New Section 232 Tariffs on Medium- and Heavy-Duty Trucks and Parts Take Effect November 1, 2025

On October 17, 2025, the President issued Proclamation 10984, “Adjusting Imports of Medium- and Heavy-Duty Trucks, Medium- and Heavy-Duty Truck Parts, and Buses into the United States,” under Section 232 of the Trade Expansion Act of 1962. The action imposes additional ad valorem tariffs of 10–25% on imports of medium- and heavy-duty vehicles (MHDVs), their parts (MHDVPs), and buses.

The new duties will apply to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT, November 1, 2025.

Overview of Affected Products

The new tariffs apply broadly to motor vehicles and components used in the commercial trucking and bus sectors, as classified under HTSUS headings 8701, 8702, 8704, 8705, 8706, and 8709.

• MHDVs: Imports of heavy trucks and related vehicles will face a 25% duty under HTSUS 9903.74.01.
  
• Buses and similar vehicles: Imports will face a 10% duty under HTSUS 9903.74.02.
  
• MHDV parts: Most truck parts classified under subdivision (i) of U.S. Note 38 to Subchapter III will face a 25% duty under HTSUS 9903.74.08.

The proclamation also includes a mechanism for USMCA-qualified vehicles and parts to apply duties only to the non-U.S. content, pending Commerce Department approval. Separate headings (9903.74.03 and 9903.74.06) will be used for approved entries once implementing guidance is issued.

Vehicles manufactured 25 years or older at the time of import are exempt from the additional duties.

Auto Parts and Related Tariffs

In addition to the MHDV measures, CBP confirmed that parts of passenger vehicles and light trucks imported for production or repair activities in the United States will now face a 25% additional duty (HTSUS 9903.94.07), except where preferential treatment applies to the EU, Japan, or UK:

• EU parts: Up to 15% combined rate, depending on Column 1 duty.
  
• Japan parts: Up to 15% combined rate, depending on Column 1 duty.
  
• UK parts: Flat 10% combined rate under HTSUS 9903.94.33.

Foreign Trade Zones and Drawback

MHDVs, MHDVPs, and buses entered into U.S. foreign trade zones after November 1, 2025, must be admitted under “privileged foreign” status (19 C.F.R. § 146.41). They will be subject to the full duty rate when entered for consumption.

CBP has confirmed that direct identification and substitution manufacturing drawback will be available for qualifying Section 232 duties on MHDV parts and automobile parts, but only under 19 U.S.C. § 1313(a) and (b).

Interaction with Other Tariff Programs

Goods covered by these new Section 232 duties are not subject to overlapping reciprocal or IEEPA-based duties (e.g., under headings 9903.01.25, 9903.01.63, or 9903.02.73), nor to Section 232 measures on steel, aluminum, or copper.

Filers should use the corresponding exemption headings—such as 9903.01.33 (Reciprocal duties) or 9903.01.83 (Brazil IEEPA duties)—to ensure proper coding in ACE.

Conclusion

The new Section 232 tariffs mark a significant expansion of U.S. trade actions affecting the vehicle manufacturing and logistics sectors. Importers, parts suppliers, and logistics providers should confirm HTSUS coverage, adjust pricing models, and ensure compliance with filing requirements before the November 1 implementation date.

As new tariff regulations continue to evolve, navigating these changes requires experienced legal counsel. At Liang + Mooney, PLLC, our seasoned tariff lawyers can answer your questions and concerns with sophisticated legal solutions.  If you seek strategic counsel and insight into which tariffs apply to your operations, we invite you to contact us to schedule a consultation.