Steel & Aluminum
Section 232 tariffs, regional melt-and-pour rules, and the collision between national-security policy and integrated North American metals trade. The USMCA text is unchanged, but late-July 2026 brought a new Section 232 aluminum onshoring incentive, fresh Section 338 pressure on Canada, and a bilateral round that kept metals firmly on the table.
Last reviewed and updated: October 18, 2026 · Next scheduled events: Fourth U.S.–Mexico bilateral round, which Ebrard said on Oct. 16 must be held before year-end (ICPA has located no announced date as of Oct. 18) · Joint review comments and hearing requests due to USTR, Jan. 12, 2027 · ← Back to Review Watch
No USMCA text change to steel or aluminum trade has been identified as legally effective as of October 18, 2026. U.S. Section 232 tariffs on Canadian and Mexican steel and aluminum, currently 50% on covered metal products with differentiated derivative-product and U.S.-content rules, remain in effect under separate domestic legal authority (19 U.S.C. § 1862) and are not suspended by USMCA preferential origin qualification. The late-July developments below changed the operating environment around that unchanged rule, not the rule itself.
Five-Minute Briefing
Everything a compliance professional needs before the details.
Steel and aluminum sit at the center of a direct conflict between two visions of North American trade: Canada and Mexico want USMCA-originating metal to move tariff-free within an integrated regional market, while the current U.S. position treats USMCA origin alone as insufficient protection against import surges, global overcapacity, and non-party content. The outcome will affect metal pricing, automotive sourcing, downstream manufacturing costs, and the practical value of USMCA preference itself.
The U.S. reimposed 25% Section 232 tariffs on Canadian and Mexican steel and aluminum on March 12, 2025, and increased the rate to 50% on June 4, 2025. Canada retaliated with 25% tariffs covering roughly C$29.8 billion of U.S. goods, which remained in effect as of the most recent official Canadian statement reviewed. Mexico has relied on negotiation, enhanced import monitoring, and country-of-melt-and-pour documentation rather than comparable retaliation. In April and June 2026, the U.S. restructured the tariff regime, introducing differentiated rates for derivative products and a deduction for U.S. content in qualifying Canadian and Mexican products. The U.S. declined to renew USMCA in its current form on July 1, 2026, triggering annual reviews through 2036.
Late-July 2026 update. No legally effective USMCA amendment on steel or aluminum has been located since July 19, 2026. Two domestic-law developments nevertheless changed the operating environment. On July 20, 2026, the United States established a new Section 232 investment incentive for primary aluminum production, authorizing Commerce to approve onshoring plans and allow qualifying firms to import primary aluminum at half the otherwise applicable Section 232 rate, subject to monitoring, audits, rescission, and future HTSUS implementation steps. Also on July 20, the United States imposed new Section 338 tariffs on certain Canadian goods while expressly excluding products already subject to Section 232, leaving the existing steel and aluminum tariff regime in place.
Negotiating status. On July 23, 2026, the United States and Mexico concluded a third bilateral round that again treated steel and aluminum as an active review topic alongside autos, labor, agriculture, and economic security. Public accounts of the joint statement say the two sides emphasized stronger North American manufacturing, regional supply chains, and action against non-party free-riding, and agreed to hold a fourth bilateral round in Washington in early September 2026.
No comprehensive public trilateral metals settlement has been located as of July 27, 2026. It also remains unclear whether the original 2019 U.S.–Canada and U.S.–Mexico bilateral steel-and-aluminum arrangements, which contemplated narrower, product-specific tariff mechanisms, have been formally superseded or remain nominally in force alongside the broader 2025–2026 measures. Reuters reports Mexico wants Section 232 auto and metals tariffs reduced before making wider concessions, and that the United States continues to press for U.S.-specific automotive content and reduced Asian content; these are reported negotiating positions, not published government text.
Potential outcomes include a North American metals security arrangement, tariff-rate quotas based on historical trade volumes, regional melt-and-pour or smelt-and-cast requirements tied to preferential treatment, expanded U.S.-content deductions, coordinated action against global excess capacity and non-party investment, or continuation of the current Section 232 regime without a negotiated settlement. The July 20 aluminum onshoring program signals that any eventual metals settlement may be structured through executive action, tariff adjustments, and origin-linked conditions rather than treaty text alone. A formal USMCA treaty amendment is possible but considered less likely than an executive arrangement or Free Trade Commission action.
The tariff exposure is live today, so metals-sourcing diligence should not wait on the negotiation:
- Confirm country of melt-and-pour (steel) and smelt-and-cast (aluminum) for inputs
- Review Chapter 99 derivative-product classifications and metal-content valuation
- For USMCA-qualifying Canadian and Mexican articles on Annex I-C, document U.S. content as BIS’s October 14 guidance to CBP defines it (91 FR 65162): the value of parts wholly obtained, entirely produced, or substantially transformed in the United States, plus, to the extent not already counted, the value of U.S. melted-and-poured steel and smelted-and-cast aluminum. Under Proclamation 11032, through December 31, 2027 the 25% duty applies only to non-U.S. content, with a 15% minimum effective duty. The 85% threshold is a separate metal-weight test for treating metal content as entirely U.S. metal
- Screen Canadian-origin SKUs against the September 15 modified Section 338 list (CBP CSMS #69851916) and the September 29 import-exclusion annexes; since September 15 the Section 232 carve-out (9903.03.15) applies only to dairy-heading goods, so do not rely on it for metals
- Track Commerce implementation of the July 20 aluminum onshoring program if you produce or source primary aluminum
Do not assume USMCA preferential origin will exempt covered metal or metal-content products from Section 232 duties, and do not rely on reported quota, exemption, or metals-relief figures that have not been confirmed in published government text.
Confirmed Developments
Official government actions and confirmed events relevant to steel and aluminum. None of these amends the USMCA text; several operate under separate Section 232 or Section 338 authority.
The Bureau of Industry and Security published a notice in the Federal Register (91 FR 65162, FR Doc. 2026-20938, Docket No. 260918-0056) that provides guidance to U.S. Customs and Border Protection on assessing “U.S. content” for purposes of implementing clause (2)(d) of Proclamation 11032. The notice states: “The Department of Commerce advises that, for purposes of implementing clause (2)(d) of the Proclamation, the term ‘U.S. content’ means the following: 1. The value of the product attributable to parts wholly obtained, entirely produced, or substantially transformed in the United States, and 2. To the extent not otherwise accounted for in (1), the value of the product attributable to steel that was melted and poured in the United States, aluminum that was smelted and cast in the United States, and/or copper that was smelted and cast in the United States.” The definition applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET October 14, 2026. The notice is guidance to CBP: it sets out no filing procedure and directs product-specific questions to CBP. It states no tariff rate, annex or date window; those come from Proclamation 11032 itself (91 FR 34085), under which the 25% Section 232 duty on USMCA-qualifying Annex I-C aluminum and steel articles of Canada and Mexico entered June 8, 2026 through December 31, 2027 applies only to their non-U.S. content, with a 15% minimum effective duty. ICPA analysis, not stated in the source: the notice does not mention CSMS #68855869 or entry reporting. The two-line structure under 9903.82.20 / 9903.82.21 in that CSMS message, which covers USMCA-eligible derivative steel articles of Canada and Mexico under subdivision (c)(xi) of U.S. note 16 and caps the U.S.-content line at 40 percent of value, remains the operative CBP instruction located by ICPA for those articles, but the message describes U.S. content only as value “attributable to parts produced in the United States,” which is narrower than the BIS definition. ICPA has located no CBP update reflecting the notice as of October 18, so importers declaring U.S. content on the 9903.82.21 line should watch for one. Federal Register, 91 FR 65162, Oct 14 ↗ Proclamation 11032 ↗
USTR states: “Building on the productive discussions at the G20 Trade Ministerial in Milwaukee, Wisconsin, these fourteen economies joined the United States in signing a Joint Ministerial Statement that expresses our collective resolve to work together in new, dedicated sectoral platforms to examine and take effective actions that address structural excess capacity and production in several key sectors of concern.” The release says USTR “convened a meeting of senior officials of 14 economies” “on the margins of the Organisation for Economic Co-operation and Development (OECD) Trade Committee.” The signatories are the trade ministers of Argentina, Australia, Canada, the European Union, France, Germany, India, Italy, Japan, the Republic of Korea, Mexico, Poland, Türkiye, the United Kingdom and the United States. The platforms start “with Autos and EVs, Batteries, Chemicals, Foundational Semiconductors, and Solar Panels”; steel and aluminum are not among them, and the statement refers to steel only in recounting the 2016 G20 history and the Global Forum on Steel Excess Capacity. Signatories commit to meeting “before December 2026, at the technical level, to develop terms of reference; share non-confidential information and data,” and the statement says countries should “cooperate, share information, and take complementary action, wherever possible.” It does not mention the USMCA. ICPA analysis, not stated in the source: this is a separate track from the September 30 GFSEC “Milwaukee Framework” recorded above; the new platforms start with autos and EVs, batteries, chemicals, semiconductors and solar, while steel remains with the GFSEC. Canada and Mexico signed alongside the United States while their Section 232 disputes with Washington remain open, and the signatory list omits G20 members Brazil, China, Indonesia, Russia, Saudi Arabia and South Africa. The statement creates no new U.S. filing, payment or documentation requirement for importers. USTR, Oct 7 ↗ Joint Ministerial Statement (PDF) ↗
Secretaría de Economía Comunicado No. 93 reports that Secretary Ebrard held “una reunión de casi una hora” (a meeting of nearly an hour) with Ambassador Greer on October 1 “en los márgenes de la reunión de ministros de Comercio del G20” in Milwaukee, and quotes Ebrard: “Nos estamos acercando (México y Estados Unidos) a muchas cosas. A avanzar, a acercar posiciones, resolver temas.” The communiqué does not list the topics discussed and does not mention steel, aluminum or Section 232. In a separate exchange with the press the same day (Mensaje a medios), Ebrard said: “Necesitamos reducir 232 en acero y vehículos, eso nos falta.” Asked about Ambassador Greer’s comments on differentiated tariff treatment by country or region, he said “México tiene la mejor posición ahorita” and that of the G20 members “los que pagamos menos somos nosotros.” No agreement text or effective date was announced. ICPA analysis, not stated in the source: the 50 percent Section 232 rate on Mexican steel and aluminum is unchanged, and as of October 18 ICPA has located no announced date for the fourth U.S.–Mexico round. Secretaría de Economía, Comunicado No. 93, Oct 1 ↗ Secretaría de Economía, Mensaje a medios, Oct 1 ↗
In Comunicado No. 92, the Secretaría de Economía reports that at the Global Forum on Steel Excess Capacity session held within the G20 Trade Ministerial, Secretary Ebrard said Mexico promotes transparency and traceability in steel trade through automated analysis of imports, and that Mexico’s steel industry, which “no recibe subsidios y que tiene bajas emisiones contaminantes” (receives no subsidies and has low emissions), does not compete on fair terms against industries operating under different standards that engage in unfair practices. The communiqué does not mention Section 232 or the T-MEC review. Secretaría de Economía, Comunicado No. 92, Sep 30 ↗
USTR states: “Today, Ambassador Jamieson Greer chaired the Ministerial Meeting of the Global Forum on Steel Excess Capacity, which reached consensus on a comprehensive framework for joint action (‘the Milwaukee Framework’).” The meeting was held on the margins of the G20 Trade Ministerial, and Greer invited like-minded partners to take similar steps. The USTR release does not describe the framework’s content and does not name Canada, Mexico, USMCA or Section 232. According to the Alliance for American Manufacturing’s October 1 summary of the framework text (Tier 2), members agree to “undertake antidumping, countervailing duty, and global safeguard investigations, including possible self-initiation,” and to adopt “procedures to collect and publish ‘country of melt and pour’ data from importers of steel products,” and the framework “encourages” members to “eliminate subsidies for their own steel industries”; AAM describes the framework as aspirational rather than binding. The framework text itself could not be retrieved for this review. ICPA analysis, not stated in the source: melt-and-pour reporting is the mechanism used to detect circumvention and transshipment, and the framework is a plurilateral statement of intent that does not by itself create any new U.S. filing, payment or documentation requirement for importers. USTR, Sep 30 ↗
CBP’s CSMS # 69851916 implements Proclamations 11064 and 11065 for goods entered for consumption or withdrawn from warehouse on or after 12:01 a.m. ET September 15, 2026. The attached list “provides the complete list of HTSUS classifications subject to Section 338 duties as of September 15, 2026, including 122 additional HTSUS classifications now subject to HTSUS 9903.03.12 or HTSUS 9903.03.14.” Ten classifications come off: 2208.30.60 and 2208.70.00 from 9903.03.12, and 2501.00.00 (salt), 2523.29.00 (Portland cement), 2940.00.60, 4803.00.40, 4818.90.00, 7801.10.00, 8537.10.91 and 9507.10.00 from 9903.03.14; the 9903.03.13 dairy list is unchanged. CBP states: “As of September 15, 2026, only goods subject to HTSUS 9903.03.13 are eligible to claim HTSUS 9903.03.15.” The additional duties remain eligible for drawback, and the Chapter 98 and FTZ privileged-foreign-status rules are restated. ICPA analysis, not stated in the source: importers of Canadian-origin goods should re-run the attached “Section 338 Canada Modified HTS LIST eff 091526” against their Chapter 99 filing logic, because coverage changed in both directions, and CBP’s August 21 guidance (CSMS # 69606660) sets out no USMCA exception, and the White House fact sheet states the duties apply “regardless of whether a good originates under the U.S.-Mexico-Canada Agreement (USMCA).” The bulletin does not mention Section 232; the stacking rule comes from Proclamation 11065, recorded above. CBP CSMS # 69851916, Sep 11 ↗
Proclamation 11065 (91 FR 58339, published September 14) modifies the scope of the additional duties imposed under Proclamation 11048, adding the products in Annex I Part A to the 50 percent duty and removing those in Part B for goods entered on or after 12:01 a.m. ET September 15, 2026. It states: “The duties imposed pursuant to Proclamation 11048, as modified in this proclamation, shall apply in addition to duties imposed pursuant to section 232 of the Trade Expansion Act of 1962, as amended.” ICPA analysis, not stated in the source: this replaces the Section 232 exclusion recorded on this page under the July 20 and August 18–22 entries. The annexes are published as images; Troutman Pepper Locke reads Part A as adding iron or steel structures and columns and aluminum profiles, tubes and pipes, alongside seating, electric lamps, golf carts, passenger vehicles of 1,000 cc or less and outboard motorboats, and Part B as removing salt, Portland cement, certain sugars, tissue stock, refined lead and switchgear. Confirm the metal lines against the HTS list attached to CSMS # 69851916 before relying on them. The same day the President signed three exclusion proclamations (11061 to 11063: alcoholic beverages, dairy-related products, motor-vehicle-sector products) effective for goods imported on or after 12:01 a.m. ET September 29, and Ambassador Greer described the package as “targeted import bans as authorized by Section 338 and a calibration of the underlying Section 338 tariffs.” The President also directed USTR and GSA to remove $50 billion worth of Canadian-origin products from GSA’s Multiple Award Schedules. Proclamation 11065, 91 FR 58339 ↗ USTR statement, Sep 8 ↗ Troutman Pepper Locke, Sep 10 (Tier 2) ↗
The revised Customs Notice 25-11 administers the amended United States Surtax Order (Steel and Aluminum 2025): from September 8, 2026 the surtax is 50 percent of value for duty for aluminum goods in new Schedule 1.1 and steel goods in new Schedule 2.1, while goods in the original Schedules 1 and 2 stay at 25 percent, declared under codes 26187A to 26187D. “The increased surtax rate from 25% to 50% effective September 8, 2026, for certain steel and aluminum goods does not apply to goods that were in transit on or before September 8, 2026,” which remain at 25 percent under code 25095A. Customs Notice 26-23 administers the United States Surtax Order (2026), introduced “in response to the U.S.’ imposition of Section 338 tariffs”: surtaxes of 15, 25 or 50 percent apply to U.S.-origin goods in Schedules 1 to 3 imported on or after September 8, declared with codes 26186A to 26186C. Where a good is covered by both the 2026 Order and the Steel Derivative Goods Surtax Order, CBSA states only the 2026 Order surtax applies. Requests for remission continue to be accepted under the Government’s U.S. remission framework. CBSA Customs Notice 25-11 ↗ CBSA Customs Notice 26-23 ↗
The Department of Finance Canada updated its remission-request guidance on August 31 to confirm that Canada’s tariff remission framework remains available for the 15, 25 and 50 percent counter-tariffs taking effect September 8, 2026 on U.S.-origin goods drawn from the Section 338 and Section 232 target lists, including the steel and aluminum lines that carry the 50 percent rate. The guidance sets out the assessment criteria and the submission requirements an importer must meet to seek exceptional relief. Canadian importers of U.S. steel and aluminum facing the doubled surtax now have a defined relief avenue. Trade reporting indicates the government intends the new measures to benefit from remission under the United States Surtax Remission Order (2025), subject to Governor in Council approval. Department of Finance Canada, Aug 31 ↗
The accompanying backgrounder sets out the measure at the tariff-item level, 629 entries, and was itself updated as of August 26, 2026. Scope turns on whether a good is eligible to be marked as a good of the United States under the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations. Goods in transit to Canada on the day the measures come into force are excluded. ICPA analysis, not stated in the backgrounder: the order defines U.S. origin by reference to the marking regulations only and does not mention the CUSMA preferential rules of origin, so members should not assume that claiming preference removes a listed good from the surtax. Administrative detail is to follow through CBSA customs notices.
Under the Department of Finance Canada countermeasures package, Canadian surtaxes on U.S.-origin steel and aluminum rise from 25 to 50 percent effective 12:01 a.m. on September 8, 2026. The 50 percent band covers steel and aluminum products previously subject only to a 25 percent counter-tariff, together with furniture and clothing and apparel; certain steel and aluminum derivative products sit in the 25 percent band. Rates are matched product by product to the corresponding U.S. Section 338 or Section 232 rate, across a package covering $27.6 billion in U.S. imports.
Prime Minister Carney announced that Canada has suspended negotiations with the United States and recalled its team to Ottawa, after the U.S. presented terms Canada characterized as uneconomic and unfair and the Section 338 duties took effect. Canada will impose matching dollar-for-dollar tariffs on the new U.S. measures effective the Tuesday after Labour Day, September 8, 2026, targeting steel, dairy, appliances, agricultural equipment, pulp and paper, and electronics, in addition to products already covered by Canada’s existing responses to the Section 232 and Section 338 actions. Members exporting U.S.-origin steel and the other listed goods into Canada should anticipate new surtaxes from September 8. The implementing Canada Gazette order had not been published as of August 24. Prime Minister of Canada, Aug 22 ↗
An August 18 presidential proclamation temporarily suspended the 50 percent Section 338 duties on certain Canadian goods imposed by Proclamations 11046, 11047, and 11048, moving the effective date from August 19 to 12:01 a.m. ET on August 22, 2026, citing the status of negotiations. Talks then broke down and the duties entered into force as rescheduled. Goods already subject to Section 232 duties, including steel and aluminum articles, remain excluded from the Section 338 action. Superseded for entries on or after September 15, 2026: Proclamation 11065 now applies the Section 338 duties in addition to Section 232 duties; see the September 8 entry below. The exclusion is now a filing obligation rather than a silent carve-out: CBP CSMS # 69606660 requires covered Canadian entries to be reported under HTSUS 9903.03.12 through 9903.03.16, with 9903.03.15 and 9903.03.16 carrying the zero-rate excluded categories. The proclamation was published in the Federal Register on August 24, 2026 as Doc. 2026-17294. Federal Register, Aug 24 ↗
The World Steel Association reported North American crude-steel production of 9.5 million tonnes in June 2026, up 5.0% year over year, including 7.2 million tonnes for the United States, up 3.5%. The release resolves no legal question but is a fresh datapoint for the industrial-policy context. See Economic Evidence.
The third bilateral round in Mexico City again covered steel and aluminum and derivative products alongside autos, economic security, labor, agriculture, and electronic payments. The July 23 joint statement emphasized growing North American manufacturing, regional supply chains, and addressing non-party free-riding, and directed a fourth round in Washington in early September 2026. Secretary Ebrard described advances on steel, aluminum, and substitution of imports from Asia. A Mexican communiqué confirmed the meeting covered “acero y aluminio y sus derivados.” Canada is not party to this bilateral track.
In Senate Finance testimony, Ambassador Greer said USTR is continuing to investigate top trading partners for acts, policies, and practices that create, sustain, or contribute to structural excess capacity and production, that negotiations with Mexico continue after the U.S. declined to renew USMCA, and that the Administration remained open to a path with Ottawa during the 30-day lead time before the new Canada tariffs take effect. Reuters separately reported Greer is aiming for interim arrangements with Canada and Mexico by year-end, leaving harder issues for 2027.
Three Section 338 proclamations impose an additional 50% duty on roughly $20 billion of Canadian dairy, alcohol, and motor-vehicle goods, originally set for August 19, 2026; Proclamation 11056 later moved the start to August 22, 2026. The White House fact sheet and USTR statement confirmed the duties did not apply to products already subject to Section 232, including steel, aluminum, copper, and their derivatives; from September 15 CBP limited that carve-out to dairy-heading goods (see the September entries). USMCA origin does not otherwise exempt covered goods. The metals rate is unchanged, but the Canada file is now more pressured.
The President issued a proclamation authorizing Commerce to establish a program for companies that build, refurbish, or expand U.S. primary-aluminum production. Approved companies may import a quantity of primary aluminum equal to the project’s reasonably anticipated annual output at half the otherwise applicable Section 232 rate, with construction required to start by January 20, 2029. Commerce may require reports and audits, rescind benefits (including retroactively), and pursue duties and penalties through CBP. It builds on the earlier Canada/Mexico import-adjustment offset framework. Not a USMCA amendment. See Current Rule vs. Proposed Change.
At the first joint review, the United States did not agree to renew USMCA in its current form, triggering annual reviews through 2036 under Article 34.7.4. This did not change the Section 232 metals regime, which sits on separate domestic authority.
Proclamation 11021 (April 2, 2026) and Proclamation 11032 (June 1, 2026) set differentiated rates for primary metals, derivatives, and specified machinery, and limited the duty on qualifying USMCA-originating products to non-U.S. content. The June action lowered from 95% to 85% the metal-weight threshold for a product’s metal content to count as entirely U.S. metal (a test separate from the USMCA non-U.S.-content calculation) and added lithographic plates and steel racks to scope. CBP implementation guidance issued June 5, 2026 (CSMS #68855869).
The United States increased the steel and aluminum Section 232 duty from 25% to 50%, applied independently of USMCA preferential origin. This remains the baseline rate on covered Canadian and Mexican metal products. See Current Rule vs. Proposed Change.
Overview
The USMCA does not contain a dedicated steel-and-aluminum chapter and does not prohibit the United States from invoking its domestic national-security authority under Section 232 of the Trade Expansion Act of 1962. As a result, USMCA-originating steel and aluminum can qualify for preferential tariff treatment under Chapter 4 while remaining separately subject to Section 232 duties, two legal regimes operating on different tracks.
The central conflict is between Canada and Mexico’s position that USMCA-originating metal should move tariff-free within an integrated regional market (subject to trade remedies and anti-circumvention enforcement), and the current U.S. position that origin alone does not adequately address import surges, global overcapacity, third-country content, transshipment, or displacement through Canada and Mexico. The U.S. reimposed and then increased Section 232 tariffs in 2025, layered in derivative-product coverage, metal-content valuation rules, and a U.S.-content deduction, and in late July 2026 added an aluminum onshoring incentive that uses Section 232 as an industrial-policy tool rather than only a border restriction.
For compliance teams, the immediate legal requirements remain unchanged unless and until the parties adopt a legally effective amendment, proclamation modification, or negotiated arrangement. Because Section 232 duties apply independently of USMCA qualification, importers should not assume that origin certification alone resolves metals tariff exposure.
Controlling Authorities
The legal texts that govern metals trade today, both USMCA origin rules and the separate Section 232 tariff regime.
Current Rule vs. Proposed Change
The most consequential comparisons on this page. Nothing here is legally effective unless labeled “confirmed by controlling authority.”
50% Section 232 duty on covered Canadian and Mexican steel and aluminum, effective June 4, 2025, applied independently of USMCA preferential origin qualification.
Tariff-rate quota, regional-origin exemption tied to melt-and-pour/smelt-and-cast, expanded content deduction, or continuation of the current rate without a negotiated settlement.
April 2026 restructuring set 50% for primary metal products, 25% for certain derivative products, and a temporarily reduced 15% for specified industrial machinery and power equipment. A June 2026 modification, for goods entered June 8, 2026 through December 31, 2027, applies the 25% duty on Annex I-C aluminum and steel articles of Canada and Mexico that qualify for USMCA preferential treatment only to their non-U.S. content, with a 15% minimum effective duty. Separately, it lowered from 95% to 85% the metal-weight threshold for metal content to be treated as entirely U.S. metal.
Content-based deduction appears to be the practical compromise mechanism the U.S. is currently using; further expansion of qualifying products or a full regional-content exemption remains unconfirmed.
Under the July 20, 2026 aluminum proclamation, Commerce may approve onshoring plans for projects that build, refurbish, or expand U.S. primary-aluminum production. If approved, the company may annually import a quantity of primary aluminum equal to the project’s reasonably anticipated annual output at half the Section 232 rate otherwise in effect, with construction required to begin by January 20, 2029. Commerce may monitor compliance, require audited reporting, rescind benefits, and seek retroactive duties and penalties through CBP.
Not a USMCA amendment, but a concrete example of the United States using Section 232 as an industrial-policy tool to reshape North American aluminum supply. It increases the likelihood that any eventual metals settlement is structured through executive action, tariff adjustments, and origin-linked conditions rather than treaty text alone.
USMCA origin qualification does not itself establish melt-and-pour or smelt-and-cast location. In July 2024, the U.S. and Mexico announced enhanced origin-information requirements for steel entering Mexico to address evasion concerns.
A formal requirement that preferential or reduced-tariff treatment depend on North American melt-and-pour (steel) or smelt-and-cast (aluminum) status has been widely discussed as a likely negotiating outcome but has not been located in published government text as final policy.
Section 232 duties on Mexican steel and aluminum remain in force at 50%; no negotiated relief has been reduced to published government text.
Reuters reports Mexico wants Washington to reduce Section 232 auto and metals tariffs before making concessions on other issues, while the U.S. presses for U.S.-specific content and reduced Asian components. The metals file is therefore tied to the automotive rules-of-origin fight and cannot be analyzed in isolation. Reported position, not a confirmed government-text proposal.
The May 2019 U.S.–Canada and U.S.–Mexico joint statements removed Section 232 duties and retaliation, ended related WTO litigation, and established monitoring and a product-specific surge-consultation process.
The 2025 measures did not follow the 2019 framework’s narrower structure. ICPA has not located a definitive instrument expressly terminating the 2019 statements; their present legal status is unresolved in the sources reviewed.
The Core Conflict
Two competing visions of North American metals trade, both grounded in official positions rather than press speculation.
USMCA-originating steel and aluminum should move tariff-free within an integrated regional market, subject to trade remedies, origin verification, and targeted anti-circumvention enforcement.
USMCA preferential origin alone does not adequately protect national security or domestic metal-production capacity from import surges, global overcapacity, third-country content, transshipment, or displacement through Canada and Mexico.
Section 232 authority rests on a separate national-security legal basis than USMCA preferential tariff commitments, so removing the tariffs does not require a treaty amendment, but it also means Canada and Mexico cannot compel removal through USMCA dispute mechanisms alone. Any durable resolution likely requires either a negotiated executive arrangement outside the treaty text, or coordinated domestic measures (melt-and-pour rules, monitoring, quotas) that satisfy U.S. economic-security objectives while preserving meaningful regional preference. The late-July record deepens this: Mexico is reportedly seeking metals relief as a precondition to broader concessions, while the U.S. layers additional pressure through Section 338 and its structural-excess-capacity Section 301 investigation.
This conflict is likely to shape whether the review produces a genuine North American metals framework or leaves Section 232 tariffs in place indefinitely, outside the treaty text, as a standing feature of the relationship.
Open Legal Issues
The customs, trade-remedy, and industrial-policy issues driving this area, distinct from the headline tariff rate. Status reflects the most recent verification pass; none is a legally effective USMCA change.
- Melt-and-pour & smelt-and-cast documentation
- Alleged transshipment through Mexico
- Alleged import displacement through Canada
- Global steel & aluminum excess capacity
- Chinese & other non-party investment in Mexico
- Metal-content valuation & product-exclusion process
- AD/CVD overlap & EAPA evasion enforcement
- Automotive steel & aluminum sourcing rules
- Section 301 structural excess-capacity investigation
- Canadian & Mexican retaliation / remission status
- Commerce implementation of the July 20 aluminum onshoring program
- Whether a steel analogue to the aluminum incentive emerges
- Interaction of the new aluminum program with Canada/Mexico adjusted-rate pathways
- Whether Section 338 pressure on Canada shifts the metals bargaining dynamic
- Whether the September round produces metals-specific text or only broad industrial-policy language
- Scope of the July 23 forced-labor Section 301 exemptions for non-USMCA metals supply chains
- Confirm country of melt-and-pour for steel inputs
- Confirm country of smelt-and-cast for aluminum inputs
- Review Chapter 99 derivative-product classifications
- Document U.S.-produced parts value for the USMCA non-U.S.-content rule, and U.S. melt/smelt records against the separate 85% metal-weight test
- Screen Canadian SKUs against the Sept. 15 modified Section 338 list and the Sept. 29 import-exclusion annexes
- Watch for Commerce implementation of the aluminum onshoring program
- Track AD/CVD and EAPA evasion exposure
- Monitor the Section 301 structural-excess-capacity investigation
Country Positions
Formal positions inferred only from official statements, not from press reporting or meeting attendance alone.
Treats Section 232 tariffs as necessary for national security, domestic capacity utilization, and protection from global overcapacity. Views USMCA origin as insufficient on its own and supports stricter regional melt-and-pour and smelt-and-cast documentation. Now pairs tariffs with an aluminum onshoring incentive and an active Section 301 structural-excess-capacity investigation.
Favors negotiated relief rather than retaliation, and has expanded import monitoring and mill-certificate requirements. Late-July reporting indicates it is pressing for reduced Section 232 auto and metals tariffs before making wider concessions. Public accounts of the July 23 round cite advances on steel, aluminum, and substitution of Asian imports, while Mexico resists solutions that preserve current metals tariffs or lock in U.S.-only content thresholds.
Economy Minister Marcelo Ebrard said Mexico is asking Washington to cut the Section 232 steel tariff on Mexican products from 50% to 10%, the preferential rate applied to the United Kingdom, arguing Mexico is the trading partner with which the U.S. runs its largest steel surplus. Mexico Business News, in its own words, describes Mexican officials as treating the 50% versus 10% gap as evidence that the current tariff structure is not calibrated to actual trade dynamics. Ebrard framed the fourth bilateral round, scheduled for September 2026 in Washington, as decisive for preserving Mexico’s standing relative to other U.S. trading partners. This is a stated negotiating position, not an agreed outcome.
Source: Mexico Business News, Jul 30 ↗ (Tier 2)
Speaking in Querétaro, Economy Secretary Marcelo Ebrard said Mexico has formally proposed that no additional tariffs be imposed while the T-MEC review talks proceed, and questioned the logic of the 50% U.S. tariff on Mexican steel given Mexico’s steel trade deficit with the United States. He again argued for preferential treatment relative to non-USMCA suppliers, and said he is preparing the agenda for the fourth bilateral round in Washington in September. This is a stated negotiating position, not a U.S. commitment; no tariff change was announced.
Source: El Financiero, Aug 14 ↗ (Tier 2)
Economy Secretary Marcelo Ebrard said Mexico is near very substantive agreements with the United States, expressly citing the Section 232 measures on steel and aluminum as well as those on vehicles. Mexico is proposing that the 50 percent steel tariff be reduced to roughly 10 percent on a UK-style basis, arguing that melt and manufacture occur in Mexico and that the United States runs a trade surplus with Mexico in the sector. The tariff reduction is a principal objective for the next round, in Washington during the first week of September. This is a Mexican official’s characterization of negotiations in progress, not an announced agreement. It stands in sharp contrast to the Canada track, which is suspended.
Source: Grupo Milenio, Aug 21 ↗ (Tier 2)
Considers Section 232 tariffs unjustified against an integrated ally and treats retaliation as its principal bargaining tool. Countertariffs on U.S. steel, aluminum, and automobiles remained in effect as of the latest official statement reviewed. The July 20 Section 338 actions did not change the metals rate (Section 232 goods are excluded) but hardened the negotiating environment; Reuters reports Canada still hopes any agreement will remove steel and aluminum tariffs and prevent the August Section 338 duties from taking effect.
Prime Minister Carney said U.S. tariffs on aluminum have driven a 58% increase in U.S. aluminum prices, arguing the burden falls on American buyers, and stated Canada is “in the middle of a tariff war with the Americans.” Canadian trade officials were in Washington the week of August 3 meeting with U.S. trade officials, ahead of the threatened imposition of 50% tariffs on additional Canadian goods beginning August 19, 2026. Steel, aluminum, and autos remain Canada’s stated priorities for sectoral tariff relief.
Source: Fortune, Aug 7 ↗ (Tier 2)
Minister Dominic LeBlanc met USTR Jamieson Greer in Washington on August 13, saying afterward that negotiations are ongoing and that Canada continues to advance its interests. The meeting came six days before the 50% Section 338 duties on roughly $20 billion of Canadian goods take effect on August 19. Sectoral Section 232 tariffs on Canadian steel and aluminum remain in place and are among the files any comprehensive arrangement would need to address. No agreement and no change to the August 19 timetable was announced.
Source: Global News, Aug 13 ↗ (Tier 2)
Government Position Matrix
Side-by-side comparison of official positions across the core issues.
| Issue | United States | Canada | Mexico |
|---|---|---|---|
| Section 232 tariffs | Necessary for security & capacity protection | Unjustified against an ally; should be removed | Should not apply to compliant trade; seeks relief |
| USMCA exemption | Origin alone viewed as insufficient | Strongly favors exemption or equivalent relief | Strongly favors preferential treatment |
| Melt & pour / smelt & cast | Supports stricter regional sourcing rules | Seeks recognition as secure supply | Expanded documentation; wary of overreach |
| Global excess capacity | Central national-security concern; active Sec. 301 | Supports action but opposes broad tariffs on Canada | Supports action; resists circumvention label |
| Retaliation | Opposes countermeasures | Principal bargaining tool | Has preferred negotiation over retaliation |
Economic Evidence
USITC modeled estimates of the 2018–2021 Section 232 tariffs, plus current production data. Modeled estimates are not observed outcomes for the 2025–2026 measures.
| Estimated outcome | USITC estimate |
|---|---|
| Covered steel imports | −24% |
| Covered aluminum imports | −31.1% |
| U.S. steel production | +1.9% |
| U.S. aluminum production | +3.6% |
| Domestic steel price (Sec. 232 + 301 sensitivity model) | +0.95% |
| Domestic steel output (Sec. 232 + 301 sensitivity model) | +2.38% |
| Covered non-Chinese steel imports (sensitivity model) | −26.39% |
Source: USITC Publication 5405 (2023) and worldsteel June 2026 production data. USITC figures reflect the 2018–2021 tariff period and related modeling; the magnitude of the 2025–2026 measures cannot safely be inferred by mechanically scaling these results, given different rates, scope, derivative coverage, exemptions, and macroeconomic conditions. The OECD Steel Outlook 2026 projects excess capacity rising further, with most of the global capacity-demand gap in China, which helps explain why anti-circumvention and non-party free-riding keep reappearing in the talks.
Timeline & Key Developments
Extended to entry into force. Distinguishes tariff, retaliation, negotiation, and enforcement events.
Commerce’s Bureau of Industry and Security published a Federal Register notice (Doc. 2026-15961, released August 4, published August 6) requesting public comment on a proposal to extend Section 232 duties to 14 additional derivative articles, including aluminum powder, certain electric conductor cables, heat exchanger parts, cranes and lifting equipment, certain trailers and semi-trailers, and filled steel containers for propane, oxygen, or propylene. Most items would face a 25% rate, with some subject to different rates under existing proclamations. BIS seeks input on metal content, import volumes, domestic capacity, and economic impact; comments must be received by August 27, 2026.
Source: Federal Register 2026-15961 ↗ (Tier 1)
Research Gaps & Open Issues
Reviewed and updated with each page verification pass.
- No comprehensive public trilateral metals settlement located through the July 1, 2026 joint review
- No definitive instrument located expressly terminating or superseding the 2019 U.S.–Canada and U.S.–Mexico joint statements
- Commerce has not yet published full application procedures, approval criteria, or an HTSUS implementation notice for the July 20 primary-aluminum onshoring program
- No public government text located describing a parallel late-July Section 232 investment program for steel
- No publicly released U.S.–Mexico negotiating text located for any new steel or aluminum side arrangement following the July 23 round
- No publicly agreed numerical thresholds for any new Canadian or Mexican steel or aluminum quota
- No final trilateral definition of qualifying North American steel or aluminum for Section 232 relief
- Final scope of product exemptions under the July 23 forced-labor Section 301 action, and interaction with non-USMCA metals supply chains, requires closer review once operative annexes are mapped
- Final U.S. Section 301 action against Mexico concerning structural excess capacity not yet resolved
- No definitive public Mexican retaliation list comparable to Canada’s response
Source Library
Full member library, all topics →Related Topics
ICPA’s trade law partners can help members navigate Section 232 exposure, derivative-product classification, melt-and-pour documentation, and metal-content valuation as this topic develops.
About this tracker
The USMCA Joint Review Tracker is published by the International Compliance Professionals Association (ICPA). It follows the 2026 USMCA joint review under Article 34.7: negotiating rounds, government positions, legal status, tariff and customs actions, and what each change means for importers and exporters. It is a policy and compliance tracker, not a trade-flow data dashboard.
Updated weekly and when a significant development breaks. It covers automotive, agriculture, labor, digital trade, de minimis, steel and aluminum, economic security and rules of origin, and it is built on primary sources from USTR, CBP, the White House, the Federal Register and the governments of Canada and Mexico, with every item marked as confirmed or reported.
This tracker is researched and maintained by Heather Tschirhart, who leads ICPA’s trade research and data work.
Spot something inaccurate, know of a development, article, or video that should be added, or notice something not working? Reach out any time.
Contact HeatherInternational Compliance Professionals Association (ICPA), USMCA Joint Review Tracker: Steel & Aluminum, researched and maintained by Heather Tschirhart, updated weekly, https://www.icpainc.org/usmca-joint-review-steel-aluminum/