If you are an aircraft parts manufacturer that obtains raw materials, fasteners or wires from outside the United States, then the new aluminum, copper and steel tariffs may affect you.
Last week, the President issued a Proclamation, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States.” That proclamation imposes 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles (metal articles) and their derivatives from all countries, effective today (April 6, 2026).
It is important to examine the tariff code for your goods, and compare it to the code listing for the tariff. NOT ALL PARTS ARE SUBJECT TO THESE DUTIES! Most bar stock and other non-finished products are covered. Many wires and fasteners/hardware are covered. For aircraft parts manufacturers, this could affect imported manufacturing materials.
Many finished aircraft parts made from these materials are not covered; but some may be (like certain hydraulic fluid pumps under heading 8413, certain heat exchange units under 8419, and certain bearings under heading 8482 or 8483). To be certain, it is important to check the annexes, which will be incorporated into the HTSUS.
Once you have identified your imports as being subject to one of these tariffs, then you still need to identify which of the annexes applies (based on tariff number) as well as the source of the material. The actual calculation mechanism has gotten more complicated and is more fully described in the proclamation and annexes. For more information, or if you need more guidance, then contact the Association.
Even if the tariff code for your goods is listed, you still need to check the metal content (by weight) because an additional exception may apply. Goods specified in the annexes to the Proclamation, except those classifiable in Chapters 72, 73, 74, and 76, that contain less than 15 percent of the aggregate weight of the applicable metal(s) are not subject to the duties imposed by the Proclamation. This is the sum of the applicable metals where there is more than one tariffed metal. For example, since HTSUS is 8302.10.60 is identified in paragraphs (c)(vi) and (vii) of annex IV as both a derivative aluminum article and steel article in annex IV, the aggregate weight of both aluminum and steel (but not copper) should be included in the 15 percent calculation. If you are able to use the “less than 15% weight” exception, then report it as HTSUS 9903.82.03, and include the aggregate weight of the applicable metal(s) in kilograms as a second quantity on the entry summary line.
