The Trump administration has made the America First Trade Policy a priority, creating both opportunities and challenges for metalcasters. In April, President Trump declared a national emergency with regard to imbalanced and nonreciprocal trade that has consistently disadvantaged the American economy. Consequently, the president issued an executive order that imposes sweeping “reciprocal” tariffs of at least 10% varying by country. The reciprocal tariffs have had sweeping impact on supply chains but also created opportunities for metalcasters to regain lost market share domestically. There have been multiple challenges to the reciprocal tariffs in court. At the time of publication, the Supreme Court recently completed oral arguments regarding the legality of the reciprocal tariffs but had not yet ruled regarding whether the International Emergency Economic Powers Act can be used to impose tariffs on an emergency basis. 

On the trade policy front, the reciprocal tariffs have served as a starting point for negotiations with different countries to rebalance U.S. trade. As a result, there have been frequent updates and modifications to the reciprocal tariffs. Over the summer, framework agreements with lower reciprocal tariff rates were announced for the European Union, United Kingdom, and Japan as agreements were reached. Conversely, negotiations with India and Brazil have stalled with the Trump administration adjusting the reciprocal tariffs for both countries to 50%. While the tariffs for India were imposed based upon purchases of Russian oil, negotiations remain ongoing and a lower tariff rate for India is likely in 2026. More recently, framework trade agreements with Thailand, Malaysia, Cambodia, and Vietnam were announced in late October. Notably, the agreements include cooperation on forced labor and combatting transshipment from China. Details have not been released officially yet but reports regarding the Vietnam agreement indicate that transshipment will result in an additional 40% tariff. 

The China Question

Regarding China, a recent trade deal was reached to ease supply chain concerns. In return for China suspending export controls on critical minerals, resuming purchases of U.S. agricultural products, and adopting other measures, the Trump administration delayed implementation of reciprocal tariff rates for one year. As a result, the reciprocal tariff rate for China is 10% as of Nov. 10. Additionally, in light of Section 301 duties of 25%, many products imported from China are assessed a combined rate of 35%. Given that reciprocal tariff rates for China are lower than many other countries, we will anticipate seeing an increase of dumping in the U.S. market by Chinese companies in 2026. 

The Trump administration has also made national security a focus with a dozen Section 232 national security tariff investigations and a ramping up of enforcement of tariffs, export controls, and sanctions. In comparison to the reciprocal tariffs, which are by country and relatively fluid, the Section 232 national security tariffs are by industry and designed to be more stable. The first Trump administration started 25% tariffs on steel and 10% tariffs on aluminum in 2018 on all imports. In June this year, his administration doubled the tariff to 50% for all imports of both steel and aluminum products. 

Additionally, the first Trump administration created a formal process by which companies could request to be excluded from the Section 232 tariffs for imports of steel and aluminum. As part of the America First Trade Policy, all Section 232 exemptions were ended in March and the exclusion request process ended. Instead, when Section 232 national security investigations are completed and tariffs are implemented, the Bureau of Industry and Security (BIS) is also creating an inclusion process for derivative products of the investigation—namely products that are part of the industry but not covered by the tariffs. While the details differ slightly for each industry, there is a window several times a year to request that the Section 232 tariffs be extended to include an additional product. The result is that the Section 232 tariffs can expand as necessary over time to combat circumvention or changes in trade patterns. 

Currently, there are Section 232 tariffs on (1) Steel/Aluminum (50%); (2) Automobiles (25%); (3) Copper (50%); and (4) Medium/Heavy Duty Trucks (25%). The first inclusion request window for steel/aluminum was in May with a second window in September. The Autos Section 232 tariffs held its first inclusion request window in October. BIS has not yet formally announced the windows for the Copper or Trucks Section 232 tariffs likely due to the government shutdown.

Seize the Moment 

The next window for filing an inclusion request is January for both Automobiles and Steel/Aluminum and is a prime opportunity for metalcasters. The information requested by BIS in the inclusion requests is relatively straightforward with one exception—explaining how a tariff will help improve U.S. national security. The Department of Defense did, however, list castings and forgings as one of four areas where there was a pressing threat to national security, indicating that BIS will likely take a favorable view towards inclusion requests from metalcasters. Typically, BIS decides on inclusion requests within 60 to 90 days. The first round of the inclusion process resulted in over 400 products being approved for the 50% Section 232 steel and aluminum tariffs, including inclusion requests from several AFS member metalcasters.

There are also several other Section 232 investigations under way for industries ranging from critical minerals to drones. One Section 232 investigation that may present a challenge for metalcasters in 2026 is the Robots and Machinery Section 232 investigation, which started in September. This investigation will likely result in tariffs on covered CNC machines, machine tools, and metalworking equipment. While metalcasting is not mentioned specifically, it is not difficult to imagine the Section 232 investigation including metal casting equipment either when tariffs are initially imposed or in the future under the inclusion process. 

Generally, national security investigations conducted under Section 232 of the Trade Expansion Act require BIS to reach its determination within 270 days. At the conclusion of the investigation, BIS will report its findings to the president on whether imports of robots and machinery into the U.S. threaten national security and whether tariffs are warranted. Given the investigation started in September, the report will be due to the president by July at the latest, although currently Section 232 investigations are being completed sooner. 

DOJ Focuses on Enforcement 

The Department of Justice (DOJ) has also announced that trade enforcement is a high priority. On Aug. 29, the department announced a new Trade Fraud Task Force that would work with Customs and the Department of Homeland Security to pursue both civil and criminal charges for trade fraud. Acting Assistant Attorney General Matthew R. Galeotti explained while announcing the task force that “For years, nefarious importers and their co-conspirators have put law-abiding businesses in the United States at a competitive disadvantage—and cheated the American public of funds—by brazenly committing trade fraud.” The task force will focus on prosecuting tariff evasion techniques, such as misclassifying or undervaluing goods, as well as transshipping, or rerouting goods to a new country and relabeling the country of origin to take advantage of lower tariffs. 

Beyond the new task force, the DOJ also announced that they intend to expand the use of the False Claims Act to pursue trade violations. The False Claims Act is one of the U.S. government’s primary tools to combat fraud. Whistleblowers or attorney generals can bring cases against companies that have avoided paying tariffs to U.S. Customs. Penalties under the False Claim Act can result in triple damages but typically settle for less. Whistleblowers can be competitors or employees of companies evading tariffs and can receive between 15%–30% of money recovered by the government. 

Similar to e-Allegations, False Claims Act complaints can be filed confidentially by anyone with non-public independent knowledge of the fraud. Additionally, in July, the Ninth Circuit confirmed in Island Industries, Inc. v. Sigma Corp. that the False Claim Act penalties are separate from any revenue that Customs collects when enforcing tariffs. The DOJ has not wasted any time with several prior tariff evasion False Claim Act cases being resolved over the summer, including several where the whistleblower was a competitor. Put another way, there is nothing preventing metalcasters from pursuing a False Claim Act case to make sure that tariffs are effectively keeping U.S. markets at a level playing field. 

Trade enforcement has also resulted in a surge in antidumping and countervailing duty (AD/CVD) investigations, including for several cast products such as freight rail couplers and slag pots. Unlike the reciprocal tariffs or Section 232 investigations, AD/CVD tariffs are imposed automatically based upon the results of the investigation by the Department of Commerce and International Trade Commission. As the party requesting the investigation, the U.S. industry selects which product lines are included in the investigation to ensure the tariffs are effective. 

AD/CVD tariffs last for five years and are renewable for additional five-year periods. For 2026, more AD/CVD investigations are expected, especially in light of the lower reciprocal tariffs on imports from China and potentially lower reciprocal tariff rate on imports from India. 

In short, the America First Trade Policy is leveraging various U.S. trade policy tools to correct imbalances that place U.S. manufacturers at a disadvantage. While it is hard to predict what exact changes will happen in 2026 with reciprocal tariffs, there are many opportunities for metalcasters seeking relief from low-priced imports. For example, the Section 232 inclusion request window in January is one such opportunity. Similarly, U.S. companies that become aware of companies evading tariffs should consider filing False Claims Act complaints or e-Allegations with Customs. Finally, for companies looking for certainty, AD/CVD cases continue to provide reliable relief.