There is an existing Executive Order from the first Trump Administration that authorizes the Treasury Department to identify target persons and businesses as Specially Designated Nationals (SDNs) when the Secretary finds that the targets operate in certain sectors of the Iranian economy. This has traditionally included construction, mining, manufacturing, and textiles.

In a new order, the Treasury Department is adding aviation to the list of affected sectors. The new order is expected to be published in the Federal Register, tomorrow.

“I hereby determine that section 1(a)(i) of E.O. 13902 shall apply to the aviation, digital asset, gold, shipping, and technology sectors of the Iranian economy. Any person determined to operate in these sectors shall be subject to sanctions pursuant to section 1(a)(i).”

Publication of a Determination Issued Pursuant to Executive Order 13902, Federal Register (August 27, 2026).

This does not automatically impose sanctions – instead it authorizes the Secretary of the Treasury to add people and/or businesses ot the list of Specially Designated Nationals. It is typically illegal to export goods to Iran without a license, so naming Iranians as SDNs may have relatively little practical effect for American businesses. This new determination will authorize the Secretary to name SDNs from other countries who participate in the Iranian economy, and this could allow an expansion of sanctions to include more people and more companies from third countries who are doing business with Iran, especially those supporting the Iranian aviation industry.

When a person is named as an SDN, that person (and that person’s property) is blocked. This typically prevents all transactions with the blocked person. This is not just export transactions – the SDN sanctions programs typically apply to any other sort of transactions as well. Someone in the U.S. who is holding the blocked person’s property must retain that property and must file periodic reports with the Treasury notifying them of the blocked property that is held.

We expect to see more aviation companies being added to the Treasury sanctions lists as SDNs. This action highlights the importance of checking your export business partners against the US sanctions lists on every transaction.

The U.S. section 338 tariffs on products of Canada were originally announced in Proclamation 11046, Proclamation 11047, and Proclamation 11048 and then formally announced in the Federal Register. Implementation was delayed until August 19, 2026 and then delayed again for three more days, until August 22.

The good news for the aviation industry is that articles subject to the Agreement on Trade in Civil Aircraft are excluded from this tariff, under operative clause two of each of the three proclamations. This does NOT exempt ALL aircraft parts – aircraft parts that are not protected under the Agreement on Trade in Civil Aircraft (such as fasteners) may be subject to the additional tariffs on products of Canada; if you examine the list of affected products, though, you will see that most aviation articles excluded from the Agreement on Trade in Civil Aircraft are also left off of the list of affected goods (a few things – like textiles, hand tools and certain navigational equipment, may be covered by the Canadian tariffs but outside of the protections of the Agreement on Trade in Civil Aircraft).

Canada has announced its own tariffs on U.S. goods. Most aircraft parts seem to be outside of the scope of the Canadian tariffs, but certain products, like pumps and air conditioning machines, may be subject to the Canadian tariffs. It is therefore important for any Canadian importer to run the tariff codes for their imported U.S. goods through the table of reciprocal Canadian tariff information to ensure you are paying the right tariffs on your imports of U.S. goods.

This advisory circular explains to a U.S.-based repair station how to apply for EASA-145 credentials. The advisory circular is based on the provisions of the FAA-EASA Maintenance Annex Guidance (MAG). Therefore, if the advisory circular is cancelled, the industry can still rely on the instructions found in the Maintenance Annex Guidance.

The FAA has identified four reasons for proposing to cancel AC 145-11A:

1. Redundancy and Risk of Inconsistency: In most instances where substantive guidance is provided, the advisory circular references the Maintenance Annex Guidance which means that the AC 145-11A is imply duplicative.   Maintaining both documents creates the potential for inconsistency, confusion, and misinterpretation, which could undermine the effective implementation of the bilateral agreement.

2. Resource Efficiency: FAA resources are better directed toward the timely update of the Maintenance Annex Guidance rather than maintaining a separate AC that is slower to revise and more likely to become outdated.

3. International Harmonization: Reliance on the Maintenance Annex Guidance as the single source of guidance promotes greater clarity, consistency, and harmonization for certificate holders operating under the agreement.

4. Obsolescence: AC 145-11A currently contains obsolete content. The Maintenance Annex Guidance is updated frequently and keeping the advisory circular current is difficult.

ASA is currently leaning toward support of the FAA’s position. If you have a reason for maintaining the separate Advisory Circular (AC) 145-11A, or if you have any comments about the FAA’s plans, then please the Association know by August 17, 2026.

The good news for aviation is that there is a specific aviation exception for certain civil aircraft parts. Details about which aircraft parts are covered are included below, but there will certainly be some parts – like certain fasteners – that do not benefit from the exception and that will be subject to import duties.

The affected source countries and jurisdictions are as follows:

Many aviation products will be excluded from these new chapter 99 tariffs. Those aircraft parts that are excluded should be declared under tariff code 9903.05.88. This is the tariff code that excludes civil aircraft parts from the newest Chapter 99 tariffs.

Normally aircraft parts that are exempt from duties under the Agreement on Trade in Civil Aircraft are identified with a “C” in the “special” column of the Harmonized Tariff Schedule of the United States (HTSUS). That is not the rule for the tariff code 9903.05.88 exception. Instead, in order to benefit from tariff code 9903.05.88, the base tariff code for the article must be in this list (the master version of this list can be found in Chapter 99, subchapter III, U.S. note 52, subdivision (d)):

3917.21.00 3917.22.00 3917.23.00 3917.29.00 3917.31.00 3917.33.00
3917.39.00 3917.40.00 3926.90.45 3926.90.94 3926.90.96 3926.90.99
4008.29.20 4009.12.00 4009.22.00 4009.32.00 4009.42.00 4011.30.00
4012.13.00 4012.20.10 4016.10.00 4016.93.50 4016.99.35 4016.99.60
4017.00.00 4504.90.00 4823.90.10 4823.90.20 4823.90.31 4823.90.40
4823.90.50 4823.90.60 4823.90.67 4823.90.70 4823.90.80 4823.90.86
6812.80.90 6812.99.10 6812.99.20 6812.99.90 6813.20.00 6813.81.00
6813.89.00 7007.21.11 7304.31.30 7304.31.60 7304.39.00 7304.41.30
7304.41.60 7304.49.00 7304.51.10 7304.51.50 7304.59.10 7304.59.20
7304.59.60 7304.59.80 7304.90.10 7304.90.30 7304.90.50 7304.90.70
7306.30.10 7306.30.30 7306.30.50 7306.40.10 7306.40.50 7306.50.10
7306.50.30 7306.50.50 7306.61.10 7306.61.30 7306.61.50 7306.61.70
7306.69.10 7306.69.30 7306.69.50 7306.69.70 7312.10.05 7312.10.10
7312.10.20 7312.10.30 7312.10.50 7312.10.60 7312.10.70 7312.10.80
7312.10.90 7312.90.00 7322.90.00 7324.10.00 7324.90.00 7326.20.00
7413.00.90 7608.10.00 7608.20.00 8302.10.60 8302.10.90 8302.20.00
8302.42.30 8302.42.60 8302.49.40 8302.49.60 8302.49.80 8302.60.30
8307.10.30 8307.90.30 8407.10.00 8408.90.90 8409.10.00 8411.11.40
8411.11.80 8411.12.40 8411.12.80 8411.21.40 8411.21.80 8411.22.40
8411.22.80 8411.81.40 8411.82.40 8411.91.10 8411.91.90 8411.99.10
8411.99.90 8412.10.00 8412.21.00 8412.29.40 8412.29.80 8412.31.00
8412.39.00 8412.80.10 8412.80.90 8412.90.90 8413.19.00 8413.20.00
8413.30.10 8413.30.90 8413.50.00 8413.60.00 8413.70.10 8413.70.20
8413.81.00 8413.91.10 8413.91.20 8413.91.90 8414.10.00 8414.20.00
8414.30.40 8414.30.80 8414.51.30 8414.51.90 8414.59.30 8414.59.65
8414.80.05 8414.80.16 8414.80.20 8414.80.90 8414.90.10 8414.90.30
8414.90.41 8414.90.91 8415.10.60 8415.10.90 8415.81.01 8415.82.01
8415.83.00 8415.90.40 8415.90.80 8418.10.00 8418.30.00 8418.40.00
8418.61.01 8418.69.01 8419.50.10 8419.50.50 8419.81.50 8419.81.90
8419.90.10 8419.90.20 8419.90.30 8419.90.50 8419.90.85 8421.19.00
8421.21.00 8421.23.00 8421.29.00 8421.31.00 8421.32.00 8421.39.01
8424.10.00 8425.11.00 8425.19.00 8425.31.01 8425.39.01 8425.42.00
8425.49.00 8426.99.00 8428.10.00 8428.20.00 8428.33.00 8428.39.00
8428.90.03 8443.31.00 8443.32.10 8443.32.50 8479.89.10 8479.89.20
8479.89.65 8479.89.70 8479.89.95 8479.90.41 8479.90.45 8479.90.55
8479.90.65 8479.90.75 8479.90.85 8479.90.95 8483.10.10 8483.10.30
8483.10.50 8483.30.40 8483.30.80 8483.40.10 8483.40.30 8483.40.50
8483.40.70 8483.40.80 8483.40.90 8483.50.40 8483.50.60 8483.50.90
8483.60.40 8483.60.80 8483.90.10 8483.90.20 8483.90.30 8483.90.50
8483.90.80 8484.10.00 8484.90.00 8501.20.50 8501.20.60 8501.31.50
8501.31.60 8501.31.81 8501.32.20 8501.32.55 8501.32.61 8501.33.20
8501.33.30 8501.33.61 8501.34.61 8501.40.50 8501.40.60 8501.51.50
8501.51.60 8501.52.40 8501.52.80 8501.53.40 8501.53.60 8501.61.01
8501.62.01 8501.63.01 8501.71.00 8501.72.10 8501.72.20 8501.72.30
8501.72.90 8501.80.10 8501.80.20 8501.80.30 8502.11.00 8502.12.00
8502.13.00 8502.20.00 8502.31.00 8502.39.00 8502.40.00 8504.10.00
8504.31.20 8504.31.40 8504.31.60 8504.32.00 8504.33.00 8504.40.40
8504.40.60 8504.40.70 8504.40.85 8504.40.95 8504.50.40 8504.50.80
8507.10.00 8507.20.80 8507.30.80 8507.50.00 8507.60.00 8507.80.82
8507.90.40 8507.90.80 8511.10.00 8511.20.00 8511.30.00 8511.40.00
8511.50.00 8511.80.20 8511.80.40 8511.80.60 8514.20.40 8516.80.40
8516.80.80 8517.14.00 8517.61.00 8517.69.00 8517.71.00 8518.10.40
8518.10.80 8518.21.00 8518.22.00 8518.29.40 8518.29.80 8518.30.10
8518.30.20 8518.40.10 8518.40.20 8518.50.00 8519.81.10 8519.81.20
8519.81.25 8519.81.30 8519.81.41 8519.89.10 8519.89.20 8519.89.30
8521.10.30 8521.10.60 8521.10.90 8522.90.25 8522.90.36 8522.90.45
8522.90.58 8522.90.65 8522.90.80 8526.10.00 8526.91.00 8526.92.10
8526.92.50 8528.42.00 8528.62.00 8529.10.21 8529.10.40 8529.10.91
8529.90.04 8529.90.05 8529.90.06 8529.90.09 8529.90.13 8529.90.16
8529.90.19 8529.90.21 8529.90.24 8529.90.29 8529.90.33 8529.90.36
8529.90.39 8529.90.43 8529.90.46 8529.90.49 8529.90.55 8529.90.63
8529.90.68 8529.90.73 8529.90.77 8529.90.78 8529.90.81 8529.90.83
8529.90.87 8529.90.88 8529.90.89 8529.90.93 8529.90.95 8529.90.97
8529.90.98 8531.10.00 8531.20.00 8531.80.15 8531.80.90 8536.70.00
8539.10.00 8539.51.00 8543.70.42 8543.70.45 8543.70.60 8543.70.80
8543.70.91 8543.70.95 8543.90.12 8543.90.15 8543.90.35 8543.90.65
8543.90.68 8543.90.85 8543.90.88 8544.30.00 8801.00.00 8802.11.01
8802.12.01 8802.20.01 8802.30.01 8802.40.01 8805.29.00 8806.10.00
8806.21.00 8806.22.00 8806.23.00 8806.24.00 8806.29.00 8806.91.00
8806.92.00 8806.93.00 8806.94.00 8806.99.00 8807.10.00 8807.20.00
8807.30.00 8807.90.90 9001.90.40 9001.90.50 9001.90.60 9001.90.80
9001.90.90 9002.90.20 9002.90.40 9002.90.70 9002.90.85 9002.90.95
9014.10.10 9014.10.60 9014.10.70 9014.10.90 9014.20.20 9014.20.40
9014.20.60 9014.20.80 9014.90.10 9014.90.20 9014.90.40 9014.90.60
9020.00.40 9020.00.60 9025.11.20 9025.11.40 9025.19.40 9025.19.80
9025.80.10 9025.80.15 9025.80.20 9025.80.35 9025.80.40 9025.80.50
9025.90.06 9026.10.20 9026.10.40 9026.10.60 9026.20.40 9026.20.80
9026.80.20 9026.80.40 9026.80.60 9026.90.20 9026.90.40 9026.90.60
9029.10.80 9029.20.40 9029.90.80 9030.10.00 9030.20.05 9030.20.10
9030.31.00 9030.32.00 9030.33.34 9030.33.38 9030.39.01 9030.40.00
9030.84.00 9030.89.01 9030.90.25 9030.90.46 9030.90.66 9030.90.68
9030.90.89 9031.80.80 9031.90.21 9031.90.59 9031.90.91 9032.10.00
9032.20.00 9032.81.00 9032.89.20 9032.89.40 9032.89.60 9032.90.21
9032.90.41 9032.90.61 9033.00.90 9104.00.05 9104.00.10 9104.00.20
9104.00.25 9104.00.30 9104.00.40 9104.00.45 9104.00.50 9104.00.60
9109.10.50 9109.10.60 9109.90.20 9401.10.40 9401.10.80 9403.20.00
9403.70.40 9403.70.80 9405.11.40 9405.11.60 9405.11.80 9405.19.40
9405.19.60 9405.19.80 9405.61.20 9405.61.40 9405.61.60 9405.69.20
9405.69.40 9405.69.60 9405.92.00 9405.99.20 9405.99.40 9620.00.50
9620.00.60 9802.00.40 9802.00.50 9802.00.60 9802.00.80 9818.00.05
9818.00.07

Section 301 is now codified at 19 U.S.C. §§ 2411-2420.

The Congressional Research Service has published a history of Section 301 and its past uses.

In addition to prohibiting tariffs that would apply duties to aircraft parts imports, ATCA also prevents technical regulations that represent hidden restrictions on trade in civil aircraft parts.  This has allowed aircraft parts to move relatively freely in global commerce.

While ATCA may prohibit he imposition of import duties on aircraft parts, the Administration continues to see tariffs as an important foreign policy tool for the President. IEEPA does not permit a violation of the ATCA, but other laws might permit aircraft parts tariffs. With this in mind, the Administration opened a Section 232 investigation into the state of aviation, last year.  It was an open docket to which many aviation companies contributed, emphasizing the strengths created by globalization.  Industry comments explained that as U.S. commercial aviation manufacturing become more deeply integrated with the global aerospace supply chains, the industry found that cross-border collaboration helped to drive innovations and improvements in aviation safety, performance and efficiency. ASA’s comment to the section 232 docket can be found here. The ASA comments emphasized:

• Current civil aviation import operations are largely separate from – and thus do not affect – the defense aircraft industry.
• The United States should focus on retaining highly specialized production and manufacturing skills rather than focusing on foreign imports of parts for which there is concurrent domestic capability.
• U.S. data shows a history of growth in exports of US manufactured aircraft and aircraft parts, and this doesn’t even include exports by U.S. based aircraft parts distributors; this growth suggests a growing positive balance of trade in the aviation industry that could be undermined by new tariffs on aviation that might lead to reciprocal foreign tariffs.
• The international and domestic legal regime implementing the Agreement on Trade of Civil Aircraft created a duty-free trade environment for civil aircraft and parts which has been a significant factor in the continued growth of the U.S.-based industry. Interference in this regime contradicts the international agreement in place as well as existing Acts of Congress.

On July 9, 2026, the White House released its response to the Department of Commerce’s Section 232 investigation into aircraft parts imports.  The response focused on whether reliance on foreign-sourced components and materials poses a risk to U.S. national security, particularly in terms of supply chain resilience and domestic production capacity.

The published findings identify the administration’s issue: the U.S. aerospace sector remains dependent on foreign suppliers for key inputs, including high-spec engine components, avionics, and specialized materials. That dependency is a function of the industry’s efforts to create a global supply chain; in addition to creating more opportunities for innovation, the global supply chain also helped to promote the sale of aircraft and engines to foreign markets that were participating in that global supply chain.

Global dependency, according to Commerce, has been found to have the potential to become a liability.  The Administration explained that it intends to protect and strengthen domestic manufacturing as a means to address this perceived liability.

The Commerce Department has not yet recommended tariffs.  Nonetheless, the White House made it clear that tariffs on aircraft parts and other aviation inputs remain an option. The July 9 communication outlines the first step: a 180 period of directed negotiations with partner countries. The future outcome may include a more targeted, phased approach—potentially including selective tariffs, supply chain restrictions, and incentives to shift production back to the U.S. or to trusted partner countries.

Aircraft parts distributors in the United States should be concerned because potential measures could eventually include (1) new tariffs on aircraft parts imports and/or (2) newly negotiated impediments (such as impediments on countries that have not agreed to additional terms with the United States).  Such new impediments could also be alleged to be technical barriers to trade, which might create further problems if the United States is accused of fomenting such barriers.  New tariffs and new barriers create the potential for cost increases, sourcing disruptions, or new compliance requirements for United States companies that rely on foreign-sourced parts.

TLDR: These new Canadian tariffs will not apply to aircraft parts.

Section 338 is a nearly century-old U.S. trade statute granting the President unilateral authority to impose up to 50% tariffs or completely exclude imports from any foreign country that discriminates against U.S. commerce. The United States has alleged that Canada is discriminating against U.S. alcohol, automobiles and dairy.

The USMCA was specifically supposed to address U.S. concerns over all three of these markets. The USTR published a report addressing the positive effect on automobile trade. Dairy has continued to be a sore subject, with the U.S. winning disputes over the interpretation of the dairy provisions in 2022 and 2023. The US Distilled Spirits Council has complained that “U.S. spirits exports to Canada have plummeted by 85%, dropping below $10 million in the second quarter of 2025, largely due to the majority of Provinces continuing to ban the sale of U.S. spirits.” Many of these bans arose in response to U.S. tariffs and U.S. rhetoric about annexing Canada.

The 50% tariff on Canadian goods is identified under HTSUS 9903.03.14, but that tariff will only apply to a limited set of tariff codes, and most aircraft parts should be outside of the scope of those codes. The language of the note that interprets the new tariff code specifically states that it applies to a list of specific goods “unless they are subject to import restrictions imposed pursuant to section 232 of the Trade Expansion Act of 1962, [e.g. steel and aluminum] as amended (18 U.S.C. 1862), or articles of civil aircraft or aircraft parts that meet the criteria of General Note 6 of the HTSUS.” If you think that your aircraft parts may be within the scope of the 9903.03.14 list of affected tariff codes, then please contact us.

The good news is that the new 25% tariff imposed on goods from Brazil will NOT apply to most aircraft parts. For the past year, the U.S. Trade Representative (USTR) has been investigating Brazil and its trade practices. The USTR determined that
certain of Brazil’s acts, policies, and practices are unreasonable or discriminatory and they burden or restrict United States commerce. On this basis, the USTR recommended a 25% tariff on goods of Brazil. This is expected to be published as a notice of action on Monday.

The 25% tariff will not apply to certain HTSUS codes. In particular, HTSUS codes identified by the administration as aviation parts are exempt from the tariff if the parts are actually intended for use on civil aircraft. Some civil aircraft parts are NOT identified in the HTSUS as aircraft parts and will be subject to the additional chapter 99 duties (even though they may be only used on civil aircraft). In the Federal Register notice this is expected to be described as an “Aircraft” scope limitation that will be implemented in subdivision (a)(iv) of U.S. note 50 (as found in subchapter III of chapter 99, HTSUS), which states:

As provided in heading 9903.05.05, the additional duty imposed by heading 9903.05.01 shall not apply to articles the product of Brazil that are civil aircraft (all aircraft other than military aircraft); their engines, parts and components; their other parts, components and subassemblies; and ground flight simulators and their parts and components, that otherwise meet the criteria of general note 6 of the HTSUS and are classifiable in the following provisions of the HTSUS, but regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub-column: [a long list of tariff codes follows this text]

When entering civil aircraft parts from Brazil (like Embraer parts), the importer will want to enter them under their base tariff number, and then confirm that the base tariff number is listed in subdivision (a)(iv) (as described above). It is important to check this list of tariff numbers because some aircraft parts, like most fasteners (as just one example) will NOT be subject to this exemption. If you can confirm that the base tariff code for your Brazilian goods is listed among the exemption list, then you will need to record an additional tariff code number of 9903.05.05 to reflect that the parts are civil aircraft parts at are exempt from the newest 25% tariff on Brazilian goods.

If your base tariff code is not listed on the exemption list in subdivision (a)(iv), then your Brazilian-origin aircraft parts are likely to be subject to the additional 25% tariff on goods from Brazil.

BUT make sure you read our other article about the section 232 tariffs!

Treasury Department export regulations are published by the Office of Foreign Asset Control (OFAC). When OFAC regulations require that property be blocked from export, then you may be required to hold that blocked property. If your company is holding any OFAC-blocked property, then you must prepare an annual report. 

The current annual report covers any property that was held by your company between July 1, 2025 and June 30, 2026 (yesterday). This report will be due on September 30, 2026.

An example of how this can happen arises in managed repair transactions. Imagine that Chabok FZCO sent you an IRU to be overhauled, earlier this year. You obtain the overhaul , and before you send the unit back to Chabok FZCO, you perform the normal export compliance checks that get performed for every export. During your due diligence, though, you learn that Chabok FZCO was listed as a Specially Designated Nations (SDN) by OFAC on April 21, 2026. You learn this information on or about June 15, 2026. Now, you cannot export the IRU to Chabok without an OFAC license, and that license is unlikely to be issued.

Even though the hypothetical IRU belongs to Chabok, it is treated as blocked property under the OFAC regulations. You will need to retain this property. You will also need to file an annual report for each year when you held the blocked poroperty. The first report will be the one due September 30, 2026 for blocked property hat your company held between July 1, 2025 and June 30, 2026.

Is there some way to stop holding the property? It is possible to seek an OFAC license to sell the goods for fair market value (don’t sell the blocked property without a license!). In such a case, you would take the proceeds of that sale and they would be held as blocked assets in a special account at your bank. You still need to file the annual report; but this allows you to mitigate the loss associated with aging of the aircraft part, and it relieves you of an obligation to maintain the unit.

Simulators are approved under 14 C.F.R. Part 60.  This sort of approval is a device approval for simulator use.  It is NOT the same as a Part 21 approval (which is the approval process for products and articles)   Thus, simulator parts are not inherently “approved parts” for purposes of installation in aircraft, because they are not naturally subject to the design and production approvals associated with “approved parts.”

We have to recognize that flight simulators can be purpose-built (so they are not subject to the Part 21 rules at all), but sometimes flight simulators are built from existing fuselages.  When the parts are purpose-built for the simulator, then there is typically no need to build them according to type design nor is there a need to produce them under a production approval; consequently, there is no evidence that they meet type design (and thus no evidence of airworthiness). When a simulator is built from an existing fuselage, though, then articles taken from the existing fuselage may, in fact, be approved parts.

Knowing that an article meets approved design parameters before installing it on a type certificated aircraft is a legal requirement under the installation rules of Part 43.

Approval sets the baseline for airworthiness, because an approved part is presumed to be airworthy at the time of release from the quality assurance system (and remains airworthy, subject to damage or degradation).  If you think you might want to take an approved part off of a simulator for use on a type certificated aircraft, then it is also important to ensure that any such parts that might be removed from a simulator remain airworthy.  Such parts may have been subject to damage or degradation that does not matter when used in a simulator, but would create unwanted risk in an aircraft.  If the parts are subject to normal maintenance cycles, then they may not have receive such normal maintenance when used within a simulator.

In summary, it may be possible to remove a part from a simulator for use in an airworthy aircraft, if:

1. The installer confirms that the original part was produced under a production approval, or is otherwise known to meet the applicable airworthiness standards (this is different from being approved for use on a simulator);
2. The installer confirms that the part has been subject to appropriate maintenance when maintenance is normal for such parts;
3. The installer confirms that the part has not been subject to damage or degradation while installed on the simulator (as well as before such installation).

While there is a theoretical path for possible use of some simulator parts on type certificated aircraft, we generally do not recommended such use, except where non-simulator parts are otherwise unavailable, because of the amount of analysis that would be necessary to confirm airworthiness.

History

Since April 2, 2026, when the President issued Proclamation 11021, “Strengthening Actions Taken to Adjust Imports of Aluminum, Steel, and Copper into the United States,” certain parts made from aluminum, steel and/or copper have been subject to import duties under special chapter 99 tariffs. That provision imposed the import duties only on parts under certain tariff codes – many aircraft parts made from aluminum, steel and/or copper were not on that list and thus were not subject to these additional duties. But some parts, including some fasteners and other hardware, were subject to these tariffs. The tariffs were issued under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  As a consequence, they were not ruled as illegal with the IEEPA tariffs.

The April proclamation imposed 10-50% additional duties on the full customs value of certain imports of steel, aluminum, copper articles and their derivatives from all countries, effective April 6, 2026. As a base rate, metals were subject to the 50% rate and metal articles (“derivatives”) were subject to the 25% rate. Aircraft parts made from these metals could be considered affected derivatives, if they were listed on the list of affected HTSUS codes.

The Change

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States” amending the April Proclamation. The changes included addition of some new metal parts (“derivatives”) subject to the Section 232 duties, as well as some clarification about reduced rates of duty.

Generally speaking, the duty rate for metals (e.g. bar stock, tubes and pipes, etc.) will be 50%. The duty rate for metal articles will be 25% of the article’s value, except:

• 15% for products of Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union (the total rate of duty – base duty plus additional section 232 duty – shall be 15%);
• 10 percent for derivative articles where the aluminum and/or steel content was smelted and cast/poured in the United States;
• For products of Canada and Mexico that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement, a duty of 25 percent shall apply only to the non-U.S. content of the product.

A list of the 50% materials is found here.

A list of the 25% articles is found here.

There are technical details and exceptions in addition to what this article covers. If you think your import may be subject to these additional duties then please make sure you scrutinize the standards carefully to ensure you are following the correct compliance path, and are not overpaying your import duties..

The announcement can be found in yesterday’s Federal Register on Page 34085.

These new standards apply to imported parts entered into the United States on or after June 8, 2026.

Looking for more import guidance? Join us at the ASA/AFRA Annual Conference, on June 14-16, in Las Vegas, Nevada. Check out the conference agenda for full details on this and many other workshops available at the conference!