There is no single Section 232 rule. Each proclamation states its own drawback treatment, and recent actions have gone in different directions. Below is where each currently stands, with the controlling Federal Register citation.
Reviewed by Anthony Nogueras, LCB · Licensed U.S. Customs Broker · Last updated August 2026
Duties under Section 232 of the Trade Expansion Act of 1962 were historically excluded from drawback. That exclusion was a policy choice written into each proclamation, not a bar in the Tariff Act. Because it is a policy choice, a proclamation can make the opposite choice, and recent ones have. To know whether a given Section 232 entry can be recovered, read the controlling proclamation and its effective date. Each type is broken out below.
The April 2, 2026 pharmaceutical proclamation imposed a high ad valorem duty on imported patented pharmaceuticals and active pharmaceutical ingredients, and clause (10) states in plain text that drawback is available with respect to the duties it imposes. Exported pharmaceuticals and APIs, or U.S.-formulated doses shipped abroad, are strong recovery candidates through unused merchandise, manufacturing, or rejected merchandise drawback.
Affected products: patented pharmaceuticals and active pharmaceutical ingredients listed in the proclamation's Annex I. See our category guide for the covered classes.
Proclamation 2026-06956, Federal RegisterThe timber and lumber proclamation of October 2025 likewise states that drawback shall be available with respect to the duties it imposes. Importers of covered timber, lumber and their derivative products whose goods are subsequently exported can recover 99% of the duty.
Affected products: timber, lumber and derivative products enumerated in the proclamation's Annex I.
Proclamation 2025-19482, Federal RegisterSteel and aluminum duties were barred from drawback from 2018 through 2025. The April 2026 strengthening proclamation reopened a defined path: manufacturing drawback under 19 U.S.C. 1313(a) and (b) is available for qualifying steel, aluminum and copper derivative articles that are products of a Trade Agreement Partner, with the metal smelted, melted or cast in a Trade Agreement Partner, while all other drawback remains barred. The base metal duties themselves are not eligible.
Affected products: derivative articles listed in the proclamation's Annexes, including chapter 99 headings for steel and aluminum. Qualification turns on the Trade Agreement Partner and metal-origin conditions, which we confirm per classification.
Proclamation 2026-06960, Federal RegisterAutomobile parts were barred from drawback as originally issued. The October 2025 medium and heavy-duty vehicle proclamation amended the landscape so that manufacturing drawback under 19 U.S.C. 1313(a) and (b) is available on auto parts and MHDV parts, and no other drawback. The allowance is written around parts; it does not on its face reach the duties on complete assembled vehicles.
Affected products: the parts enumerated in the proclamation's Annex I, and buses under HTSUS heading 8702.
Proclamation 2025-19639, Federal RegisterThe semiconductor proclamation states that no drawback shall be available with respect to the duties it imposes, and the base metal duties under the steel and aluminum actions remain excluded. For these, drawback is not a recovery route, and the strategy shifts to classification, sourcing and exclusion analysis.
Affected products: semiconductors, semiconductor manufacturing equipment and derivative products listed in the proclamation's Annex.
Proclamation 2026-01052, Federal RegisterIt depends on the specific proclamation. Pharmaceuticals and timber and lumber are eligible. Steel, aluminum and copper derivatives and auto and heavy-vehicle parts allow manufacturing drawback only, for qualifying goods. Semiconductors and the base metal duties are not eligible. Each proclamation states its own treatment.
There is no statutory bar to drawback on Section 232 duties. Historically each proclamation wrote in a drawback exclusion as a policy choice. Recent proclamations have chosen differently, so eligibility now varies by the controlling action and its effective date.
For steel, aluminum and copper derivatives and for auto and heavy-vehicle parts, the proclamations allow only manufacturing drawback under 19 U.S.C. 1313(a) and (b), for qualifying goods, and bar all other drawback. That covers imported inputs used to make a different article that is then exported.
Yes. The April 2, 2026 pharmaceutical proclamation states that drawback shall be available with respect to the duties it imposes. At the proclamation's high duty rate, exported pharmaceuticals and ingredients are strong recovery candidates.
All tariffs at a glance.
Section 232 in context with 301, 122 and the overruled IEEPA duties.
Back to tariff refunds Tariff cheat sheetThe route for metals and parts.
How imported inputs used in U.S. production are recovered on export under 1313(a) and (b).
Manufacturing drawbackSize your recovery.
We confirm which of your Section 232 entries qualify, and by which method.
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