When analyzing the aggressive trade policies of 2026, it is easy to get distracted by the headline-grabbing 50% and 100% tariff rates. But for trade compliance professionals and supply chain managers, the real shockwaves this year have come from how those tariffs are being applied.
The administration has systematically targeted the loopholes that importers have historically used to shield themselves from duties. Two major enforcement shifts define this new era: the Section 232 “Full Value Rule” and the controversial overriding of USMCA exemptions.
The “Full Value Rule”: Changing the Math on Metals
Since 2018, Section 232 tariffs on steel and aluminum have been a headache for importers. However, there was always a critical workaround for “derivative” products (goods made partially from these metals, like hinges, handles, or construction brackets): importers were largely assessed based on the value of the metal content itself.
That all changed in the spring and summer of 2026. Through a series of Presidential Proclamations, the administration introduced what the industry now calls the Full Value Rule.
Under this new framework, if an imported derivative article is made entirely, almost entirely, or substantially of steel or aluminum, the heavy 50% or 25% Section 232 tariff rate is applied to the entire customs value of the finished product—not just the raw metal component.
The Real-World Impact: Imagine a specialized stainless steel glass hinge that costs $100 to manufacture. Previously, you might have only paid a tariff on the $15 worth of raw steel inside it. Today, the 50% rate applies to the full $100. AsSingular Glass Hardwarenoted in their recent pricing breakdown, “the full-value rule matters more than the headline rate.”
The USMCA Crackdown: Bypassing Free Trade
The second massive loophole the administration slammed shut involves the United States-Mexico-Canada Agreement (USMCA). Traditionally, if a product satisfied the USMCA’s strict “rules of origin” (meaning it was legitimately manufactured in North America), it could cross the border duty-free.
However, the administration has weaponized Section 338 to aggressively bypass these free-trade protections.
When the sweeping 50% tariffs on Canadian goods took effect on August 22, 2026, U.S. Customs and Border Protection (CBP) issued strict guidance confirming the worst fears of cross-border manufacturers: USMCA origin does not protect a listed product from the surcharge.
As detailed by Thompson Hine, even if a Canadian good satisfies the USMCA rules and would otherwise enter at a zero-percent preferential rate, it will still incur the 50% Section 338 duty if its Harmonized Tariff Schedule (HTS) classification is on the administration’s hit list.
This maneuver effectively nullifies the core benefit of the USMCA for thousands of products, signaling that the administration views trade enforcement as superseding established regional treaties. With the formal joint review of the USMCA having begun in July 2026, these aggressive unilateral moves suggest the administration is willing to tear up the 30-year foundation of North American economic integration if its demands aren’t met.
Source: Real-world breakdowns of how the “Full Value Rule” changes pricing structures for importers, as detailed by Singular Glass Hardware