signed a proclamation which adjusts the steel, aluminum, and copper Section 232 tariffs, as well as an executive order for pharmaceutical import tariffs.

Specifically, according to a White House fact sheet, the proclamation “defines the way that tariffs are assessed, ensuring that they reflect the full value of imported steel, aluminum, and copper products—not an artificially low foreign price.”

The proclamation also establishes rules for calculating Section 232 metals tariffs:

• 50% Tariff on Full Value: Applied to goods composed entirely, or almost entirely, of aluminum, copper, or steel. (Annex I-A – Tariff List) 
• 25% Tariff on Full Value: Applied to derivative products where steel, aluminum, or copper is the primary component.  (Annex I-B – Tariff List)
• 10% Duty: Applied to goods manufactured abroad exclusively from US-origin steel, aluminum, and copper.    
• 15% Duty (Through 2027): Applied specifically to certain metal-intensive industrial and electrical grid equipment to encourage the expansion of US industrial capacity.  (Annex III – Tariff List)
• No Tariff: Goods containing 15% or less aluminum, copper, or steel are no longer subject to Section 232 tariffs. (Annex II – Tariff List) 

The Trump administration said the new Section 232 tariff rates for steel, aluminum and copper will take effect at 12:01 a.m. ET on April 6. See Annexes I-A, I-B, II, III & IV for more details.

In his executive order, President Trump said under Section 232 that his administration will impose a 100% tariff on patented pharmaceutical products and ingredients. The tariffs will take effect in 120 days for certain large companies, and 180 days for smaller companies.

However, if a pharmaceutical product is from the European Union, Japan, Korea, or Switzerland and Liechtenstein, a 15% tariff will apply. If a pharmaceutical product is from the United Kingdom, a lower tariff will apply, subject to the recently concluded UK pharmaceutical agreement.

For companies that enter into Most Favored Nation (MFN) pricing agreements with the Health and Human Services (HHS) Department and onshoring agreements with the Commerce Department, a 0% tariff will apply through Jan. 20, 2029, according to the EO. For companies that only enter into onshoring agreements with the Department of Commerce, a 20% tariff will apply. The Commerce Department and HHS will provide pathways for companies to enter into onshoring and MFN pricing deals with the U.S. Government, according to a White House fact sheet accompanying the EO.

“The Proclamation establishes strong monitoring and enforcement mechanisms, including external audits and tariff increases on future and past imports,” the fact sheet added.

0% Tariff (through January 20, 2029): Available to companies that enter into both:

• Most Favored Nation (MFN) pricing agreements with the Department of Health and Human Services (HHS), and
• Onshoring agreements with the Department of Commerce.

20% Tariff: Applies to companies that enter only into onshoring agreements with the Department of Commerce.

The Department of Commerce and HHS are expected to establish pathways for companies to participate in these programs.

Enforcement Measures
The administration has indicated that the proclamation includes enhanced monitoring and enforcement mechanisms, including external audits and the potential for tariff increases on both future and past imports.

Key Takeaways for Importers

• Review product compositions carefully to determine applicable tariff tiers.
• Assess exposure to increased duties, particularly for metal derivatives and pharmaceutical imports.
• Monitor eligibility for exclusions and incentive programs tied to onshoring and MFN pricing agreements.
• Prepare for implementation timelines and potential compliance requirements.

RIM logistics, ltd. will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative if you have any further questions.