US defines domestic content for Section 232 tariffs on Canadian and Mexican products

A specific definition for the USMCA rule

The notice applies to Canadian and Mexican products that qualify for preferential tariff treatment under the United States–Mexico–Canada Agreement. It implements clause 2(d) of Proclamation 11032 rather than altering the USMCA rules of origin.^[1][2]

US content means value attributable to parts wholly obtained, entirely produced or substantially transformed in the United States. To the extent not already counted, it also includes value attributable to steel melted and poured in the United States, aluminium smelted and cast there, and copper smelted and cast there. Product-specific application questions are directed to US Customs and Border Protection.^[1]

How the additional duty is calculated

Proclamation 11032 modified the metal tariffs imposed under section 232 of the Trade Expansion Act of 1962 through Proclamations 9704, 9705 and 10962. For Annex I-C products from Canada or Mexico qualifying for USMCA preference, clause 2(d) applies a 25% additional duty only to non-US content. Non-US content is total product value less value attributable to US-produced parts, but the proclamation sets a 15% minimum total effective duty through its tariff-schedule implementation.^[2]

The notice supplies the definition needed to operate that rule. It does not extend clause 2(d) to goods lacking USMCA preference or remove the minimum effective rate. The proclamation also directs CBP to impose available penalties where an importer fraudulently or deliberately misleads the government about US content.^[1][2]

Timing and records

The public-inspection document was filed on 9 October and is scheduled for Federal Register publication on 14 October 2026. The guidance is scheduled to apply to products entered for consumption, or withdrawn from warehouse for consumption, from 12:01am Eastern Time on the publication date. Importers relying on clause 2(d) should be able to evidence component origin or transformation and any separately counted US-melted, poured, smelted or cast metal value. Until publication, the notice should not be described as already effective.^[1]