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Tariffs have tightened, untightened, and will continue to evolve as the Trump administration navigates global negotiations.
Whew... There's still A LOT to unpack here, so hold on for the roller coaster ride.
A little background on where all of this started and what it means. Tariffs are duties placed on foreign goods, paid by domestic importers to Customs and Border Patrol at ports of entry. President Trump introduced tariffs on select Chinese goods in his first term back in 2018, which President Joe Biden later maintained, along with duties on steel and aluminum from most countries. In February of 2025, Trump reinstated tariffs—10% more on Chinese imports, bringing them to 35%, and 25% on Mexican and Canadian goods (except for oil, taxed at 10%).
As of April 8th, 2026, at 11 am EST, here's what we're seeing. On April 2nd, Trump signed a new proclamation that took effect on April 6th to ultimately counter the February 20, 2026, Supreme Court ruling that stated that tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded presidential authority. The Court determined that IEEPA does not grant the executive branch the power to impose broad tariffs, reaffirming that tariff authority primarily resides with Congress. The Trump administration imposed a brief 10% Section 122 tariff after this ruling, which has now been replaced by the following. Please refer to our March Metal Market Update for more information on the Supreme Court ruling and what has transpired since then.
1 - Section 232 tariff calculation methodology has been overhauled. Tariffs now apply to the full customs value of imported steel, aluminum, and copper products, rather than just the metal portion. This is a major shift from prior methodology.
2 - New tiered rate structure:
Articles made entirely or almost entirely of steel, aluminum, or copper pay a flat 50% on their full value (e.g., steel coils, aluminum sheet). Derivative articles substantially made of these metals pay a flat 25% on their full value. Certain metal-intensive industrial equipment and electrical grid equipment pay 15% through 2027. Products manufactured abroad using 100% U.S.-origin metals are subject to a reduced 10%.
Products containing 15% or less of steel, aluminum, or copper by value are no longer subject to Section 232 tariffs at all.
3 - Copper added to Section 232. In July 2025, President Trump issued a proclamation adding copper to the Section 232 tariffs program at the same 50% rate as steel and aluminum. This is now fully baked into the new framework.
4 - The Section 122 "150-day clock" discussed above and from our March newsletter has been effectively bypassed. The administration has now re-anchored these tariffs to Section 232, which is more legally durable in the long term.
How Does This Affect Imported Pressure Vessels and Heat Exchangers?
Per our understanding, pressure vessels and heat exchangers are fabricated equipment classified under HTS Chapter 84 (industrial machinery), not Chapters 72–76 (raw steel mill products). This distinction matters significantly under the April 6th Section 232 overhaul.
For aluminum heat exchangers, the picture is clear. HTS subheadings 8419.50.10 and 8419.50.50 are explicitly listed as aluminum derivative articles in the April 6th proclamation, meaning imported finished aluminum heat exchangers are subject to a 25% tariff on the full customs value of the unit — not just the metal content. On a $500,000 imported aluminum heat exchanger, the tariff base is the full $500,000.
For stainless steel, alloy, and carbon steel heat exchangers, and for pressure vessels of any material, the situation is less settled. These products typically classify under HTS 8419.50.50 and 8419.89, respectively, neither of which appears in the steel derivatives section of the April 6th annexes. This creates a genuine gray area because imported finished steel heat exchangers and pressure vessels may not currently be explicitly covered by the Section 232 derivative tariff on the finished unit.
It is also worth noting what the Annex language does, and does not, say about tanks and vessels under Chapter 73. Two codes are listed under Annex I-A at the 50% rate:
- HTS 7309.00.00 — "Iron or steel, reservoirs, tanks, vats, similar containers for any material (other than compressed or liquefied gas), with a capacity exceeding 300 l, whether or not lined or heat-insulated, but not fitted with mechanical or thermal equipment".
- HTS 7311.00.00 — "Iron or steel, containers for compressed or liquefied gas".
While these codes may appear to cover pressure vessels and storage vessels at first glance, the critical limitation in 7309 is the phrase "not fitted with mechanical or thermal equipment." A fabricated ASME pressure vessel with nozzles, instrumentation, internals, and process connections would almost certainly not qualify under this language. Similarly, neither code uses the word "vessel" at all, and a purpose-engineered ASME Code vessel is fundamentally different from a simple storage tank or container. The customs classification of fabricated pressure equipment under Chapter 73 versus Chapter 84 is a fact-specific determination, and Chapter 84 typically governs process equipment of this nature.
- What is unambiguous for all product types is that the raw material inputs (i.e. stainless plate, carbon steel plate, seamless and welded tubing, and pipe fittings) are covered at the full 50% rate under Annex I-A, regardless of how the finished equipment is ultimately classified.
As manufacturers of pressure vessels and heat exchangers, we need to continue engaging with our elected officials to ensure that protection is in place for us, manufacturers of steel products, not just for our domestic suppliers.
How does this affect your pricing for pressure vessels and heat exchangers?
At Ward, we purchase 80-90% domestically, depending upon the project. This means our total material spend has increased by approximately 5-15% since the tariffs were enacted, resulting in a 3-10% overall unit price increase after labor is factored in. We are doing our part to support American manufacturing while keeping our pricing as competitive as possible.
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