UAS Section 232 Tariffs: 100% and 25% Start September 3, 2026

Trade remedies5 min read

Executive Summary

The August 13 proclamation sets 100% duties for specified unmanned aircraft systems, docking stations and components, and 25% duties for listed aircraft at or below 25 kilograms without thermal imaging, beginning September 3, 2026.

For Annex I and Annex II goods, the entry-for-consumption or warehouse-withdrawal date controls. Annex III components receive a 25% duty starting February 9, 2027, unless a qualifying lower rate applies.

Country rate caps depend on where the goods are products of and certification that substantially all critical components and technology come from specified jurisdictions. A Commerce onshoring program is directed, but plan approval and implementation procedures remain to be established.

Annex IV states a February 9, 2026 effective date for a component provision, while the proclamation sets February 9, 2027 for Annex III duties. Importers should not assume the inconsistency is resolved.

UAS Section 232 tariffs begin September 3, 2026, at 100% or 25% for listed aircraft, docking stations and components. The August 13 proclamation applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on that date. A separate 25% duty for listed components starts February 9, 2027, subject to the proclamation’s country and onshoring provisions.

Which UAS Face the 100% Section 232 Duty?

The Annex I list covers unmanned aircraft with a maximum take-off weight over 25 kilograms, and aircraft with thermal imaging, including aircraft at or below 25 kilograms. The listed codes include 8806.24.00, 8806.29.00, 8806.94.00 and 8806.99.00 for aircraft over 25 kilograms, plus specified lower-weight aircraft codes marked for thermal imaging. Annex I says the 100% duty applies to the full value of covered articles.

The list also reaches specified docking-station equipment, including static converters and electrical control boards for use in UAS. Listed aircraft parts under headings 8807.10, 8807.20, 8807.30 and 8807.90 are covered only when they are parts for listed UAS over 25 kilograms. That parts coverage excludes parts for systems for retail delivery use, agricultural use, or sale to the Department of War. Check the scope note as well as the tariff classification: Annex I says its product descriptions are informational and do not independently delimit the action.

Which UAS Receive the 25% Duty?

The Annex II list covers listed remote-controlled and non-remote-controlled aircraft with maximum take-off weight of 25 kilograms or less, when they do not have thermal imaging. Its listed codes are 8806.21.00, 8806.22.00, 8806.23.00, 8806.91.00, 8806.92.00 and 8806.93.00. The 25% duty applies to the full value of the listed aircraft.

The Annex III list separately covers listed aircraft parts for use in UAS, including propellers and rotors, undercarriages and other aircraft parts. Its 25% duty begins February 9, 2027. If an article falls under both Annex I and Annex III, Annex III expressly says only the Annex I rate applies. The proclamation also says the duties apply in addition to other applicable duties, taxes, fees and charges unless it provides otherwise.

Can UAS Qualify for a Lower Country Rate?

The proclamation caps the duty rate at 15% for products of Japan, the Republic of Korea, Taiwan, Switzerland, Liechtenstein or a European Union member nation, including any Column 1 duty. For products of the United Kingdom, the cap is 10%. These rates apply only if importers certify that substantially all critical components and technology are products of the United States or the specified partner jurisdictions.

The Commerce Secretary must establish a process to decide which products qualify and inform CBP of qualifying products. Do not treat country of origin alone as enough to claim the cap. The proclamation also authorizes a program for companies building new U.S. facilities: approved plans can allow imports of covered products and necessary production equipment, in volumes commensurate with anticipated annual facility output, without applicable Section 232 duties while the facility is under construction. The Secretary is directed to establish the program; the proclamation does not itself provide the application procedures.

When Do the UAS Tariff Dates Apply?

  • August 13, 2026: The President signed the proclamation.
  • September 2, 2026: The date used to identify companies on the DoW Blue UAS Cleared List, the Blue UAS Framework, or the FCC Conditional Approval List for the delayed treatment described in clause 7.
  • September 3, 2026, at 12:01 a.m. eastern time: The 100% Annex I and 25% Annex II duties begin for covered entries, unless a qualifying exception applies.
  • February 9, 2027: The proclamation sets this date for the 25% Annex III component duty. It also provides a 180-day delay for specified products of listed companies, measured from the proclamation date.
  • Before January 20, 2029: An onshoring plan must commit to construction occurring before this date.
  • Within 120 days of August 13, 2026: The Secretary must provide an update to the President.

What Should UAS Importers Check Before Entry?

Classify the complete article. Match aircraft weight, flight type and thermal-imaging capability to the annex descriptions and HTSUS provisions. Separately identify docking-station equipment and parts, including the intended UAS use and any Annex I parts exclusion.

Confirm the entry date. Identify whether goods will be entered for consumption or withdrawn from warehouse for consumption before or after the applicable effective time. The proclamation makes that date the trigger for the duties.

Substantiate any lower rate. Check product origin and gather support for the certification concerning substantially all critical components and technology. Do not claim a partner-country cap until the Secretary’s qualifying process and CBP identification requirements are clear.

Review special inventory and programs. Check whether a product falls under the delayed treatment for a company on a specified list as of September 2, 2026, and whether an approved onshoring plan applies. For goods entering a foreign-trade zone on or after the effective date, the proclamation generally requires privileged foreign status unless domestic status is available.

What UAS Tariff Details Remain Unclear?

The proclamation’s clause 2 sets the Annex III duty date as February 9, 2027, and describes it as 180 days from the August 13 proclamation. But Annex IV’s second part states that its component provision is effective February 9, 2026, a date before the proclamation, and describes changes to the tariff headings for components. The instruments do not explain how to reconcile those dates. Importers should obtain current entry instructions before declaring affected components, rather than assume which date controls.

The proclamation also leaves the partner-rate qualification process and the Commerce onshoring application process for later action. It authorizes further components to be added by the Secretary through a Federal Register notice, but does not identify future additions.

Sources

This publication is for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. Reading it does not create, and receipt of it does not constitute, an attorney-client relationship. Readers should not act on this information without seeking advice from qualified counsel. The views expressed are those of this site and its owner as of the date of publication. Although we try to keep this content complete, accurate and up to date, we assume no responsibility for its completeness, accuracy or timeliness.

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