Gym Equipment Sits Outside Section 232 Metal Tariffs While Delivery Trailers Can Pay 25 Percent

Section 232 derivative tariffs changed shape on April 6, 2026, and the change now matters more for what a fitness equipment dealer buys to run the business than for the equipment it sells. Proclamation 11021 moved the metals program from a metal-content basis to the full customs value of covered goods. It also listed HTSUS 9506.91.00, the heading covering articles and equipment for general physical exercise, gymnastics or athletics, among the codes taken out of scope. Goods trailers, industrial hand trucks and welding machine parts were not taken out.

That split is easy to miss on a purchase order. A dealer importing a container of selectorized machines and a trailer for the delivery fleet now sits in two different positions under Section 232 derivative tariffs on the same entry date.

How Section 232 derivative tariffs changed in April 2026

Proclamation 11021 was signed on April 2, 2026 and published at 91 FR 18201. The Federal Register notice states that the changes apply to goods entered “on or after 12:01 a.m. eastern daylight time on April 6, 2026.” Three structural points stand out for equipment buyers.

Duties now apply to the full customs value of a covered good rather than to its steel, aluminum or copper content. The proclamation set a 50 percent rate for the articles listed in its Annex I-A and 25 percent for those in Annex I-B, with reduced rates for United Kingdom origin goods and for derivatives whose metal qualifies as smelted and cast or melted and poured in the United States, and separate treatment for the articles in its other annexes. It also ended the earlier inclusion processes and allows the Secretary of Commerce and the United States Trade Representative to add derivative products on a rolling basis.

The annexes carry the operative notes. Annex I-A states that a 50 percent ad valorem Section 232 tariff “shall apply to the full value of the following articles,” and Annex I-B states the same for 25 percent. Annex II is headed “Removed from Scope of Section 232 Steel and Aluminum Derivatives” and notes that “The following articles will not be subject to Section 232 aluminum, steel or copper tariffs.”

Those lists are not frozen at April. Proclamation 11032, signed June 1, 2026, provides at clause (1) that “the lists of products provided in Annex I-A, Annex I-B, Annex II, and Annex III of Proclamation 11021 are modified,” effective for goods entered on or after 12:01 a.m. eastern daylight time on June 8, 2026. The reissued Annex II is the list to read today.

Where fitness equipment sits under Section 232 derivative tariffs

HTSUS 9506.91.00 appears in the Annex II steel derivatives table, described there as “Articles and equipment for general physical exercise, gymnastics or athletics; parts and accessories thereof.” That is the subheading under which finished commercial strength and cardio equipment and its parts are commonly entered, though the classification of any given item is a question for the entry rather than a given. The reissued Annex II also carries three aluminum-side breakouts: 9506.91.0010 for exercise cycles, 9506.91.0020 for exercise rowing machines, and 9506.91.0030 for gymnasium or other exercise articles and equipment, parts and accessories, nesoi. Under the Annex II note, none of those articles is subject to the Section 232 metals tariffs.

Two qualifications belong on that sentence. The relief is from the Section 232 metals program only, and other trade programs can still reach the same entry, which is why FEX has covered quote validity and escalation terms on tariffed equipment orders and entry checks after the 800 dollar de minimis suspension separately. Classification also has to be right. A part entered under a chapter 84, 85 or 87 code rather than under 9506.91.00 is read against the annex that covers that code.

The dealer purchases that stayed in Annex I-B

The same annexes keep a dealer’s own operating assets inside the program at 25 percent of full value. In the reissued Annex I-B, 8716.39.00 for trailers and semi-trailers for the transport of goods and 8716.90.50 for parts for trailers and semi-trailers appear in both the steel and the aluminum table. The steel table also carries 8716.80.50 for vehicles not mechanically propelled, nesoi, and 8716.90.30 for castors other than those of heading 8302. The aluminum table carries 8716.80.5010 for industrial hand trucks and 8515.90.20 for welding machine parts and parts of apparatus.

Read with the Annex I-B note, an imported goods trailer, hand truck or welding machine part is dutiable on its full customs value rather than on its metal content. That exposure lands in a different part of the business from the product book: the delivery fleet, the warehouse and the repair bay. Dealers running their own trucks already track that fleet for federal DOT rules once a delivery vehicle crosses 10,000 pounds, and the acquisition cost of the trailer behind it now belongs in the same review.

The 14 products Commerce proposed in August 2026

The rolling additions are not theoretical. On August 6, 2026 the Bureau of Industry and Security published a request for public comments on proposed duties for 14 additional aluminum, steel and copper derivative products. The notice states that comments “may be submitted at any time but must be received by August 27, 2026,” and directs commenters to regulations.gov docket BIS-2026-0331.

Several proposed items sit closer to a dealer’s operations than to its catalog. The list includes parts of welding machines and apparatus under 8515.90.2000, free-standing floor safes under 8303.00.0000, fire extinguishers under 8424.10.0000, other trailers and semi-trailers under 8716.40.00, and mobile lifting frames on tires and straddle carriers under 8426.12.0000.

The welding entry is worth a second look, because 8515.90.20 already sits on the Annex I-B aluminum list. The notice does not state existing coverage code by code, so a dealer importing welding machine parts should put the overlap to its broker rather than try to settle it from the notice.

The notice states that these products “would generally be subject to the 25 percent tariff outlined in clause (3)” of Proclamation 11021, with separate treatment for the mobile industrial equipment, the agricultural trailers and the filled steel containers on the list. No finished fitness equipment code appears among the 14. Comments closed on August 27, 2026, so a dealer importing any of those codes should check the docket for a final determination before relying on current treatment. The point is the mechanism rather than this list: scope moves by notice and comment on a rolling basis, so relief that holds one quarter is not fixed.

Six checks before the next equipment or vehicle purchase

1. Confirm the code on the entry, not the invoice. Ask the customs broker for the HTSUS code actually used on each entry summary for the last four quarters. A supplier invoice description is not the classification that determines annex treatment. Split the lookback at June 8, 2026, because entries before and after that date were filed against different annex lists.
2. Split the product book from the asset book. List the codes the business imports under in two groups: goods for resale, and equipment bought to operate. The annex answer can differ between the two groups.
3. Read the duty basis in every supplier quote. A quote written on a metal-content basis predates the April 2026 change. Ask whether the quoted duty is calculated on full customs value and who absorbs a reclassification.
4. Ask for melt and smelt origin. The reduced rate for derivatives whose metal qualifies as smelted and cast or melted and poured in the United States depends on documentation the supplier holds, not on an assertion in an email. Proclamation 11032 provides that “The current threshold of 95 percent shall be modified to 85 percent,” measured by weight, so ask which threshold the supplier’s record was built against.
5. Watch the docket. Inclusion proposals run through the Federal Register and regulations.gov. Any interested party may file a comment, including a dealer that imports trailers, hoists, safes or shop equipment, and the comment window in the August 2026 notice ran three weeks, from August 6 to August 27, 2026.
6. Put a scope-change clause in long-lead orders. For orders delivering a quarter or more out, agree in writing what happens to price if the code is added to or removed from an annex between order and entry.

A worked example, with stated assumptions

The figures below show how Section 232 derivative tariffs can land on two entries in the same week. They are illustrative assumptions, not industry data and not a quotation from any supplier.

Assume a dealer imports one trailer for the delivery fleet at a declared customs value of 38,000 dollars, classified under 8716.39.00, and one container of strength equipment at a declared customs value of 210,000 dollars, classified under 9506.91.00. Applying the Annex I-B rate of 25 percent to the trailer’s full customs value gives a Section 232 duty of 9,500 dollars. Applying the Annex II treatment to the equipment gives no Section 232 metals duty on that entry.

The full-value basis is what makes the trailer figure what it is. If the same 25 percent were applied instead to an assumed steel content of 60 percent of value, the result would be 5,700 dollars. The 3,800 dollar difference between those two illustrative calculations falls in the fleet budget, which is not usually where a dealer’s tariff review looks. Rising metal input prices compound the same line, as the FEX review of steel mill producer prices and quote validity sets out.

Records and metrics to review

• Entry summaries for the last four quarters from the customs broker, grouped by HTSUS code rather than by supplier.
• A single list of every code the business imports under, flagged as resale goods or operating asset.
• Origin and melt or smelt documentation held by suppliers for each derivative purchase.
• Open purchase orders with delivery dates beyond the next quarter, and the duty language in each.
• Landed cost per unit recalculated on a full-value duty basis, compared with the figure in the current price file.
• Capital purchase requests for trailers, lifts, shop equipment and safes scheduled for the next four quarters.

Warning signs and common mistakes

• A landed cost model that still applies duty to an estimated metal percentage.
• Treating an Annex II listing as permanent relief rather than as current scope, when the Annex II list was itself modified in June 2026.
• Reviewing tariff exposure only for cost of goods, leaving fleet and shop purchases unexamined.
• Accepting a supplier statement of United States melt or smelt origin without the supporting record.
• Assuming a part shares the treatment of the machine it belongs to, when it is entered under a different chapter.

Common questions

Does the Annex II listing mean gym equipment imports are duty free?

No. Annex II states only that the listed articles “will not be subject to Section 232 aluminum, steel or copper tariffs.” Ordinary duty rates and any other applicable trade program still apply to the entry, and a dealer should confirm the full duty picture with its broker.

Can a code be moved back into scope later?

Proclamation 11021 ended the earlier inclusion processes and allows derivative products to be added on a rolling basis by the Secretary of Commerce and the United States Trade Representative. Changes of that kind generally appear in the Federal Register, which is where a dealer can see them before an entry is filed. Proclamation 11032 modified all four of those product lists in June 2026.

The practical move is small: pull the code list, mark each code as resale or operating asset, and check the annex each one sits in. A dealer who knows which side of the line Section 232 derivative tariffs put a purchase on can quote it, budget it and argue it. One who does not will meet the answer on a broker’s invoice.