Section 232 Tariffs on Heavy/Medium-Duty Vehicles (U.S. Content Procedures for USMCA-Eligible Imports)

Published Oct. 18, 2025 | Updated Feb 5, 2026

Key Points

• Tariffs Effective Nov. 1, 2025: 25% on heavy- and medium-duty trucks (Classes III–VIII) and parts; 10% on buses.

• CBP Guidance: On Oct. 29, 2025, CBP released a guidance providing detailed entry filing instructions. The guidance clarifies the use of Chapter 99 HTSUS codes and allows Direct Identification and Substitution Manufacturing Drawback claims for eligible MHDV and passenger/light truck parts, with no other drawback claims permitted.

• USMCA Treatment: Eligible trucks from Canada/Mexico get tariff relief on U.S. content; buses receive no preferential treatment.

• Domestic Assembly Offset: U.S.-assembled trucks and engines can claim a 3.75% offset through 2030 for tariffs paid on parts.

• Steel & Aluminum Relief: Canadian/Mexican metals used in vehicles potentially face *25% tariffs instead of 50%, this is limited to expansion quantities. *Note: a reduction to 25% is possible, not guaranteed, and it is not clear whether all or only certain parties will benefit from a reduction.

• National Security Justification: MHDVs and buses are vital for military readiness, emergency response, and moving 70% of U.S. freight by weight.

• Special Rates: Japanese/European truck parts and heavy-duty engines face a 15% tariff instead of 25%.

• Used/Remanufactured Vehicles: Tariffs apply only if manufactured in the last 25 years.

• Latest Update: On February 2, 2026, the U.S. Department of Commerce’s International Trade Administration issued procedures allowing importers of USMCA‑eligible medium‑ and heavy‑duty vehicles to submit documentation showing U.S. content so that Section 232 tariffs may be applied only to the vehicles’ non‑U.S. content

P​​​resident Donald Trump has issued a proclamation imposing Section 232 tariffs on medium- and heavy-duty trucks, certain truck parts, and buses, citing national security concerns. The tariffs will take effect on November 1, 2025, and are intended to bolster domestic production, strengthen supply chains, and maintain U.S. industrial and defense readiness. The U.S. also issued a fact sheet summarizing the tariffs and import adjustment offsets.

On October 29, CBP released detailed guidance on filing entries for these Section 232 tariffs, including instructions for eligible vehicle and parts shipments. More info on the CBP guidance section below.

Latest Update: On February 2, 2026, the U.S. Department of Commerce’s International Trade Administration published procedures allowing importers of USMCA‑eligible medium‑ and heavy‑duty vehicles to submit documentation showing U.S. content so that Section 232 tariffs may be applied only to the vehicles’ non‑U.S. content. See details below under USMCA Treatment.

Tariff Rates and Coverage

• Trucks: Classes III through VIII heavy- and medium-duty trucks and their parts will be subject to a 25% ad valorem tariff.

• Buses: All buses, including school buses, city buses, and motor coaches, will face a 10% tariff.

• Used and Remanufactured Vehicles: Tariffs also apply to trucks and buses manufactured within the past 25 years.

• Foreign Parts Exception: Japanese and European truck parts or heavy-duty engine parts will be charged a 15% all-inclusive rate rather than 25%.

USMCA Treatment

• Eligible trucks imported from Canada or Mexico can receive preferential treatment under USMCA: only non-U.S. content is subject to the 25% tariff; however, there is an application and approval process that must be followed before the 25% will be assessed on non-US content only.

• Buses remain eligible for preferential treatment under the USMCA. However, the process that allows approval to assess duty only on the non-U.S. content of the vehicle has not been extended to buses. As a result, the full vehicle value remains subject to the applicable 10% tariff unless otherwise specified.

• Truck parts for use in Medium- and Heavy-Duty Vehicles (MHDVs) from Canada or Mexico entering under USMCA rules of origin are currently duty-free. Buses are excluded from this provision. The duty exemption applies pending the Commerce Department’s final methodology for assessing duties on non-U.S. content in these truck parts.

Latest Update: USMCA Content Procedures & Preferential Treatment

Effective February 2, 2026, the U.S.Department of Commerce’s International Trade Administration (ITA) implemented formal procedures allowing importers of medium- and heavy-duty vehicles (MHDVs) to apply for approval to assess Section 232 tariffs only on the non-U.S. content of qualifying vehicles.

These procedures implement Presidential Proclamation 10984 and apply solely to MHDVs imported from Canada or Mexico that qualify for preferential tariff treatment under the USMCA.

Only the following vehicles qualify:

• Medium- and heavy-duty trucks imported from Canada or Mexico
• Vehicles that meet USMCA rules of origin
• Vehicles subject to the Section 232 MHDV tariffs effective November 1, 2025

MHDVs from non-USMCA countries and USMCA-origin vehicles that fail to qualify for preferential treatment remain subject to the full 25% tariff on total vehicle value.

Submission Requirements

Importers must submit documentation on a model-specific basis, certified by a senior corporate officer (such as a CFO or General Counsel). Required information includes:

• Total declared customs value at importation
• Total U.S. content value attributable to U.S. production and production-related activities
• Total non-U.S. content value
• Production locations and country of final assembly
• Proof of USMCA eligibility, including origin certification and approved steel, aluminum, and labor value content certifications
• Importer, manufacturer, and model identification details
• Entry numbers if requesting retroactive treatment

Submissions must be sent electronically to:
MHDV232USMCAContent@trade.gov

Review and Approval Process

Commerce will review each submission for completeness and compliance and may request supplemental information. Upon approval, Commerce will notify both the importer and U.S. Customs and Border Protection (CBP) of the authorized U.S. and non-U.S. content values for each approved model.

Once approved:

• The 25% Section 232 tariff applies only to the non-U.S. content
• CBP will apply the reduced assessment at entry based on Commerce’s determination

Retroactive Application and Validity

At the Secretary’s discretion, approved determinations may apply retroactively to qualifying MHDVs imported on or after November 1, 2025, provided entry numbers are supplied.

Eligibility determinations:

• Issued in 2026 are valid only for vehicles imported in 2025 or 2026
• Must be resubmitted annually for continued eligibility
• Require updated submissions if sourcing or production changes affect U.S. content levels

Consequences of Misreporting

If CBP determines that U.S. content was overstated or inconsistent with Commerce’s approval:

• The 25% tariff applies to the full vehicle value
• Duties may be assessed retroactively and prospectively
• Enforcement applies to all vehicles of the same model imported by the same importer

No Impact on USMCA Qualification

These procedures do not alter a vehicle’s USMCA preferential status. They apply only to how Section 232 tariffs are calculated once USMCA eligibility has already been established.

Domestic Assembly Offsets

• U.S.-assembled medium- and heavy-duty trucks are eligible for a 3.75% offset of the manufacturer’s suggested retail price (MSRP) if tariffs were paid on parts accounting for 15% or more of vehicle value.

• Heavy truck engine manufacturers, such as Cummins, are also eligible for the offset.

• Offset program for U.S.-assembled trucks and engines: November 1, 2025 – October 31, 2030. Offsets will remain in place through 2030 to incentivize domestic production.

Aluminum and Steel Exceptions

• Aluminum or steel imported from Canada or Mexico and used in truck manufacturing, provided it was smelted and cast or melted and poured in those countries, is subject to 25% tariffs instead of 50%. Aluminum and steel must also qualify for USMCA; however, whether this will occur, how it will be applied and what the reduced rate will be, has not been confirmed. Modifications will be allowed, and it may be reduced by up to half.

• The Commerce Secretary will limit this break to the amount of metals expected from announced U.S. expansions.

CBP Guidance

CBP’s guidance provides detailed instructions for filing entries for Section 232 tariffs on medium- and heavy-duty vehicles (MHDVs), MHDV parts, buses, and certain passenger vehicle and light truck parts.

Entry Filing Instructions

• Tariffs apply to goods entered for consumption or withdrawn from warehouse on or after Nov. 1, 2025.
• Importers, brokers, and filers must use Chapter 99 HTSUS codes to report applicable duties.

Specific Duty Classifications

• MHDVs: 9903.74.01 (25%), 9903.74.05/06/07 (0% for non-MHDVs, U.S. content, or vehicles ≥25 years old).
• Buses: 9903.74.02 (10%).
• MHDV Parts: 9903.74.08/09 (25%), 9903.74.10 (0% for USMCA-eligible), 9903.74.11 (0% for non-MHDV parts).
• Passenger vehicle & light truck parts: Use 9903.94.07, 9903.94.33–55 depending on origin and certification for U.S. production/repair.

Drawback Eligibility

• Direct Identification and Substitution Manufacturing Drawback allowed for MHDV and auto parts under specific HTSUS codes (e.g., 9903.74.08, 9903.94.07, 9903.94.33).
• No other types of drawback claims are permitted.

Foreign Trade Zone (FTZ)

• MHDVs, MHDV parts, and buses entering a U.S. FTZ not under domestic status must be admitted as privileged foreign status, subject to applicable Section 232 tariffs.

Reciprocal/IEEPA Duty Exemptions

• Certain reciprocal or IEEPA duties (e.g., headings 9903.01.25, 9903.01.77, 9903.01.84) do not apply to MHDVs/MHDVPs under 9903.74.01–03, 9903.74.08–09.
• Filers must report applicable exemptions using 9903.01.33, 9903.01.34, 9903.01.83, 9903.01.87.

Filing Support

• Refer to CSMS #64018403 for guidance on ACE entry summaries involving Chapter 99 HTSUS codes. A summary of the MHDVs/MHDVPs Chapter 99 HTSUS classification list is available to help identify the applicable codes for different entries.
• Questions on ACE entry rejections should go to your CBP Client Representative. For questions regarding trade remedy programs, visit CBP Trade Remedies or contact TradeRemedy@cbp.dhs.gov.

National Security Justification

• Section 232 of the Trade Expansion Act allows the President to impose tariffs when imports threaten national security.

• Medium- and heavy-duty vehicles (MHDVs) and parts are critical to U.S. defense, supporting military readiness, troop and supply transport, and emergency response operations.

• Trucks move over 70% of U.S. freight by weight, including essential goods such as food, fuel, and medical supplies.

• Import penetration of Class IV–VIII trucks is 43%, with Class VIII semi trucks at 50%, highlighting dependence on foreign suppliers.

• The bus industry, which shares supply chains with MHDVs, is similarly at risk from foreign dependency.

Tariff Administration and Implementation

• CBP will administer the tariffs, including oversight of USMCA content claims and import offsets.

• Stacking rules from previous automobile tariffs will apply to trucks, buses, and parts.

• Manufacturing-type drawback may be permitted for Medium- and Heavy-Duty Vehicle Parts (MHDVPs) only; however, it is additionally now extended to Passenger Vehicle and Light Truck (PVLT) parts. No other types of drawback claims are permitted under the current provisions. Medium- and Heavy-Duty Vehicles (MHDVs) and buses remain ineligible for drawback, and Passenger Vehicles and Light Trucks (PVLTs) continue to be excluded.
• No additional drawback claims are authorized. Any drawback claims made on parts will result in a corresponding reduction of offset allowances for both the MHDV and PVLT categories.

• The Commerce Secretary will continue to monitor imports and may adjust tariffs on additional truck and bus parts to address national security threats.

Expected Impact

According to the White House:

“This is a proclamation designed to restore the sector, keep those jobs here, expand production, and address the national security importance of this sector to the economy. Because we already have robust domestic production, and because we’ve designed a very fair import adjustment offset program, we do not expect price increases as a result of these tariffs.”

The proclamation aims to strengthen supply chains, create high-quality jobs, increase domestic production share, and encourage U.S. investment and innovation in the medium- and heavy-duty truck and bus industries.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.