Steel, Aluminum, and Tariff Exposure in 2026: What Section 232 Actually Does to IMP, PEMB, and Structural Steel Pricing
Materials · Trade Policy · Updated August 25, 2026
Steel, Aluminum, and Tariff Exposure in 2026: What Section 232 Actually Does to IMP, PEMB, and Structural Steel Pricing
On April 6, 2026 the duty on an imported insulated metal panel roughly quadrupled without a single rate change. If your escalation clause, estimating template, or proposal boilerplate was written before then, it is wrong, and the error is not small.
The Short Answer
The steel content valuation rule is dead. Proclamation 11021, effective April 6, 2026, applies the Section 232 duty to the full customs value of the imported product, regardless of metal content. On a $10 per square foot imported panel with 25 percent declared steel content, the duty went from about $1.25 per square foot to about $5.00 per square foot with no change in the rate. Current structure is three tiers: 50 percent on steel, aluminum, copper and the Annex I-A derivatives, 25 percent on Annex I-B derivatives including prefabricated buildings and refrigeration equipment, and a temporary 15 percent floor on fixed industrial machinery and power equipment that reverts to 25 percent on January 1, 2028. Separately, the Supreme Court struck down the IEEPA tariffs on February 20, 2026, and they were terminated.
Key Takeaways
- Domestic galvanized coil is at $1,425 per short ton. World export hot rolled band is $500 per metric tonne. The United States is trading at roughly a 2.5 times premium to world export price, and that wedge is the tariff made visible.
- Steel mill products PPI is up 22.5 percent year over year. Aluminum mill shapes are up 40.5 percent. Fabricated structural metal is up only 1.9 percent and down 1.1 percent year to date. Fabricator margins are being compressed, and that is not sustainable.
- A $100 per ton move in coated coil is worth about 8 cents per square foot of 26 gauge over 26 gauge IMP at the coil level, and roughly 10 to 11 cents installed.
- Coil is a minority of installed IMP cost. Which means coil price alone does not explain 2026 IMP inflation. The 50 percent duty on full customs value does more of the work.
- The inclusions petition process was terminated. Commerce and USTR can now add derivative products on a rolling basis with effectively zero lead time. There is no window to watch anymore.
- There is no drawback on the 50 percent tier, and foreign trade zone admissions must now enter as privileged foreign status, so the FTZ no longer defers the duty.
- An imported PEMB kit at 25 percent of full customs value on a $12 per square foot FOB kit is $3.00 per square foot of duty. Domestic PEMB is now structurally advantaged.
What This Covers
- The current rate structure, and the dates that produced it
- Where IMP, PEMB, and structural steel actually land in the tariff schedule
- The valuation change, and why it matters more than any rate change
- What steel actually costs right now
- Pass through arithmetic you can use on a bid
- The escalation clause that survives a fight
- Early buyout, and the insurance mistake everyone makes
- Lead times, honestly stated
- What to do and what not to do
- Frequently asked questions
Read This Before You Read Anything Else
Two things changed fundamentally in 2026, and pre 2026 material on this subject is wrong on both counts.
First, the steel content valuation rule for derivative products is gone. Duty now applies to full customs value.
Second, the IEEPA tariffs were struck down by the Supreme Court on February 20, 2026 and terminated by executive order five days later. Section 232 and Section 301 were expressly preserved. CBP is processing refunds on the IEEPA duties, which is money that in many contracts should flow back to the owner.
Any escalation clause, estimating template, or proposal boilerplate written before April 2026 needs to be pulled and reviewed. This is a live margin exposure on anything bid since spring.
The Current Rate Structure
Governed by Proclamation 11021 of April 2, 2026, as amended by Proclamation 11032 of June 1 and Proclamation 11045 of July 20. Implemented in HTSUS chapter 99, subchapter III, headings 9903.82.01 through 9903.82.26.
| Tier | Rate | Applies to |
|---|---|---|
| 9903.82.02 | Plus 50% | Aluminum, steel, and copper articles and the Annex I-A derivative lists |
| 9903.82.09 | Plus 25% | Annex I-B derivatives |
| 9903.82.10 and .11 | 15% floor | Fixed industrial machinery, power equipment, agricultural equipment, residential HVAC. Temporary through December 31, 2027, then reverts to 25 percent |
| 9903.82.04 and .05 | 25% / 15% | UK origin, where 95 percent or more of steel is melted and poured in the UK |
| Note 16(e) | 10% | Where 85 percent or more of metal content by weight is US melted and poured, or US smelted and cast. Threshold was lowered from 95 percent in June 2026 |
The Chronology, With Dates You Can Cite
| Effective | Instrument | What changed |
|---|---|---|
| Mar 12, 2025 | Proclamations 10895 and 10896 | Aluminum 10 to 25 percent. All country exemptions, tariff rate quotas, and agreements terminated. All general approved exclusions terminated. Derivative scope expanded into chapters 73 and 76 |
| Jun 4, 2025 | Proclamation 10947 | 25 to 50 percent on steel, aluminum, and derivatives. UK held at 25. Codified the steel content valuation rule |
| Apr 6, 2026 | Proclamation 11021 | Duty applies to full customs value regardless of metal content. Three tier 50 / 25 / 15 structure. Inclusions process terminated. Drawback allowed only for 25 and 15 percent tiers from trade agreement partners. FTZ admissions must be privileged foreign status |
| Jun 8, 2026 | Proclamation 11032 | Agricultural equipment and residential HVAC into the 15 percent tier. Steel racks added. US metal threshold redefined from 95 percent to 85 percent by weight |
| Jul 2026 | Proclamation 11045 | No rate change. Primary aluminum onshoring incentive allowing approved investors to import at half the Section 232 rate |
| Comments closed Aug 27, 2026 | BIS notice, 91 FR 50756 | Proposes adding 14 more derivative articles at 25 percent |
On country treatment, the short answer is that there are no country exemptions and no tariff rate quotas on steel or aluminum articles. All were terminated in March 2025. What survives is the UK reduced rate, a 15 percent rate for eleven jurisdictions on mobile industrial equipment only, USMCA non US content treatment on that same narrow list, an auto sector only Canada and Mexico quota program, and punitive Russia rates. Separately, Canada has announced it will match US rates including 50 percent on steel and aluminum effective September 8, 2026.
Where Your Products Actually Land
All HTS codes below verified against US Note 16, HTSUS Revision 17 for 2026.
The 50 Percent Tier
| Product | HTS | Rate |
|---|---|---|
| Galvanized, Galvalume, and prepainted coil | 7210, whole heading | 50% |
| Hot rolled, cold rolled, plate, flat rolled | 7208, 7209, 7211, 7212, 7225, 7226 | 50% |
| Structural shapes, angles, sections | 7216 series | 50% |
| Rebar and bars | 7213, 7214, 7215 | 50% |
| Pipe and tube, including HSS | 7304, 7305, 7306 | 50% |
| Cold formed sections: purlins, girts, Z and C sections | 7216.91.0010 | 50% |
| Fabricated structural steel, structures and parts of structures | 7308 series | 50% |
| Fasteners: screws, bolts, nuts, washers, self drilling | 7318.11.00 through 7318.29.00 | 50% |
| Wire mesh, expanded metal, grating | 7314 series, 7308.90.95 | 50% |
| Aluminum structures and parts, curtain wall and framing | 7610.10.00, 7610.90.00 | 50% |
The 25 Percent Tier
| Product | HTS | Rate |
|---|---|---|
| Prefabricated buildings, the classic PEMB kit classification | 9406.20.00 and 9406.90.01 | 25% |
| HVAC machines and parts, commercial split systems, condensers, AHU parts, enclosures | 8415.10.30, 8415.83.00, 8415.90.40 | 25% |
| Refrigeration equipment and enclosures, walk in cooler and freezer equipment | 8418 series | 25% |
| Steel furniture, shelving, and racks | 9403 series | 25% |
| Motors, generators, transformers | 8501, 8502, 8504 series | 25% |
Where Insulated Metal Panels Sit
There is no HTS line reading "insulated metal panel." IMPs are classified by construction and use, and the realistic outcomes are:
- 7308.90.95, other structures and parts of structures of iron or steel. The most common landing spot for profiled building panels prepared for use in structures. 50 percent, full customs value, no metal content threshold, because chapter 73 goods are exempt from the 15 percent by weight test.
- 7326.90.86, other articles of steel. Also 50 percent, also chapter 73, also no threshold.
- 9406.90.01, if imported as part of a prefabricated building or complete kit. 25 percent, and because chapter 94 sits outside chapters 72, 73, 74 and 76, the 15 percent by weight test does apply. A steel skinned foam core panel comfortably exceeds 15 percent steel by weight, so it is dutiable at 25 percent on full value.
- Single skin wall and roof panels, trim, flashing, soffit, liner panel: same analysis. 7308.90.95 at 50 percent, or if simply coated flat coil not yet formed, 7210 at 50 percent.
Classification Risk Is The Largest Unquantified Exposure In The Chain
A 25 point rate difference turns on whether CBP treats your panel as a structural part under 7308 or a prefabricated building component under 9406. On a container of panels that is real money. Anyone importing panel should hold a binding ruling, or at minimum a documented classification opinion, for each imported panel line. We could not locate a published 2026 CBP ruling specifically on IMP classification, so treat this as an open question and get it answered in writing rather than assumed.
The Valuation Change, And Why It Beats Any Rate Change
Before April 6, 2026, the Section 232 duty applied only to the steel content of chapter 73 articles and only to the aluminum content of chapter 76 articles. Importers declared steel content value. The non metal content fell under other tariff regimes.
On and after April 6, 2026, the language of Proclamation 11021 is unambiguous: the additional ad valorem duty "shall apply to the full customs value of the imported product, regardless of metal content."
| Assembled IMP, worked example | Before April 6, 2026 | After April 6, 2026 |
|---|---|---|
| Imported panel, customs value | $10.00/sf | $10.00/sf |
| Declared steel content value | $2.50/sf, 25 percent | Irrelevant |
| Section 232 rate | 50% | 50%, unchanged |
| Duty | 50% of $2.50 equals $1.25/sf | 50% of $10.00 equals $5.00/sf |
Four Consequences Nobody Priced
What Changed On April 6 Beyond The Number
Proclamation 11021 did more than reprice. It closed most of the escape hatches importers had been using.
Inclusions Are Now Rolling
The public petition process was terminated. Commerce and USTR may jointly add derivatives on a rolling basis, effective on the date of their finding. They may solicit input but are not obliged to. There is no longer a scheduled window to watch, and scope can expand with roughly zero lead time. New inclusions default to 25 percent unless a comparable article sits on the 50 percent list.
No Drawback On 50 Percent
Drawback is available only for the 25 and 15 percent tiers, only from trade agreement partners, only where metal content is entirely from a trade agreement partner, and never where the merchandise type is under an antidumping or countervailing duty order.
FTZ No Longer Defers
Covered goods admitted on or after the effective date must enter as privileged foreign status. The foreign trade zone no longer defers or avoids the duty.
AD/CVD Stacks On Top
Note 16(b) preserves all antidumping, countervailing, and other duties. Live 2026 proceedings touching construction include rebar from Bulgaria, Egypt, and Vietnam, with final affirmative determinations July 30, 2026, and welded stainless line and pressure pipe investigations initiated August 10, 2026.
Sources: Proclamation 11021, 91 FR 18201; HTSUS Revision 17 (2026) US Note 16. Within Section 232, headings 9903.82.02 through .26 are mutually exclusive, so a good containing both steel and aluminum pays once.
What Steel Actually Costs Right Now
| Product, $/short ton FOB mill | Low | Average | High |
|---|---|---|---|
| Hot rolled coil | $1,170 | $1,195 | $1,220 |
| Cold rolled coil | $1,400 | $1,430 | $1,460 |
| Galvanized | $1,390 | $1,425 | $1,460 |
| Galvalume | $1,400 | $1,430 | $1,460 |
| Plate | $1,360 | $1,395 | $1,430 |
The Number That Explains Everything Else
SteelBenchmarker's August 12, 2026 report puts USA hot rolled band at $1,264 per metric tonne, and notes that the previous record peak was $1,203 per tonne set in July 2008. The current price exceeds it. Meanwhile world export hot rolled band is $500 per tonne, China is $415, and Western Europe is $825. The United States is trading at roughly a 2.5 times premium to world export price. That gap is the tariff wedge, made visible in a single number.
Producer Price Index, Year Over Year Through July 2026
| BLS series | What it covers | Year over year | Year to date 2026 |
|---|---|---|---|
| WPU1017 | Steel mill products | +22.5% | +19.8% |
| WPU101707 | Cold rolled steel sheet and strip | +19.0% | +17.2% |
| WPU101704 | Hot rolled bars, plates, and structural shapes | +14.7% | +8.1% |
| WPU102501 | Aluminum mill shapes | +40.5% | +21.0% |
| WPU107405 | Fabricated structural metal | +1.9% | minus 1.1% |
| WPU10740514 | Fabricated structural for commercial, institutional, and public buildings | +21.5% | +13.4% |
| WPU1074051 | Bar joists and concrete reinforcing bars | +17.7% | +10.7% |
| WPU107407 | Custom roll form products: purlins, girts, deck substrate | +4.0% | +5.7% |
| WPU107901 | Prefabricated metal building systems | +4.1% | +2.3% |
| WPU10790354 | Panels, parts and sections for prefabricated buildings. The closest public proxy for metal panel pricing | +9.4% | +6.9% |
| WPUIP230000 | Inputs to construction industries | +7.2% |
The Divergence That Predicts Late 2026
Fabricated structural metal is up only 1.9 percent year over year and down 1.1 percent year to date, while its input, hot rolled bars, plates, and shapes, is up 14.7 percent. Prefabricated metal building systems are up 4.1 percent against steel mill products up 22.5 percent.
Fabricators and PEMB manufacturers are absorbing the mill move. That is a demand signal, and it is not a durable one. It is the most likely source of a step change in fabricated quotes in late 2026 and into 2027. If you are budgeting a 2027 start off a 2026 quote, carry that risk explicitly.
Pass Through Arithmetic You Can Use
Insulated Metal Panel
Steel density is 0.2836 pounds per cubic inch, which is 40.84 pounds per square foot per inch of thickness. Coil consumed per square foot of finished panel is both skins, times a profile development factor of about 1.05 for lightly ribbed panel, times a coil yield and trim factor of about 1.06.
| Panel skin combination | lb coil per sf | Coil cost/sf at $1,425/st galvanized | Change per $100/ton coil move |
|---|---|---|---|
| 26 ga / 26 ga, most common | 1.63 | $1.16 | $0.081/sf |
| 24 ga exterior / 26 ga interior | 1.90 | $1.35 | $0.095/sf |
| 22 ga / 22 ga, heavy duty cold storage | 2.72 | $1.94 | $0.136/sf |
Rule of thumb: a $100 per ton move in galvanized or prepainted coil is worth roughly 8 cents per square foot of 26 over 26 IMP at the coil level, or about 10 to 11 cents per square foot installed after fabricator and installer markup. A $500 per ton move, roughly the scale of the 2024 to 2026 repricing, is worth about 40 cents at coil and 50 to 55 cents installed.
Here is the nuance that matters. Coil is a minority of installed IMP cost. At $1.16 per square foot of coil against typical installed IMP wall assembly ranges, raw coil is a single digit percentage of installed cost. Which means coil price alone does not explain 2026 IMP inflation. What does: prepaint and coil coating conversion cost, the 50 percent duty on full customs value of any imported panel or imported coil, core material costs, freight, and labor.
The PPI confirms it. Panels and parts for prefabricated buildings rose 9.4 percent year over year while steel mill products rose 22.5 percent. Panels absorbed roughly 40 percent of the mill move over twelve months, which is exactly what you would expect if coil is a minority of panel value. We priced the full IMP picture in the 2026 IMP installation cost guide.
Pre-Engineered Metal Building
Typical low rise PEMB steel intensity runs primary rigid frames at 3 to 8 pounds per square foot of footprint, secondaries at 1.5 to 3, and roof and wall sheeting at roughly 1.3 to 1.6, for a total of about 6 to 12 pounds per square foot at conventional spans and 40 to 60 psf design loads. Heavier for long span, high seismic or wind, and crane buildings.
| Steel intensity | Per $100/ton | Per $250/ton | Per $500/ton |
|---|---|---|---|
| 6 lb/sf | $0.30/sf | $0.75/sf | $1.50/sf |
| 8 lb/sf | $0.40/sf | $1.00/sf | $2.00/sf |
| 12 lb/sf | $0.60/sf | $1.50/sf | $3.00/sf |
Structural Steel, Joists, And Deck
| Framing weight | Per $100/ton | Per $250/ton |
|---|---|---|
| 8 lb/sf, low rise commercial | $0.40/sf | $1.00/sf |
| 10 lb/sf | $0.50/sf | $1.25/sf |
| 15 lb/sf, industrial | $0.75/sf | $1.88/sf |
| 20 lb/sf, heavy | $1.00/sf | $2.50/sf |
The Tariff Arithmetic, Stated Plainly
- Imported galvanized coil at a $900 per tonne landed value carries $450 per tonne of Section 232 duty. That single line explains a $1,425 domestic galvanized price against a $500 world export hot rolled price.
- Imported IMP: duty went from about $1.25 to about $5.00 per square foot on a $10 panel on April 6, 2026, with no rate change.
- Imported PEMB kit under 9406.90.01: 25 percent of full customs value. On a $12 per square foot FOB kit that is $3.00 per square foot. Domestic PEMB is structurally advantaged in a way it was not two years ago. We laid out the underlying economics in the PEMB cost per square foot guide.
The Escalation Clause That Survives A Fight
Start with the structural fact. AIA A201-2017 contains no material price escalation clause. A102 and A103 allocate cost risk through the Cost of the Work and GMP structure rather than through an index, and A201 section 8.3 on delays gives time only, not money. Escalation protection under AIA has to be added by supplementary conditions or an exhibit.
ConsensusDocs 200.1, the Material Price Escalation Amendment, is the only standard published escalation form. It uses a named schedule of materials, an agreed objective market index, and it operates bidirectionally, meaning de-escalation as well as escalation.
Eight Elements. Most Failed Clauses Are Missing Three Or More.
01
Named commodities with a scope definition, not "materials"
Write "galvanized and prepainted steel coil, ASTM A653 and A792, incorporated into insulated metal panels and single skin metal wall and roof panels." Not "steel."
02
A named published index with a stated series ID
BLS WPU1017 for steel mill products, or WPU10790354 for panels and parts for prefabricated buildings, or a named galvanized assessment. And say what happens if the series is discontinued. This is not hypothetical. BLS killed the hot rolled sheet series in February 2022.
03
A fixed baseline date and baseline value
Stated as a number, not as "at time of bid."
04
A threshold, and a statement of what the adjustment applies to
Typically 5 percent movement before adjustment triggers. Then state whether the adjustment applies to the full movement or only the movement above the threshold. Ambiguity here is the single most litigated point in escalation disputes.
05
Symmetry
De-escalation must be express. An owner will not sign a one way clause, and a one way clause invites a bad faith argument.
06
A cap or a shared band
Contractor absorbs the first 5 percent, parties share 50/50 from 5 to 15 percent, owner absorbs above 15. Caps are what make the clause signable.
07
A measurement point and a documentation standard
Is the adjustment measured at buyout, at release for fabrication, at shipment, or at installation? Require supplier invoices or quotes as substantiation.
08
A separate, explicit tariff and change in law provision
Do not rely on the index to capture tariffs. A PPI is a domestic transaction price index. A duty imposed on an imported component may not move it in the same period, and April 6, 2026 proves the risk: the duty on an assembled panel quadrupled with no rate change and no index event. Draft a change in law clause capturing new or increased duties, changes in the method of duty assessment or valuation, changes in classification or scope inclusion, and newly included derivative articles. Then draft the mirror image for refunds. The IEEPA refunds now flowing through CBP are a live example of money that should go back to the owner.
Force Majeure Is Not An Escalation Clause
Force majeure gives time, not money. Neither AIA A201 section 8.3 nor ConsensusDocs 200 section 6.3 converts a price increase into a change order. And in 2026, after two years of published proclamations, tariffs are foreseeable. A court will not find an unforeseeable event. Any force majeure based escalation claim in 2026 is weak. The correct instruments are an escalation clause, a change in law clause, an allowance, a cost plus or GMP structure, and early buyout. Force majeure is a fifth string backup.
Early Buyout, And The Insurance Mistake Everyone Makes
Buy out early on long lead, tariff exposed, price volatile items: IMP coil, PEMB kits, structural steel mill orders, joists, deck. Do not buy out early on anything commodity generic, easily substituted, or short lead.
Before releasing money, get all of this:
- Title transfer language. Specify when title passes, typically on payment, and that it passes free of liens.
- Segregation and identification. Material physically segregated, tagged to the project, and identified in the supplier's records. Otherwise you have paid for a fungible pile.
- Off site storage insurance. Builders risk policies commonly exclude or sub limit off site and in transit property. This must be an affirmative endorsement with a stated sub limit adequate to the stored value, with the owner and lender as named insureds. This is the single most common failure in early buyout deals.
- A bonded or third party warehouse with a warehouse receipt, or a supplier storage agreement with inspection rights.
- Right of inspection and audit for the owner and lender.
- Storage cost and duration, including what happens if the schedule slips past the storage term.
- Consequences of supplier insolvency. A UCC-1 filing on stored goods is worth the filing fee.
- Escalation clause interaction. A bought out item must be carved out of the escalation clause, or the owner pays twice.
On letters of intent for mill orders and PEMB kits, at minimum: state a not to exceed authorized spend, identify the specific mill order or release, tie the price validity period to the mill's quote expiry rather than the LOI date, address what happens if the prime contract is never executed, confirm insurance is in place before any material is produced, state that the LOI amount is credited against the eventual subcontract rather than additive, and get it signed by someone with authority to bind the owner. LOIs signed by a development manager without funding authority are the classic dispute.
The GMP Structure That Shares Escalation Fairly
The cleanest and most defensible structure is an escalation specific contingency line, owner controlled, separate from the GMP contingency, sized off the actual exposure. Steel intensive scope, times pounds per square foot, times a stated dollar per ton band. Unused balance returns to the owner. Pair it with allowances for named commodities reconciled to actual invoices at buyout, with the escalation clause suspended for allowance items so nothing is counted twice. That is how we structure design build GMPs on steel intensive work.
Lead Times, Honestly Stated
| Product | Mill lead time, August 19, 2026 |
|---|---|
| Hot rolled | 7.59 weeks |
| Cold rolled | 8.71 weeks |
| Galvanized | 8.87 weeks |
| Galvalume | 8.86 weeks |
This is the number that matters for IMP. Coated coil is the panel feedstock, and roughly nine weeks at the mill sits in front of panel fabrication. So a realistic 2026 IMP lead time is mill nine weeks, plus panel line queue, plus finishing and shipping.
We are deliberately not publishing week counts for IMP, PEMB packages, fabricated structural steel, joists, or deck. No 2026 dated public source exists for any of them. Manufacturers quote privately, MBMA publishes no public lead time data, and AISC's availability page is not accessible. Anyone quoting you a specific number for those from a public source is repeating something they cannot support. Ask your contractor for their current live buyout log instead. That is a better source than anything published.
What To Do, And What Not To Do
| Do | Do not |
|---|---|
| Pull and rewrite every escalation and change in law clause written before April 2026. The valuation change is not captured by an index. | Rely on force majeure. It gives time, not money, and tariffs are foreseeable in 2026. |
| Get a binding ruling or written classification opinion on every imported panel line. A 25 point rate swing turns on 7308 versus 9406. | Speculatively buy material without storage, segregation, title transfer, and an off site storage endorsement naming the owner and lender. |
| Name the BLS series ID in the clause, and say what happens if it is discontinued. | Assume the FTZ defers the duty. It does not, as of April 2026. |
| Carry an owner controlled escalation contingency sized off pounds per square foot times a stated dollar per ton band. | Assume drawback is available. There is none on the 50 percent tier. |
| Budget the fabricator margin compression risk explicitly on any 2027 start priced off a 2026 quote. | Wait for an inclusions window before checking scope. There is no window anymore. |
| Write the refund mirror clause. IEEPA money is flowing back through CBP right now. | Carry a pre 2026 tariff assumption in an estimating template. It is wrong by a factor of roughly four on assembled imported product. |
Get Your Escalation Language Reviewed Before The Next Buyout
Terrapin Construction Group has installed more than one million square feet of insulated metal panel across 38 states and holds direct relationships with the major IMP manufacturers. We price steel intensive scope with the current duty structure, the current mill lead time, and a stated escalation band, not with a template written before the rules changed.
Schedule A 30 Minute Call Get An Instant IMP EstimateFrequently Asked Questions
What is the current Section 232 tariff on steel in 2026?
Fifty percent on steel, aluminum, and copper articles and on the Annex I-A derivative list. Twenty five percent on Annex I-B derivatives, which includes prefabricated buildings, HVAC and refrigeration equipment, and steel racks. A temporary fifteen percent floor applies to fixed industrial machinery, power and grid equipment, agricultural equipment, and residential HVAC through December 31, 2027, after which it reverts to twenty five percent. A ten percent rate applies where 85 percent or more of metal content by weight is US melted and poured, a threshold lowered from 95 percent in June 2026. There are no country exemptions and no tariff rate quotas.
Do tariffs apply to the whole panel or just the steel in it?
The whole panel, as of April 6, 2026. Proclamation 11021 states that the duty applies to the full customs value of the imported product regardless of metal content. Before that date the duty applied only to the declared steel content of chapter 73 articles. On a $10 per square foot imported panel with 25 percent declared steel content, the duty went from about $1.25 per square foot to about $5.00 per square foot with no change in the rate. For assembled, coated, or value added products where the metal is a minority of value, this change is worth far more than the 25 to 50 percent rate move of June 2025.
How much does a $100 per ton steel move actually cost me per square foot?
On a 26 gauge over 26 gauge insulated metal panel, about 8 cents per square foot at the coil level and roughly 10 to 11 cents installed. On a pre-engineered metal building at 8 pounds per square foot of steel intensity, about 40 cents per square foot. On structural steel at 10 pounds per square foot of framing, about 50 cents. On steel deck at 1.5B 20 gauge, about 10 cents. On joists at 2.5 to 4 pounds per square foot of framed area, 13 to 20 cents. A $100 per ton mill move is 5 cents per pound, so once you know your pounds per square foot the arithmetic is direct.
Are the IEEPA tariffs still in effect?
No. The Supreme Court held on February 20, 2026 in Learning Resources, Inc. v. Trump that IEEPA does not authorize tariffs, and an executive order five days later terminated all IEEPA ad valorem duties. Section 232 and Section 301 were expressly preserved and are unaffected. CBP is processing refunds on IEEPA duties already paid, which in many contracts is money that should flow back to the owner. If your contract has an escalation or change in law clause with no refund mirror, that is a live gap.
Does putting material in a foreign trade zone defer the tariff?
Not since April 6, 2026. Proclamation 11021 requires that Section 232 covered goods admitted to a foreign trade zone on or after the effective date must enter under privileged foreign status. That fixes the duty treatment at admission, so the FTZ no longer defers or avoids the duty. Similarly, drawback is now available only for the 25 and 15 percent tiers, only from trade agreement partners, only where the metal content is entirely from a trade agreement partner, and never where the merchandise type is subject to an antidumping or countervailing duty order. There is no drawback at all on the 50 percent tier.
Is a domestic PEMB cheaper than an imported one now?
Structurally, yes, in a way it was not two years ago. An imported prefabricated building kit classified under 9406.90.01 carries 25 percent of full customs value. On a $12 per square foot FOB kit that is $3.00 per square foot of duty before freight. The domestic PEMB market has also been absorbing rather than passing through the mill increase, with prefabricated metal building systems PPI up only 4.1 percent year over year against steel mill products up 22.5 percent. That absorption is a demand signal rather than a durable condition, so a 2027 start priced off a 2026 quote carries real risk.
Will steel prices come back down?
We are not going to predict that, and you should be skeptical of anyone who does. What we can tell you is the structure. US hot rolled band at $1,264 per tonne against a world export price of $500 means roughly a 2.5 times premium, and that gap is the tariff. It closes if and when the tariff structure changes, not because of ordinary supply and demand. Separately, the divergence between mill prices up 22.5 percent and fabricated structural metal up 1.9 percent tells you fabricator margins are compressed, which points toward fabricated quotes catching up rather than mill prices falling.
What should my escalation clause say?
Eight things. Name the specific commodities with a scope definition, not "materials." Name a published index with its exact series ID, and say what happens if the series is discontinued. State a fixed baseline date and a baseline value as a number. Set a threshold, typically 5 percent, and state whether the adjustment applies to the full movement or only the movement above it. Make it symmetric so de-escalation is express. Cap it or band it. Name the measurement point and the documentation standard. And write a separate change in law provision that captures new or increased duties, changes in the method of duty assessment or valuation, changes in classification, and newly included derivatives, with a mirror clause for refunds.
Can I still get a tariff exclusion for my product?
No. The exclusion request process was terminated in March 2025 along with all general approved exclusions. The inclusions petition process, which allowed parties to request that products be added to the derivative lists, was itself terminated by Proclamation 11021 in April 2026. Commerce and USTR may now jointly add derivatives on a rolling basis, effective on the date of their finding, and they may solicit input but are not obliged to. The practical consequence is that there is no longer a scheduled window to monitor, and scope can expand with effectively zero lead time.
How do I know if my imported panel is being classified correctly?
You get it in writing. There is no HTS line reading insulated metal panel, so classification turns on construction and use. A profiled building panel prepared for use in structures most commonly lands at 7308.90.95 at 50 percent of full customs value with no metal content threshold, because chapter 73 goods are exempt from the 15 percent by weight test. The same panel imported as part of a prefabricated building kit lands at 9406.90.01 at 25 percent. That is a 25 point swing on the same physical product. Get a binding ruling from CBP, or at minimum a documented classification opinion for each imported panel line, and do not accept an assumption.
Sources And Further Reading
- Proclamation 11021, 91 FR 18201, full customs value rule effective April 6, 2026
- Proclamation 11032, 91 FR 34085, June 2026 amendments
- Proclamation 11045, primary aluminum onshoring incentive
- BIS, 91 FR 50756, proposed additional derivative articles, August 2026
- Proclamation 10947, the 25 to 50 percent increase and the superseded content rule
- Proclamation 10896, termination of all country exemptions and quotas
- Learning Resources, Inc. v. Trump, 607 U.S. 229 (2026)
- Executive Order 14389, terminating IEEPA duties, preserving Section 232 and 301
- USTR, 91 FR 47318, Section 301 actions effective July 2026
- USITC Harmonized Tariff Schedule, Revision 17 (2026), headings 9903.82.01 through .26 and US Note 16
- Commerce and BIS Section 232 program page
- AGC Producer Price Index tables, data through July 2026
- AGC monthly construction PPI index page
- Steel Market Update flat rolled price assessment
- Steel Market Update flat rolled mill lead times
- SteelBenchmarker price history, World Steel Dynamics
- Sandler Travis and Rosenberg Section 232 steel and aluminum tracker
- ConsensusDocs 200.1, Material Price Escalation Amendment
- ConsensusDocs 2026 price escalation guidance and recommended indices
- Metal Construction Association on the CBP IEEPA refund effort
- Dodge Momentum Index, July 2026
- Dodge total construction starts, July 2026
Terrapin Construction Group is a nationwide design build commercial general contractor headquartered in Denver, Colorado, licensed in all 50 states, and a Procore Certified Contractor. We have installed more than one million square feet of insulated metal panel across 38 states and hold direct relationships with the major IMP manufacturers, including PermaTherm, Kingspan, Metl-Span, CENTRIA, AWIP, MBCI, and UPI Panels.
Trade policy on this subject has changed materially four times in eighteen months. Every rate, date, and HTS code in this article was verified against the Federal Register, the Harmonized Tariff Schedule, or a Supreme Court slip opinion on August 25, 2026, and every one of them can change with days of notice. Confirm current status before relying on any figure. Nothing here is legal advice, customs advice, or a classification opinion. Classification questions should go to a licensed customs broker or trade counsel, and a binding ruling from CBP is the only authoritative answer.
