Cab To Axle

Independent reporting for the vocational truck trade.

The metals tariff now counts the whole part, not the steel in it

Since April 6 the Section 232 duty on a hydraulic cylinder or pump runs on the full invoice. June added a reduced tier tied to cranes and lift trucks. Dump trucks are not on that list.

Mack dump truck parked at a curb in front of a brick building
Photo: Raysonho / Wikimedia Commons, CC0

Most tariff coverage in the truck-equipment trade is about the chassis. The tariff that lands on a body builder's own purchase orders for cylinders, pumps and hoists runs on a different rule, and the rule changed in April.

The Secretary of Commerce recommended that the tariffs "apply to the full customs value of derivative products." Proclamation 11021 of April 2 did that. For goods entered on or after April 6, 2026, the Section 232 duty on listed steel, aluminum and copper products applies to the full customs value of the imported product, regardless of metal content. A hydraulic cylinder that is mostly machining, seals and labor now pays its percentage on the whole invoice, the same as a plate of steel.

What is on the 25 percent list

Annex I-B of the proclamation is the 25 percent list of derivative products. As revised in June, it includes these tariff lines that touch a work-truck build:

Tariff lineDescription in the annex
8412.21.00Hydraulic power engines and motors, linear-acting (cylinders)
8413.81.00Pumps
8425.42.00Jacks and hoists, hydraulic, not of a built-in type used in garages
8431.49.10Parts suitable for use solely or principally with the machinery of heading 8426, nesoi
8708.10.30Bumpers for motor vehicles of headings 8701 to 8705

Heading 8707, truck bodies, does not appear in the April annexes or in the June versions of Annex I-B and I-C. That says something about how the bodies are classified, not about what a body costs.

June added a third list, and it is narrow

Proclamation 11032 of June 1 created Annex I-C for mobile industrial equipment. It runs from June 8 until 11:59 p.m. on December 31, 2027. The list includes mobile cranes (8705.10), mobile drilling derricks (8705.20), lift trucks under heading 8427 and parts for them (8431.20). It does not include heading 8704, which is where dump trucks sit.

Where the product is listedRate on full valueExceptions in the text
Annex I-A, metal articles and some derivatives50%Reduced rates for certain UK products; 10% for derivatives if the metal is entirely U.S.
Annex I-B, derivatives such as cylinders and pumps25%15% for UK steel; 10% if the metal is entirely U.S.
Annex I-C, mobile industrial equipment, June 8, 2026 to Dec 31, 202725%EU, Japan, Korea, Switzerland, Taiwan, UK and others: combined duty brought to 15%. USMCA goods: 25% on non-U.S. content, never below 15% total. 10% if the metal is entirely U.S.
Annex I-C from Jan 1, 2028Back to the Annex I-B ratesNone added
When the rules change
  1. Apr 6
    Duty applies to the full customs value of listed products.
  2. Jun 8
    Annex I-C starts. The 'entirely U.S. metal' test drops from 95% to 85% of metal weight.
  3. Dec 31, 2027
    The reduced Annex I-C rates end at 11:59 p.m.
  4. Jan 1, 2028
    Annex I-C goes back to the Annex I-B rates.

Source: Proclamation 11021 (April 2, 2026); Proclamation 11032 (June 1, 2026)

The 10 percent rate is worth reading twice. A derivative product qualifies only if its steel was melted and poured in the United States and its aluminum was smelted and cast here. June changed what "entirely" means. At least 85 percent of the product's metal, by weight, now has to be American. The old threshold was 95 percent.

The USMCA floor

For Canadian and Mexican goods that qualify under USMCA, the June text taxes only the non-U.S. content at 25 percent, with a floor: the total effective duty may not be less than 15 percent. The arithmetic below is the formula applied to a $100 article. How U.S. content is measured is left to guidance from the Secretary to CBP, so these are not rates a broker can enter today.

Duty on a $100 USMCA article in Annex I-C, by U.S. content
0% U.S. content$25
20% U.S. content$20
40% U.S. content$15
60% U.S. content$15
80% U.S. content$15

Source: Proclamation 11032, clause (2)(d); editor's arithmetic

Past 40 percent U.S. content the floor, not the content, sets the duty.

The part that decides which list you are on

A cylinder for a mobile crane and a cylinder for a dump hoist can end up in different places. The header of the June Annex I-B says any part in chapters 84, 85 or 87 that is listed on it takes the reduced rate from clause (5) of Proclamation 11021 "when imported exclusively for use in the manufacturing of mobile industrial equipment listed in Annex I-C," or of agricultural or fixed industrial equipment listed in Annex III. Dump trucks, heading 8704, are not on the Annex I-C list.

Then there is the other tariff. The October 2025 proclamation on medium- and heavy-duty trucks and their parts took effect November 1, 2025. Its clause 9 says stacking of tariffs follows the rules that apply to the auto-parts proclamation, 10908. Per CBP's November 2025 guidance, goods subject to the truck tariff are not also charged the metals duties. Neither 2026 proclamation restates that rule, so which tariff a given part falls under is a classification question for the entry.

Ask the brokerWhy it matters
Is this entry under the truck tariff or the metals list?The two are not supposed to stack. The answer moves the rate.
Can we document that 85% of the metal by weight is U.S. melted and poured, or smelted and cast?10% instead of 25% on an Annex I-B part.
Is the part going into equipment that is on Annex I-C, or Annex III?The reduced tier is tied to the equipment the part is imported for.

None of the documents reviewed says how a finished, upfitted truck is entered. That is a customs-broker question, and the answer can differ from the answer for the parts that go into it.

Sources: Proclamation 11021, April 2, 2026 (Federal Register); Proclamation 11032, June 1, 2026 (Federal Register), Annexes I-B, I-C and IV; Presidential proclamation on imports of medium- and heavy-duty trucks and parts, October 2025, clauses (1), (3) and (9); CBP guidance on the MHDV tariff, November 2025.

About the author

Alex Harlan

Alex Harlan edits Cab to Axle and writes about the vocational truck trade: bodies, upfits, chassis and the shops that build them.

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