Section 232 Cut to 15 Percent Leaves Several HVAC Tariff Lines at 25 Percent
The 15 percent rate took effect June 8 and runs through Dec. 31, 2027. Air-conditioning machines without a refrigerating unit and central heating boilers remain at 25 percent.
Imports on a listed set of air-conditioning and heating tariff lines have paid a 15 percent Section 232 rate instead of 25 percent since June 8, under a proclamation President Donald Trump signed June 1. A Federal Register search through Nov. 4 found no later notice changing that treatment.
Proclamation 11032 says it covers "certain HVAC systems and components that are predominantly for residential use." Its Annex III lists window and wall units, machines with a refrigerating unit with or without a reversing valve, parts under 8415.90.80 and electric space heating apparatus (8516.29.00), along with evaporator coils and heat pump parts on the aluminum list. Those entries carry no size limit or end-use test, and neither text says how Customs will treat a commercial unit classified under the same line.
Lines That Stayed at 25 Percent
Annex I-B, the 25 percent list, keeps 8415.83.00 for air-conditioning machines not incorporating a refrigerating unit, 8415.10.30 for self-contained window or wall machines, and 8415.90.40 for chassis and cabinets. It also keeps non-electric air heaters with motor-driven fans (7322.90.00), central heating boilers (8403.10.00), heat exchange units (8419.50) and water heater parts (8419.90.10).
Holland & Knight reads the 15 percent as a ceiling on general duty plus the Section 232 tariff, with a 10 percent ceiling for goods made of U.S. metal. The proclamation loosened that test from 95 percent to 85 percent by weight, which Alex Ayers, HARDI's vice president of government affairs, said would help "many of the product categories not included in the new HVAC exemption," according to Contracting Business.
"HARDI's initial analysis shows the adjustment will help consumers keep nearly $2.3 billion in their pockets," Ayers said in a June 2 statement. The figure is the distributor group's own estimate.
Later Actions Touch the Edges
Commerce proposed Aug. 6 to add parts of heat exchange units (8419.90.3000) to the tariffs at 25 percent. Comments closed Aug. 27, and no final notice has appeared. Section 301 duties of 10 percent to 12.5 percent that began July 24 exempt goods already under Section 232, ACHR News reported.
Why This Matters to Contractors
The Annex III note ties the reduction to Dec. 31, 2027, about 14 months away, which puts the expiration inside the term of any multiyear equipment pricing signed now. ACCA said in June it wanted all HVAC equipment exempted, a request the June proclamation did not grant.
Sources
- The White House, Proclamation 11032, "Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States," Federal Register, June 4, 2026. govinfo.gov
- Proclamation 11032 with annexes, public inspection copy, Federal Register Doc. 2026-11314. federalregister.gov
- Bureau of Industry and Security, "Request for Public Comments on the Proposed Implementation of Duties on Additional Aluminum, Steel, and Copper Derivative Articles Under Section 232," Aug. 6, 2026. federalregister.gov
- Holland & Knight, "Annexed Opportunity: Proclamation Provides a Targeted Reduction of Section 232 Tariffs," June 4, 2026. hklaw.com
- HARDI, "HARDI Applauds Trump Administration Action to Reduce Tariff Pressure on Residential HVAC Equipment," June 2, 2026. hardinet.org
- Contracting Business, "HVAC Equipment Gets a Break as Section 232 Tariffs Are Revised," June 4, 2026. contractingbusiness.com
- ACHR News, "New Tariffs Could Increase HVAC Equipment and Components Costs," July 29, 2026. achrnews.com