Quarterly Trade Update Now Available

AWPA Trade Policy Update: U.S.-Canada Tensions, Section 301 Tariffs and Customs Enforcement Reshape Trade Landscape

September 2026

The trade policy environment affecting North American wire producers continues to shift, with significant developments involving Section 232 metals tariffs, new Section 301 actions, U.S.-Canada trade relations, the USMCA review, and increased customs enforcement. These developments continue to have important implications for steel and wire producers navigating raw material costs, supply chains, imports, and North American trade.

AWPA’s latest Quarterly Trade Policy Report, prepared by Kelley Drye & Warren LLP, provides a comprehensive review of the major federal trade actions and negotiations currently affecting manufacturers throughout the steel wire supply chain.

Key Developments This Quarter

Section 232 Metals Tariffs Continue to Evolve

The Administration continues to use Section 232 as a central trade policy tool. The current tariff structure includes a 50 percent tariff on the full entered value of articles made entirely or almost entirely of steel, aluminum, or copper, as well as a 25 percent tariff on certain derivative articles.

The process for determining which downstream products are subject to Section 232 tariffs also remains active. The Commerce Department requested comments in August on adding 14 additional derivative articles, while a new formal process for future derivative inclusions may be developed in 2027.

For AWPA members, continued changes to derivative coverage remain particularly important as the scope of Section 232 tariffs expands further into downstream manufactured products.

New Section 301 Tariffs Take Effect

The Office of the U.S. Trade Representative has moved from investigation to action on forced labor, imposing new Section 301 tariffs of 10 or 12.5 percent on imports from 60 economies. Products already subject to Section 232 tariffs are among those exempt from the new forced labor tariffs.

At the same time, USTR’s separate Section 301 investigations into structural industrial overcapacity remain underway. Those investigations cover 16 major trading partners and a broad range of manufacturing sectors, including steel and aluminum. AWPA submitted comments earlier this year as part of that process.

Additional remedies resulting from the overcapacity investigations could have significant implications for future tariff levels and international competition.

U.S.-Canada Trade Tensions Escalate

U.S.-Canada trade relations have become an increasingly important issue for the wire industry. In August, the United States imposed 50 percent tariffs under Section 338 on certain Canadian imports following unsuccessful negotiations between the two countries.

Canada responded with counter-tariffs effective September 8 on $27.6 billion in U.S. imports, with rates of 15, 25, or 50 percent depending on the product.

Section 232 steel and aluminum tariffs remain a major point of discussion between the two countries. Negotiations reportedly came close to producing an agreement that would have provided some tariff relief for Canadian steel and aluminum before talks broke down in August.

USMCA Moves Into Annual Reviews

The first six-year Joint Review of the United States-Mexico-Canada Agreement took place July 1. The United States did not agree to renew the agreement in its current form, triggering annual reviews while USMCA remains in force.

The United States continues separate negotiations with Mexico and Canada, with issues involving North American manufacturing, rules of origin, steel and aluminum, supply chains, and third-country investment among the areas under discussion.

For AWPA members, the relationship between USMCA negotiations and Section 232 steel and aluminum tariffs will remain an important area to watch.

Customs Enforcement Becomes a Growing Compliance Issue

Customs enforcement is also receiving increased attention. A June Executive Order directed stronger oversight of importers of record, and U.S. Customs and Border Protection has begun implementing enhanced procedures to verify importer information.

CBP is also considering significantly expanded supply-chain disclosure requirements. If ultimately adopted, these changes could increase recordkeeping, disclosure, and due diligence responsibilities for importers and involve functions well beyond traditional customs departments.

Members involved in importing should continue to monitor these developments and review the accuracy and completeness of their importer information.

Trade Enforcement Legislation Remains in Focus

Trade enforcement also continues to receive attention in Congress. AWPA recently joined a multi-organization letter supporting stronger customs enforcement and highlighting four bipartisan proposals: the Fighting Trade Cheats Act, the Strengthening Trade Enforcement and Evasion Limitations (STEEL) Act, the Leveling the Playing Field 2.0 Act, and the Protecting American Industry and Labor from International Trade Crimes (PAIL) Act.

The PAIL Act recently passed the House, with AWPA issuing a statement of support for the legislation.

AWPA’s Ongoing Commitment

Trade policy remains one of the most important issues facing the wire industry. As part of AWPA’s strategic focus on advocacy and industry representation, the association continues to monitor policy developments, engage with policymakers, participate in federal trade proceedings, and provide members with timely information and analysis.

AWPA will continue to advocate for policies that support a competitive and resilient North American wire industry while keeping members informed of developments that may impact their businesses.

Read the full Quarterly Trade Policy Report prepared by Kelley Drye & Warren LLP by clicking the link here.