Tariff Update: List of Products Covered by the Autos Tariffs

Kelley Drye & Warren LLP
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On April 3, 2025, the Presidential Proclamation Adjusting Imports of Automobiles and Automobile Parts into the United States, and its accompanying Annex I, were published in the Federal Register. The text of the Proclamation was released by the White House on March 26, but the Annex – which includes the Harmonized Tariff System lines impacted by the tariffs – is new. These 25% tariffs, imposed under Section 232 of the Trade Expansion Act of 1962, are in addition to any other duties, fees, exactions, and charges applicable to such imported automobiles and automobile parts.

Auto tariffs

  • 25% tariffs on covered passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks from any country, effective 12:01 a.m. EDT on April 3, 2025.
  • The following HTS lines are included within the scope of these tariffs: 8703.22.01, 8703.23.01, 8703.24.01, 8703.31.01, 8703.32.01, 8703.33.01, 8703.40.00, 8703.50.00, 8703.60.00, 8703.70.00, 8703.80.00, 8703.90.01, 8704.21.01, 8704.31.01, 8704.41.00, 8704.51.00, 8704.60.00
  • U.S. content
    • For any covered passenger vehicle or light truck that is eligible for special tariff treatment under the United States-Mexico-Canada Agreement (USMCA), importers of such passenger vehicles or light trucks may submit documentation to the Secretary of Commerce identifying the amount of U.S. content in each vehicle or light truck imported into the United States.
    • U.S. content refers to the value of the automobile attributable to parts wholly obtained, produced entirely, or substantially transformed in the United States.
    • Thereafter, the Secretary may approve imports of such passenger vehicles or light trucks to be eligible to apply the 25% ad valorem rates of duty exclusively to the value of the non-U.S. content of the vehicle or light truck.
    • The non-U.S. content of the vehicle or light truck shall be calculated by subtracting the value of the U.S. content in a vehicle or light truck from the total value of the vehicle or light truck.
  • Passenger vehicles and light trucks that were manufactured in a year at least 25 years prior to the year of the date of entry are excluded from the 25% tariff.

Auto parts tariffs

  • 25% tariffs on certain covered auto parts from any country, effective 12:01 a.m. EDT on May 3, 2025.
  • The annex identifies 130 HTS lines corresponding to parts of passenger vehicles and light trucks that are included within the scope of the tariffs.
  • Additional auto parts may be added pursuant to a process to be established by the Secretary of Commerce by June 24, 2025.
  • Any covered auto part that is eligible for special tariff treatment under the USMCA, other than automobile knock-down kits or parts compilations, is excluded from the 25% tariff.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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