US Widens Content Rule for Canadian and Mexican Metal Goods

United States customs now counts US-made parts and US-made steel, aluminum and copper as tax-free US content from Oct. 14, 2026.

The US Commerce Department told customs on Oct. 14, 2026 how to count American parts and metal in Canadian and Mexican goods facing metal tariffs¹.

The Bureau of Industry and Security (BIS), part of the Department of Commerce, published the guidance as a notice in the Federal Register. It applies to goods entered on or after 12:01 a.m. Eastern Time on Oct. 14, 2026¹.

In short, a Canadian or Mexican product can now count more of its value as "U.S. content", which pays no 25% metal tariff. Parts made, grown or substantially changed in the United States count, and so does steel, aluminum or copper first produced there¹.

What does the Commerce notice on U.S. content say?

The notice gives U.S. Customs and Border Protection (CBP), the US border and customs agency, a definition of "U.S. content"¹. This definition matters because the 25% tariff falls only on the part of the product that is not U.S. content.

Under the notice, "U.S. content" means two things¹:

• Parts made in the United States: the value of parts that were wholly obtained, entirely produced, or substantially transformed in the United States.
• US-made metal: to the extent not already counted as a part, the value of steel melted and poured in the United States, and of aluminum or copper smelted and cast there.

The second item is new. A product may hold US steel that was not part of a finished US component. That metal value can now count as U.S. content too¹.

The notice is one page long. It says questions about a specific product should go to CBP¹.

Which goods from Canada and Mexico are covered?

The guidance serves one clause of a presidential order, Proclamation 11032 of June 1, 2026². That order adjusted the tariffs on aluminum, steel and copper that the United States imposes under Section 232, a national security trade law.

Clause (2)(d) of the proclamation covers products of Canada and Mexico that qualify for preferential treatment under the United States–Mexico–Canada Agreement (USMCA), the North American trade deal². It applies to the aluminum and steel goods listed in the proclamation’s Annex I-C².

A CBP message to the trade dated June 5, 2026 explains which entries use this treatment. It ties the Canada and Mexico rule to steel derivative goods in subdivision (c)(xi) of the tariff schedule’s note 16³. In the same message, CBP describes subdivision (c)(xi) as mobile industrial equipment³.

The proclamation explains why these machines got lower tariffs. It says construction equipment is essential for rebuilding US industry, and material-handling equipment keeps factories and warehouses working².

CBP’s June message lists the tariff codes that received reduced duty rates. They include forklifts and other lifting trucks (heading 8427), bulldozers, graders and excavators (heading 8429), and tractors (heading 8701)³.

How is the 25% duty on the non-US part worked out?

Under the proclamation, a 25% duty applies only to the non-U.S. content of a qualifying Canadian or Mexican product². The non-U.S. content is the total value of the product minus the value of its U.S. content.

There is a floor. The total effective duty on the imported product cannot be less than 15% of its value². So even a product with a lot of American content still pays at least 15%.

CBP’s June message adds a second limit at the border. Importers may report U.S. content at a zero rate only up to 40% of the entered value of the goods³. Any U.S. content above 40% goes on the first line and pays the 25% rate³.

A simple example shows the effect. Take a machine with an entered value of $100,000, of which $40,000 is U.S. content. The importer pays 25% on $60,000, or $15,000. That equals 15% of the full value, the floor the proclamation sets.

How do importers report U.S. content on the entry?

CBP’s June message sets out how importers and customs brokers declare these goods³. The importer splits one product into two lines on the entry summary.

The steps are:

1. On the first line, report the full quantity and the value of the non-U.S. content, under heading 9903.82.20 at 25% additional duty³.
2. On the second line, report a quantity of zero and the value of the U.S. content, up to 40% of the total, under heading 9903.82.21 at 0% additional duty³.
3. On both lines, report the same tariff code from chapters 1 to 97, the same country of origin (Canada or Mexico), and program code "S" for USMCA³.
4. On both lines, report any other duties that apply, such as anti-dumping duties³.

The Commerce notice does not change these lines. It changes what value an importer may put on the second line. More US-made metal can now count toward it¹.

Why did Commerce issue the guidance now?

The proclamation itself ordered it. Clause (2)(d) says the Secretary of Commerce shall issue guidance to CBP on how to assess "U.S. content"². The Secretary passed this task to the Deputy Assistant Secretary for Technology Security, who signed the notice¹.

The proclamation first defined non-U.S. content in a narrow way. It said the value of "parts produced in the United States" is subtracted from the total value². CBP’s June message used the same wording³.

The Commerce notice widens this. It brings in parts substantially transformed in the United States and US-melted or US-smelted metal¹. This fits the stated aim of the proclamation, which was to encourage more use of American aluminum, steel and copper in finished products².

What penalties apply for false claims?

The proclamation warns importers about overstating U.S. content. If CBP finds that an importer committed fraud or deliberately misled the US government about U.S. content, CBP shall impose penalties to the extent the law allows².

This puts the burden on the importer. A larger U.S. content claim cuts the duty owed. It also needs records of where parts were made and where the metal was melted or smelted.

CBP already asks importers to report where steel was melted and poured and where aluminum was smelted and cast³. Its June message said it would announce later when importers must also report where copper was smelted and cast³.

How does this fit the wider Section 232 metal tariffs?

The United States first imposed these tariffs in 2018 on aluminum and steel, and in 2025 on copper². In April 2026, Proclamation 11021 set a 50% duty on products made of these metals and 25% on many derivative products². Derivative products are goods made mostly from these metals.

Proclamation 11032 then made several changes from June 8, 2026²:

• Lower rates for machinery: farm equipment and some home heating and air-conditioning systems moved to a 15% rate, and mobile industrial equipment got a temporary rate.
• New products covered: aluminum printing plates and steel racks became subject to the derivative tariff.
• US metal threshold: a product now counts as made "entirely" from American metal if US metal is at least 85% of its metal weight, down from 95%.

Products of some partners, such as Japan, Korea, the United Kingdom and the European Union, pay a combined 15% on the Annex I-C goods when their normal duty is below 15%². Goods whose steel or aluminum is made entirely from US metal get a 10% rate². When more than one rate applies, the lowest rate applies².

When do the rules start and end?

The new definition of U.S. content applies to goods entered, or withdrawn from a warehouse, on or after 12:01 a.m. Eastern Time on Oct. 14, 2026¹. Entries made before that time used the narrower wording of the June proclamation.

The reduced rates under clause (2) of the proclamation run until 11:59 p.m. on Dec. 31, 2027². From Jan. 1, 2028, the Annex I-C goods return to the rates in Proclamation 11021². CBP said it would issue more guidance before Jan. 1, 2028³.

Commerce and the US Trade Representative continue to watch metal imports. They must tell the President if further action is needed, or if any tariff is no longer necessary².

Key points on the U.S. content guidance

The table sums up the Commerce notice and the rules it serves.

From Oct. 14, 2026, Canadian and Mexican makers that use American steel, aluminum or copper can count that metal as U.S. content. Their US buyers can pay less duty, down to the 15% floor, until the reduced rates end on Dec. 31, 2027.

Sources

1. ↩ Federal Register :: Guidance to U.S. Customs and Border Protection Regarding the Assessment of “U.S. Content” for Purposes of Implementing Tariffs Pursuant to Clause (2)(D) of Proclamation 11032 of June 1, 2026 https://www.federalregister.gov/documents/2026/10/14/2026-20938/guidance-to-us-customs-and-border-protection-regarding-the-assessment-of-us-content-for-purposes-of
2. ↩ Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper into the United States – The White House https://www.whitehouse.gov/presidential-actions/2026/06/further-adjusting-the-tariff-regimes-for-imports-of-aluminum-steel-and-copper-into-the-united-states/
3. ↩ CSMS # 68855869 – GUIDANCE: Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States https://content.govdelivery.com/accounts/USDHSCBP/bulletins/41aa83d