Commerce Dept. Sets Rules for Auto-Linked Steel, Aluminum Tariff Adjustments

2 min readSources: Lex Blog

The U.S. Commerce Department published new tariff adjustment procedures for select steel and aluminum producers on April 23, 2026.

Why it matters: Legal and compliance teams in the automotive and heavy-duty manufacturing supply chain must adapt immediately—the new rules directly impact tariff rates, documentation requirements, and cross-border trade eligibility.

  • Procedures apply to steel and aluminum producers in Canada or Mexico supplying the U.S. auto and MHDV market.
  • Producers must submit detailed investment and production plans to qualify for tariff adjustments.
  • The minimum adjusted tariff rate remains at 25% under Proclamations 9704 and 9705.
  • Eligible applicants may submit documentation to the Commerce Department starting April 23, 2026.

The U.S. Department of Commerce on April 23, 2026, released new procedures for steel and aluminum producers seeking tariff adjustments under Presidential Proclamation 10984. This move specifically targets producers supplying the U.S. automobile and medium- and heavy-duty vehicle (MHDV) sectors.

  • Eligibility: Only steel and aluminum producers in Canada or Mexico are eligible, provided their products serve U.S. producers of automobiles or MHDVs, and the metals were smelted and cast (for aluminum) or melted and poured (for steel) in those countries.
  • Tariff adjustments: Qualified applicants may see reduced tariffs—no lower than 25%—as authorized by Proclamations 9704 and 9705. Eligibility is limited to imports that also qualify for USMCA preferential treatment.
  • Documentation requirements: Producers must submit extensive documentation as of April 23, 2026, using a process outlined in the Federal Register. Required details include project objectives, proposed investment location, production volumes, and milestone schedules. See the Federal Register details.

Coinciding with these changes, the U.S. International Trade Commission released the 2026 Harmonized Tariff Schedule Revision 6 to incorporate the procedural modifications.

Legal and compliance teams for affected producers should review these new requirements to optimize tariff outcomes and minimize regulatory risk.

By the numbers:

  • April 23, 2026 — Commerce published new procedures in the Federal Register
  • 25% — Minimum adjusted tariff rate for qualifying steel and aluminum imports
  • April 23, 2026 — Official open date for producer documentation submissions