The October 17, 2025 Presidential Proclamation 10984 Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses into the United States included a provision to self-declare certain auto and truck parts and components as being subject to the tariffs as follows:
(12) An importer of record may declare an automobile part or MHDVP as subject to the automobile parts tariff pursuant to Proclamation 10908, as amended, or to the MHDVP tariff pursuant to this proclamation. For an automobile or MHDV part to be eligible for this treatment, the part must meet the following conditions:
(a) the part cannot be presently subject to the tariffs imposed pursuant to Proclamation 10908, as amended, or this proclamation;
(b) the part cannot be classifiable in Chapters 72, 73, or 76 of the HTSUS; and
(c) the part must be used for automobile- or MHDV-related production or repair activity in the United States, as attested to by certification from the importer of record.
At first blush, one might wonder why an importer would wish to voluntarily declare its imported auto or truck parts as being subject to the 25% Section 232 Auto / truck tariffs. The answer relates to the interplay of the other tariff regimes, and also to the availability of certain “offsets”, or import credits made available to U.S. manufacturers under the Section 232 auto and truck Pronouncements that utilize imported parts and components in their U.S. made auto and truck vehicles.
Under the Section 232 auto / truck tariff pronouncements, the auto / truck tariffs have primacy in the “stacking” hierarchy and given the difference between the 25% Section 232 auto / truck tariff rates and the 50% Section 232 steel / aluminum tariffs, parts importers can do the math to see if there would be net savings by self-declaring as auto / truck parts.
Also, at present auto / truck parts that are USMCA qualifying can enter fully exempt from the Section 232 auto / truck tariffs while the Secretary of Commerce continues to work out a process for declaring the U.S. content-only for duty exemption. Once again applying the stacking rules, declaring under the Section 232 auto / truck regime would trump the Section 232 steel / aluminum tariffs and might result in a nearly complete Section 232 tariff savings.
In addition, imported auto and truck parts can be eligible for Section 232 tariff offset. Under the Section 232 auto and truck tariff programs, U.S. manufacturers can apply for offset credits to be used to offset the auto / truck tariff liability for eligible imported parts. These offset credits can be allocated by the U.S. manufacturer to its parts suppliers, and recent experience shows that the U.S. auto and truck manufacturers are very eager to utilize the offset program to reduce tariff impacts on their imported part content, and also have been aggressive in assuring that their suppliers are taking full advantage of the offset program, including self-declaring parts and components that are not specifically listed under the Annexes to the respective proclamations.
For the foregoing reasons importers of auto / truck parts and components that are utilized in the manufacture of U.S built automobiles and trucks may wish to examine the potential benefits of self-declaring their imported products to determine the eligibility and potential tariff benefits of self-declaring under the Section 232 auto / truck tariff programs.
