Section 232 Tariffs: The Amazon FBA Seller's Action Guide
If you source metal-containing products from China and sell on Amazon, your landed cost model is outdated as of April 6, 2026. A Presidential Proclamation signed April 2 restructured how Section 232 tariffs are calculated on steel, aluminum, and copper imports shifting from a metal-content basis to a full declared-value basis. For many FBA sellers, that one change doubles the Section 232 duty bill overnight.
This guide gives you the actual numbers, the four-tier product classification system, a step-by-step check for your own HTS codes, and a realistic picture of what your duty stack looks like going forward.
What Changed on April 6 and Why It Hits FBA Sellers Hard
Section 232 of the Trade Expansion Act of 1962 lets the President impose tariffs on imports deemed a national security risk. The program has covered steel and aluminum since 2018. What changed this year is not the program itself. It is the math.
Under the old rules, Section 232 duties on derivative products were calculated on the estimated value of the metal embedded in the product. A shelf bracket that cost $10 to import but contained only $3 worth of steel was taxed on $3. Under the new rules, the duty applies to the full $10 customs value. That gap between metal content and full product value is where most of the additional cost lives for FBA sellers importing finished goods.
The rules took effect at 12:01 a.m. EDT on April 6, 2026. There is no in-transit exemption. U.S. Customs and Border Protection confirmed in CSMS #68253075 that any goods entering consumption or withdrawn from a bonded warehouse on or after that date and time are subject to the new rates, regardless of when they shipped from China. The full legal text is published in the Presidential Proclamation on the White House website.
The Four-Annex System: Finding Your Rate
The proclamation divides affected products into four annexes. Your annex determines your Section 232 rate. Getting this wrong at customs either overpaying or underpaying creates problems in both directions.
Annex I-A: 50% Full-Value Tariff
Base metals and their close derivatives. If your product is classified in HS Chapters 72 (steel), 73 (steel articles), 74 (copper), or 76 (aluminum), you are almost certainly here. This annex covers steel coils, aluminum sheet, copper rod, stainless cookware, steel hardware, and similar products made primarily from a single metal.
Annex I-B: 25% Full-Value Tariff
Downstream manufactured goods where metal is the primary structural material but the product has been substantially processed aluminum frame LED fixtures, steel-chassis shelving units, copper-wound motors. The rate is lower than Annex I-A, but it is still applied to the full declared value of the shipment.
Annex II: Exempt
Roughly 247 HTS codes have been removed from Section 232 scope entirely. If your code appears on Annex II, you owe no additional Section 232 duty under this proclamation. The complete list is available in the official Annexes I-A through IV published by the White House. Check before assuming you are affected.
Annex III: Industrial and Grid Equipment (Transition)
Certain power generation, transmission, and heavy industrial equipment gets a softer landing. Through December 31, 2027, the combined duty rate MFN base plus Section 232 is capped at 15%. If a product already carries a base duty above 15%, no additional Section 232 is charged. Starting January 1, 2028, these products move to the standard 25% rate.
The 15% Metal Content Rule
For any product not classified in Chapters 72, 73, 74, or 76, Section 232 only applies if steel, aluminum, or copper makes up at least 15% of the product's total weight. Customs has the authority to request a third-party material composition analysis to verify this. If you import products in this borderline category, ask your factory for a certified materials report before your next shipment clears.
Section 232 Rates by Country of Origin
| Country of Origin | Annex I-A | Annex I-B |
|---|---|---|
| China (standard FBA source) | 50% | 25% |
| United Kingdom | 25% | 15% |
| Made with 100% U.S.-origin metal | 10% | 10% |
| Russia / Belarus | 200% | 200% |
Is Your Product in Scope? A 3-Step Check
Before you recalculate a single landed cost, confirm whether your product actually falls under these new rules. A lot of FBA sellers are paying unnecessary attention to tariffs that do not apply to their catalog.
- Pull your 10-digit HTS code. Use the U.S. Census Bureau Schedule B Search Tool or CBP's ACE portal. Do not rely on the code your supplier used on previous commercial invoices verify it yourself or through your customs broker.
- Match it to the Annex files. Download the White House Annexes PDF and search your HTS code across Annex I-A, I-B, and II. This takes about five minutes and tells you definitively whether you have a 50%, 25%, or 0% Section 232 exposure.
- Run the 15% weight test if needed. If your product is outside Chapters 72-76, have your supplier provide a bill of materials showing metal content by weight. If it comes in below 15%, you are outside Section 232 scope entirely.
FBA Product Categories Most Likely to Be Affected
- Hand tools: wrenches, ratchets, socket sets, pliers, drill bits
- Kitchen: cast iron cookware, stainless steel pots and pan sets, knife blocks
- Home: metal shelving, wire storage racks, steel wall brackets, aluminum picture frames
- Lighting: aluminum-frame LED floor lamps, ceiling fixtures, track lighting
- Electronics accessories: copper USB cables, connectors, heat sinks
- Automotive: steel and aluminum trim pieces, mounting hardware, roof racks
Special note for copper product sellers: Clause 20 of the proclamation authorizes CBP to require importers of copper and copper-derivative products to provide third-party documentation verifying the country of smelting and casting. Coordinate with your supplier now do not wait until your shipment is flagged at the port.
The Actual Numbers: How Much More Are You Paying?
For a China-origin Annex I-A product, your duty stack now looks like this:
- MFN base rate: ~5% (varies by HTS code)
- Section 301 tariff: 25%
- Section 232 tariff: 50%
- Total: approximately 80% of customs value
For Annex I-B products from China the total is closer to 55% (5% MFN + 25% Section 301 + 25% Section 232). Neither number is what most sellers budgeted for at the start of the year.
The bigger issue is the shift from metal-content to full-value assessment. Here is what that looks like across three common FBA products:
| Product | Customs Value | 232 Duty (Old Method) | 232 Duty (New Method) | Extra Cost |
|---|---|---|---|---|
| Stainless steel cookware set (60% metal content) | $5,000 | 50% x $3,000 = $1,500 | 50% x $5,000 = $2,500 | +$1,000 |
| Aluminum LED floor lamp (45% metal content) | $8,000 | 25% x $3,600 = $900 | 25% x $8,000 = $2,000 | +$1,100 |
| Copper cable set (30% metal content) | $3,000 | 25% x $900 = $225 | 25% x $3,000 = $750 | +$525 |
Two Workarounds That No Longer Apply
Foreign Trade Zones: Clause 12 of the proclamation closes the FTZ deferral strategy. Any goods entering a U.S. FTZ on or after April 6 must be admitted under Privileged Foreign Status, meaning the Section 232 duty is assessed at the time of entry into the zone not when goods leave it. There is no longer a timing advantage.
Duty Drawback: Clause 14 explicitly eliminates drawback eligibility for Section 232 duties under this order, except for qualifying trade agreement partners. China is not one of those partners. If someone tells you that you can recover Section 232 duties on China-origin goods through drawback, they are wrong. For an independent legal review of these provisions, see the analysis published by Torres Trade Law on April 8, 2026.
What to Look for in an FBA Freight Forwarder Right Now
The freight forwarder conversations that mattered six months ago were about transit times and container rates. Today, the more important conversation is about duty classification and all-in pricing transparency. Here is what that means in practice.
- DDP quoting capability. Your forwarder should be able to give you a single confirmed number that covers ocean freight, U.S. customs clearance, all applicable import duties, and final-mile delivery to your Amazon fulfillment center. If they can only quote to the port, you are carrying the duty uncertainty yourself.
- Annex classification experience. A good forwarder in 2026 can look at your HTS code and tell you whether you are Annex I-A, I-B, or II without needing to call a lawyer. This is now baseline freight forwarding competency for metal goods from China.
- Amazon SPN certification. Required for smooth FBA inbound processing covers labeling standards, carton specs, and delivery appointment scheduling at Amazon warehouses.
- Copper documentation support. If your catalog includes copper products, confirm your forwarder can help coordinate the smelting and casting origin certificates that CBP may request under Clause 20.
- No CIF-only pricing. A quote that stops at the port will underestimate your real landed cost by 40-55% on Annex I-A goods from China. Insist on DDP pricing before committing to any shipment.
At Zbao, our LCL DDP service quotes you a single all-in rate before your cargo ships. That rate covers ocean freight from China, U.S. customs clearance, Section 301 and Section 232 duties, and last-mile delivery to your FBA fulfillment center. No port-arrival surprises.
Current all-in DDP rates (all duties included):
- US West Coast (Los Angeles): $1/kg
- US Central (Savannah): $1.1/kg
- US East Coast (New York): $1.2/kg
Section 232 FAQ
Do Section 232 and Section 301 tariffs stack for products from China?
Yes, fully. Both programs apply simultaneously, and there is no mechanism to offset one against the other. For an Annex I-A product from China you are looking at 50% Section 232 plus 25% Section 301 plus whatever MFN base rate applies to your HTS code. The combined burden for most common FBA metal goods now sits between 75% and 80% of customs value.
How do I know if my product is on the Annex II exemption list?
Download the Annexes PDF from the White House and search your 10-digit HTS code across the document. If your code appears in Annex II, no Section 232 duty applies. This check takes about five minutes and can save you significant duty costs if you have been assuming the worst.
Is there an in-transit exemption for cargo already on the water?
No. CBP's CSMS #68253075 is clear: the effective date is April 6, 2026 at 12:01 a.m. EDT, and it applies to all goods entering consumption or leaving a bonded warehouse after that moment regardless of when they were loaded onto the vessel.
Can I use an FTZ to delay paying these tariffs?
No. Clause 12 eliminated this option. Goods entering an FTZ from April 6 onward must be admitted under Privileged Foreign Status, which locks in the Section 232 duty at entry. The deferral benefit is gone.
Can I get a duty drawback refund on Section 232 tariffs paid on China-origin goods?
No. Clause 14 of the proclamation eliminates drawback eligibility for Section 232 duties imposed under this order, except for qualifying trade agreement partners. China does not qualify. There is no refund path for Chinese-origin FBA shipments under this program.
Send us your HTS code and we will confirm your Annex classification, calculate your full duty stack, and send back a confirmed all-in DDP rate within 24 hours.
