The three duty layers that matter in 2026
After the Supreme Court struck down the IEEPA-based reciprocal tariffs in February 2026, the practical duty stack for fabricated steel imports has three layers. First, Section 232: 50% on steel and aluminum and an expanding list of derivative products, applied to all countries with no exemptions, calculated on the steel content value rather than the full invoice value for derivatives. Second, Section 301: China-specific duties, typically 25% on fabricated steel categories, which do not apply to Vietnam-origin goods. Third, AD/CVD orders: product-specific and country-specific; China carries active orders on dozens of steel product categories with combined rates that frequently exceed 100%, while Vietnam has far fewer orders in fabricated-product categories.
What 'steel content' means for your invoice
For a derivative product — say a welded steel cart with casters, hardware and powder coating — the 50% duty applies to the value of the steel mill content, not the finished unit price. A $200 cart with $60 of steel content carries roughly $30 of Section 232 duty, not $100. This is why accurate steel-content declarations and supplier cost breakdowns now directly reduce your duty bill, and why fabricators that provide Mill Test Certificates and material cost transparency are worth more than their quote suggests.
Worked example: identical cart, two origins
Take that $200 FOB cart with $60 steel content. From Vietnam: ~$30 Section 232 = $230 landed before freight. From China: $30 Section 232 + $50 Section 301 (25% of value) = $280 before freight — and if the category carries an AD/CVD order, the gap widens dramatically. On a 5,000-unit annual program, the China-origin stack costs $250,000+ more per year, before factoring supply-risk premiums.
What procurement teams should do now
Pull the current Section 232 derivative HTS list and map every SKU you import. Require steel-content breakdowns in every quote. Add a tariff-adjustment clause to supplier contracts. And re-run the math quarterly — the derivative list has been expanding, and the planned Section 122 universal tariff (10%) may add a further layer to all origins. LIPHOCO provides steel-content declarations and MTC traceability on every shipment; email madeinvietnam@liphoco.com for a landed-cost worksheet.
Frequently Asked Questions
Yes. As of mid-2026, Section 232 applies to steel, aluminum and listed derivative products from all countries, including Vietnam, with the duty on derivatives calculated on the steel content value. Vietnam's advantage over China lies in Section 301 (China-only, typically +25%) and AD/CVD orders, which do not apply to most Vietnam-origin fabricated products.
For products on the Section 232 derivative list, the 50% rate applies to the declared value of the steel mill content, not the full invoice price. A $200 product with $60 of steel content owes about $30, which is why suppliers who document steel content accurately reduce your duty bill.
No. That claim has been inaccurate since the 2025 tariff expansions. Treat it as a competence red flag. Verify the current HTS classification and duty stack for your specific product with a licensed customs broker before placing orders.