New Section 232 Tariffs on Trucks, Truck Parts, and Buses Take Effect November 1
On October 17, 2025, President Trump signed a Section 232 proclamation (the “Proclamation”) that, effective November 1, 2025, imposes a 25% ad valorem duty on Class III through VIII trucks (“MHDVs”) and specified truck parts (“MHDVPs”), and a 10% duty on buses. Covered parts are listed in Annex I. If an item is classified in Annex I but is not actually an MHDV part or vehicle as defined, it may be entered under HTSUS 9903.74.11 (parts) or 9903.74.05 (vehicles), so the 25 percent does not apply.
USMCA. For MHDV vehicles, HTSUS 9903.74.03 applies the 25% duty only to non-U.S. content, subject to approval by the Secretary of Commerce. Do not report any duty based on non-U.S. content under 9903.74.03 until CBP issues further guidance. For MHDV parts, HTSUS 9903.74.10, with 0% additional duty, applies to parts that qualify under the USMCA (other than knock-down kits or parts compilations)
Offset eligible for U.S. assembly. To incentivize domestic production, manufacturers that assemble MHDVs in the U.S. earn an offset equal to 3.75% of vehicle value. This equals 25% applied to parts assumed to be 15% of vehicle value. The offset may be used to reduce Section 232 duty on imported parts. MHDV and engine offsets apply from November 1, 2025, through October 31, 2030. The auto offset runs from April 5, 2025, through April 30, 2030.
Optional 232 treatment for eligible parts. A part may be declared subject to the 232 auto or MHDVP tariff if it is certified by the importer of record that (1) it is not already subject to those tariffs, (2) it is not classifiable in HTSUS Chapters 72, 73, or 76, and (3) it is used to produce or repair autos or trucks in the United States. Opting in can help ensure consistent tariff treatment and allow earned offsets to be applied.
Stacking and other duties. Trucks and truck parts have the same priority in the “stacking orders” as commercial vehicles receive. Where goods are subject to the auto or MHDV tariffs, certain other 232 tariffs do not stack as they otherwise might. Products subject to these new tariffs on MHDVs, MHDVPs, and buses will not be subject to additional or existing tariffs on steel, aluminum, copper, autos and auto parts, or lumber. They also will not be subject to reciprocal tariffs or the tariffs imposed on Canada, Mexico, Brazil, or India. For passenger and light-truck parts, products from Japan or the European Union remain subject to the 15% “all-in” rates. Section 301 and AD/CVD still apply.
North American metals relief. Commerce may reduce 232 steel/aluminum rates from 50% to 25% for qualifying metal from Canada or Mexico that is supplied to U.S. auto and MHDV manufacturers. This reduction is limited to newly committed U.S. production capacity and applies only if the metal is smelted and cast or melted and poured in Canada or Mexico and meets USMCA requirements.
FTZ and drawback. Entries on or after November 1, 2025 must be admitted as “privileged foreign status” (unless admitted in domestic status under 19 C.F.R. § 146.43) Only manufacturing drawback claims under subsections (a) and (b) of Section 313 of the Tariff Act of 1930 are permitted. Other types of drawback claims may lead to a reduction in offset allowances.
On Oct. 29, CBP issued CSMS #66665333 with entry-filing instructions for MHDVs, MHDVPs, and buses. As with other Section 232 actions, there will be an inclusion process. Please stay tuned for Annex I updates, Commerce’s non-U.S. content calculation method (CBP will provide further instructions before any reporting), and election and offset procedures, including any additional CSMS notices
