By the Digital Empire Regulatory Research Team (TariffWatch Analysis Team) · Reviewed by Andy Gaber, Founder, Digital Empire Holdings LLC · Published August 29, 2026 · Last updated August 29, 2026
Aluminum entering the U.S. in 2026 can carry up to five stacked duty regimes at once: the base MFN Column 1 tariff from HTS Chapter 76, a Section 232 national-security duty at 10 percent that may soon extend to 14 new derivative articles under Federal Register notice 2026-15961, antidumping duties on Chinese extrusions and foil and common alloy sheet, countervailing duties running alongside those AD orders, and Section 301 duties on China-origin goods where the HTS code sits on Lists 1 through 4a. The stack is administered by different agencies (CBP, BIS, ITA, USTR), on different timelines, with different paperwork, and none of them talk to each other automatically. This guide walks each regime end to end, maps HTS Chapter 76 subheading by subheading, and shows where TariffWatch sits inside the monitoring workflow.
1. Column 1 MFN tariff (HTS Chapter 76). The base ad valorem rate from the Harmonized Tariff Schedule of the United States. For aluminum this ranges from free (unwrought aluminum in 7601 for eligible origins) to 6.5 percent (certain finished articles in 7616), by 10-digit subheading. Administered by CBP at entry, published by USITC in the online HTS.
2. Section 232 national-security duty. Currently 10 percent on primary aluminum and on covered derivative articles, imposed under 19 USC 1862 and the underlying Proclamation 9704 of March 8, 2018, and subsequent modifications. The pending FR 2026-15961 proposal would add 14 more derivative-article definitions. Administered by BIS at Commerce, collected by CBP at entry against the Section 232 HTSUS Chapter 99 subheadings.
3. Antidumping duty (AD). Rates set case-by-case by the ITA (International Trade Administration) at Commerce under 19 USC 1673 for imports sold at less than fair value. Active AD orders on aluminum include Chinese aluminum extrusions, aluminum foil from China (with additional AD orders on foil from other origins added in later investigations), and common alloy aluminum sheet from China. Rates are producer-specific in the original investigation and updated in annual administrative reviews; the "China-wide" rate for non-participating producers is typically materially higher than the individual-respondent rate.
4. Countervailing duty (CVD). Rates set case-by-case by the ITA under 19 USC 1671 for imports that benefit from countervailable foreign-government subsidies. Where the ITA finds both dumping and a countervailable subsidy on the same import, both AD and CVD orders issue on the same product and both apply. For Chinese aluminum extrusions, foil, and sheet, CVD orders run alongside the AD orders.
5. Section 301 duty. Additional ad valorem duty imposed by the USTR under 19 USC 2411 on China-origin goods where the HTS code appears on Lists 1, 2, 3, or 4a of the Section 301 action list. Rates range from 7.5 to 25 percent depending on the list. Section 301 stacks additively on top of Section 232 and MFN in the final duty math when the goods are China-origin and the HTS code is listed. Administered by USTR, collected by CBP at entry.
Section 232 of the Trade Expansion Act of 1962, codified at 19 USC 1862, authorizes the President to impose import restrictions on any article the Commerce Department finds threatens national security. The Commerce Section 232 investigation on aluminum concluded in January 2018 that aluminum-import volumes threatened U.S. national-security industrial capacity, and Proclamation 9704 (March 8, 2018) imposed a 10 percent tariff on aluminum imports effective March 23, 2018.
The Section 232 aluminum regime has been modified repeatedly since 2018: country-specific exemptions (Canada, Mexico, Australia, the EU, the UK, Japan, and others at various points), tariff-rate quota (TRQ) replacements for some of those exemptions, quota-plus-tariff hybrids for others, and periodic reinstatement and reversal cycles tied to bilateral negotiations. The current baseline as of August 2026 is 10 percent on aluminum imports outside of the country-specific carve-outs, applied at the Chapter 99 HTSUS subheadings established for Section 232 rather than embedded in Chapter 76 directly.
The pending expansion is the derivative-article proposal at Federal Register notice 2026-15961, published 2026-08-06, comment window closing 2026-08-27. That notice proposes 14 new derivative-article definitions that would extend the Section 232 aluminum duty from raw aluminum ingots, slabs, and standard semi-fabricated forms into specific finished aluminum-content products. The exact 14 definitions and the specific 10-digit HTS codes they would touch are the subject matter of the derivative-articles reference page and the HTS-checker tool.
Exclusion requests under Section 232 are filed with BIS under 15 CFR Part 705 supplements. The exclusion-request process is a specialized customs-law engagement typically handled by a trade attorney or an experienced customs broker; the paperwork is submitted to BIS through its 232 exclusions portal on regulations.gov and typically involves a detailed showing that the specific HTS code and product application either does not have a U.S. domestic supplier at the required quality, quantity, or timeline, or is otherwise appropriate for exclusion on national-security-neutral grounds. TariffWatch does not file exclusion requests; it drafts the exposure analysis and the inclusion-rebuttal or comment-letter template that the trade attorney or broker would review and submit.
The ITA (International Trade Administration) at Commerce administers antidumping and countervailing duty investigations and orders under 19 USC 1673 et seq. and 19 USC 1671 et seq. respectively. Active AD/CVD orders on aluminum, as of August 2026, include:
Aluminum Extrusions from the People's Republic of China. Original AD order effective 2011 (Case A-570-967); companion CVD order in effect since 2011 (C-570-968). Rates are producer-specific and updated in annual administrative reviews. The scope was expanded significantly through the Aluminum Association-led 2023 investigation covering 15 additional countries, with final AD/CVD orders on multiple new origins issued in 2024 following that investigation.
Aluminum Foil from the People's Republic of China. Original AD order effective 2018 (A-570-053); companion CVD order (C-570-054). Rates are updated in administrative reviews. Additional aluminum-foil AD orders were subsequently issued against foil originating from Armenia, Brazil, Oman, Russia, and Turkey following the 2020-2021 investigations.
Common Alloy Aluminum Sheet from the People's Republic of China. Original AD order effective 2019 (A-570-073); companion CVD order (C-570-074). The 2020-2021 "common alloy sheet 18-country" investigation extended AD/CVD orders to 18 additional origins.
AD/CVD rates are set producer-by-producer. The rate a specific importer's specific supplier receives depends on whether that supplier participated in the ITA investigation (individually-reviewed rate), whether the supplier was assigned an "all-others" rate for participating non-respondents, or whether the supplier defaults to the "China-wide" rate (which is typically materially higher, often 100 percent or more). Anyone importing from a Chinese supplier not on the individually-reviewed list should assume the China-wide rate applies until a scope inquiry or a supplier certification proves otherwise. The current AD/CVD order text is at ITA ACCESS, the primary system of record for AD/CVD proceedings.
Section 301 of the Trade Act of 1974, codified at 19 USC 2411, authorizes the USTR to impose duties in response to a finding that a foreign government's policy or practice is unreasonable or discriminatory and burdens U.S. commerce. The 2018 China Section 301 action grew to four lists (Lists 1, 2, 3, and 4a) covering the majority of China-origin imports, with duty rates from 7.5 to 25 percent depending on the list. Several aluminum-content HTS codes appear on Lists 3 and 4a. USTR-published exclusions have been renewed and expired on rolling cycles since 2018; the current active-exclusion set is published on the USTR Section 301 page.
For an aluminum importer, the practical Section 301 question is: for each of my SKUs, is the country of origin China, and if yes, is the 10-digit HTS code on List 1, 2, 3, or 4a, and is there an active exclusion that covers my specific product application? The stacked duty math for a China-origin aluminum article on a listed HTS code with no active exclusion is: Column 1 MFN + Section 232 (if the code is on the Section 232 list) + Section 301 (7.5 to 25 percent depending on list) + AD (if an AD order covers the specific origin and scope) + CVD (if a CVD order covers the specific origin and scope). Four or five regimes stacked on the entered value is not unusual for a China-origin aluminum extrusion or foil.
The Harmonized Tariff Schedule Chapter 76 (Aluminum and Articles Thereof) is the classification anchor for every aluminum-import duty determination. The 4-digit subheading map:
7601 Aluminum, unwrought. Primary aluminum ingots, slabs, billets, and other unwrought forms. Split at 6-digit into 7601.10 (not alloyed) and 7601.20 (alloyed). Historically the anchor code for Section 232 base coverage.
7602 Aluminum waste and scrap. Post-consumer and post-industrial aluminum scrap. Column 1 MFN duty-free.
7603 Aluminum powders and flakes. Split at 6-digit into 7603.10 (non-lamellar structure powders) and 7603.20 (lamellar powders and flakes).
7604 Aluminum bars, rods, and profiles. Includes hollow profiles at 7604.10.10 and solid profiles at 7604.10.30 and higher. This is where a large share of the AD order on Chinese aluminum extrusions applies at the 10-digit level.
7605 Aluminum wire. Split at 6-digit into 7605.11, 7605.19 (not alloyed), 7605.21, 7605.29 (alloyed) by cross-sectional dimension.
7606 Aluminum plates, sheets, and strip, thickness > 0.2 mm. The common alloy sheet AD/CVD order landing zone. Split at 6-digit into 7606.11, 7606.12 (rectangular) and 7606.91, 7606.92 (other).
7607 Aluminum foil, thickness ≤ 0.2 mm. The aluminum foil AD/CVD order landing zone. Split at 6-digit into 7607.11 (not backed, rolled but not further worked), 7607.19 (not backed, other), and 7607.20 (backed).
7608 Aluminum tubes and pipes. Split at 6-digit into 7608.10 (not alloyed) and 7608.20 (alloyed).
7609 Aluminum tube or pipe fittings. Couplings, elbows, sleeves, and similar fittings.
7610 Aluminum structures and structure parts. Bridges, towers, columns, roofs, roofing frameworks, doors, windows, and frames. Split into 7610.10 (doors, windows, frames) and 7610.90 (other).
7611 Aluminum reservoirs, tanks, vats, and containers > 300 L. Large-capacity aluminum containers.
7612 Aluminum casks, drums, cans, and containers ≤ 300 L. Split into 7612.10 (collapsible tubular containers) and 7612.90 (other).
7613 Aluminum containers for compressed or liquefied gas. High-pressure aluminum cylinders.
7614 Aluminum stranded wire, cables, plaited bands. Not electrically insulated. Split into 7614.10 (with steel core) and 7614.90 (other).
7615 Aluminum table, kitchen, and household articles. Cookware, sanitary ware, pot scourers. Split into 7615.10 (table, kitchen, household), 7615.20 (sanitary ware).
7616 Other aluminum articles. The residual catch-all. Split into 7616.10 (nails, tacks, staples, screws, bolts, nuts, similar articles), 7616.91 (cloth, grill, netting, fencing of aluminum wire), and 7616.99 (other). The 7616.99 residual is where several of the FR 2026-15961 proposed derivative articles land at the 10-digit level.
The full current text with 10-digit codes, statistical suffixes, and Column 1 rates is at hts.usitc.gov/current. USITC updates the HTS periodically in response to Presidential proclamations and Section 301 actions.
The stacked-duty math on aluminum turns on the country of origin, and the country-of-origin determination for a finished aluminum article is a substantial-transformation question under 19 CFR Part 134. An aluminum ingot smelted in Country A, rolled into sheet in Country B, and stamped into a finished article in Country C is generally the origin of the country where the last substantial transformation occurred, but the specific test varies by article and by trade regime. For Section 232, the origin analysis governs which country-specific exemption or TRQ applies. For AD/CVD, the origin analysis governs whether a specific ITA order covers the shipment. For Section 301, the origin analysis governs whether the China-origin surtax applies. These three origin analyses are not always identical, which is why an importer's customs broker or trade attorney is the appropriate resource for a specific origin call.
TariffWatch is built specifically around the Section 232 aluminum-and-steel derivative-article regime and the FR 2026-15961 public-comment workflow. Its exposure checker at /tariffwatch/hts-checker reads a 10-digit HTS code and returns whether the code falls within one of the 14 proposed derivative-article definitions, what the potential Section 232 duty exposure is, and which of the 14 comment-letter or inclusion-rebuttal templates applies. Its watchlist at /tariffwatch/watchlist ($29/month) notifies when an HTS code the importer is watching moves into or out of a final BIS inclusion after the comment window closes on 2026-08-27.
TariffWatch is not a general AD/CVD scope-inquiry tool, does not track Section 301 exclusion renewals, and is not a substitute for a customs broker or trade attorney monitoring the AD/CVD and Section 301 regimes for the same importer. Those adjacencies are on the roadmap. Anyone importing aluminum in scope of an active AD/CVD order on their specific origin should be monitoring the ITA ACCESS docket for their case (e.g. A-570-967 for Chinese aluminum extrusions), and anyone importing China-origin aluminum should be monitoring the USTR Section 301 exclusion cycle for their specific HTS code.
This is a hypothetical scenario, not a real customer case. Consider an importer bringing in Chinese aluminum extrusions classified at HTS 7604.29.5090 for a mid-size construction contractor client. The stacked duty at entry for this hypothetical shipment: Column 1 MFN 5.0 percent + Section 232 10 percent + Section 301 List 3 25 percent + AD order A-570-967 at the applicable producer rate + CVD order C-570-968 at the applicable subsidy rate. That is five regimes on the same entered value. If FR 2026-15961 extends the Section 232 derivative-article coverage to a downstream finished-extrusion category that touches the importer's specific product application, a sixth regime enters the stack after the 2026-08-27 comment window closes and the final BIS inclusion publishes. TariffWatch covers the Section 232 exposure and the FR 2026-15961 inclusion-rebuttal drafting piece of that stack. The AD/CVD and Section 301 pieces are the broker's and trade attorney's beats.
TariffWatch is a data and workflow tool that estimates Section 232 tariff exposure from publicly available Federal Register, USITC, and CBP data. TariffWatch is NOT a licensed customs broker under 19 CFR 111, NOT a filer of record, and NOT a legal-advice service. This is not customs classification advice. Compliance decisions remain the responsibility of the importer and their customs broker or trade attorney. TariffWatch does not guarantee that any classification, exposure estimate, or comment letter will be accepted by CBP, BIS, or Commerce.
TariffWatch is not affiliated with the U.S. Department of Commerce, the Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP), or the U.S. International Trade Commission (USITC).
As of August 2026, aluminum imports into the U.S. can carry up to five stacked duty regimes at once: (1) the Column 1 MFN tariff from HTS Chapter 76, generally 0-6.5 percent by subheading; (2) Section 232 national-security duties on primary aluminum and covered derivative articles, currently 10 percent, subject to expansion under the pending FR 2026-15961 proposal; (3) antidumping duties on specific alloys and articles from specific countries (China principally, but also aluminum foil from several other origins), rates set case-by-case by the ITA; (4) countervailing duties running alongside the AD orders where the subsidy finding supports one; and (5) Section 301 duties on China-origin goods where the HTS code appears on List 1, 2, 3, or 4a. The stack is order-agnostic in the final duty math but very order-specific in the paperwork.
Section 232 refers to Section 232 of the Trade Expansion Act of 1962, codified at 19 USC 1862, which authorizes the President to impose import restrictions in response to a Commerce Department finding that specific imports threaten national security. Proclamation 9704 (March 8, 2018) imposed a 10 percent tariff on aluminum imports based on a Commerce Section 232 investigation concluding that aluminum-import volumes threatened U.S. national-security industrial capacity. Multiple subsequent proclamations expanded, modified, and country-specifically excluded portions of the regime; the current baseline is 10 percent on primary aluminum and on covered derivative articles, with country-specific carve-outs that have shifted repeatedly.
A derivative article is a downstream product made partially or wholly from aluminum that the Bureau of Industry and Security determines should be included in the Section 232 regime to prevent circumvention. Federal Register notice 2026-15961, published 2026-08-06, proposes 14 new derivative articles that would extend the Section 232 duty from raw aluminum ingots and slabs into specific finished aluminum-content products. The public comment window on that proposal closes 2026-08-27. Anyone importing an aluminum-content article that could reasonably fall within one of the 14 proposed definitions is affected by that comment window regardless of whether the specific HTS code is currently on the Section 232 list.
Antidumping duties compensate for imports sold at "less than fair value" (below the price the same good sells for in the exporting country, or below the exporter cost of production). The ITA (International Trade Administration) at Commerce administers AD investigations under 19 USC 1673 et seq. Active AD orders on aluminum include Chinese aluminum extrusions (order in effect since 2011), aluminum foil from China (2018), common alloy aluminum sheet from China (2019), and aluminum wire and cable from multiple origins. AD rates are set producer-by-producer in the original investigation and updated in annual administrative reviews; a "China-wide" rate covers producers that did not participate in the investigation and is typically much higher (often 100 percent or more).
Countervailing duties compensate for imports that benefit from a foreign-government subsidy the ITA finds to be countervailable. When a subsidy finding supports a CVD order, the CVD runs in parallel with the AD order on the same product. For Chinese aluminum extrusions, aluminum foil, and common alloy sheet, both AD and CVD orders are in effect and both apply to a covered import. The CVD rate is separate from the AD rate; the two stack additively on the entered value in the final duty calculation.
HTS Chapter 76 (Aluminum and Articles Thereof) covers the full range of primary aluminum, semi-fabricated aluminum, and finished aluminum articles. The high-level subheading map: 7601 unwrought aluminum; 7602 waste and scrap; 7603 powders and flakes; 7604 bars, rods, and profiles; 7605 wire; 7606 plates, sheets, and strip greater than 0.2 mm thick; 7607 foil less than or equal to 0.2 mm thick; 7608 tubes and pipes; 7609 tube or pipe fittings; 7610 structures (bridges, towers, columns) and structure parts; 7611 reservoirs, tanks, and containers greater than 300 liters; 7612 casks, drums, and containers less than or equal to 300 liters; 7613 aluminum containers for compressed gases; 7614 stranded wire, cables, and plaited bands; 7615 table, kitchen, and household articles; 7616 other articles of aluminum. Every 10-digit HTS code in Chapter 76 rolls up under one of these subheadings.
TariffWatch is built specifically around the Section 232 aluminum-and-steel derivative-article regime and the FR 2026-15961 comment window. Its Section 232 exposure checker (/tariffwatch/hts-checker) reads a 10-digit HTS code and returns whether the code falls within one of the 14 proposed derivative-article definitions, and its watchlist notifies when an HTS code moves into or out of a final BIS inclusion. TariffWatch is not a general AD/CVD scope-inquiry tool and is not a substitute for a customs broker or trade attorney monitoring the ITA AD/CVD orders for the same importer. Those two regimes -- Section 232 on one hand, AD/CVD on the other -- are administered by different agencies (BIS for Section 232, ITA for AD/CVD), on different timelines, and require different paperwork.
No. TariffWatch is a data and workflow tool, not a licensed customs broker, not a filer of record, and not a legal-advice service. HTS classification is the responsibility of the importer under 19 USC 1484, typically executed by the importer customs broker or in-house trade compliance function. Nothing on this page constitutes legal, tax, or customs advice. Compliance decisions remain the responsibility of the importer and their customs broker or trade attorney.
TariffWatch monitors the Section 232 aluminum and steel regime end to end — free exposure checker, $29/month watchlist for post-2026-08-27 final-inclusion changes, 14 slug-specific inclusion-rebuttal templates.