Auto Parts Self-Certification: What Importers Need to Know
Trade Update • May 6, 2026
Key Points
- Importers may voluntarily self-certify certain dual-use products that can be used as vehicle parts even if they are not directly covered under automotive tariff classifications.
- Self-certification applies when goods are intended for use in vehicle manufacturing or repair and meet specific classification exclusions under HTSUS rules.
- Importers must use the correct HTSUS codes, including 9903.74.09 for medium- and heavy-duty vehicle parts and 9903.94.07 for passenger vehicles and light trucks.
- Eligibility depends on meeting defined conditions, including proper end use, exclusion from specific HTSUS chapters, and absence from existing automotive tariff scope.
- USMCA qualification may reduce costs, as certain self-certified goods can qualify for duty-free treatment under HTSUS 9903.74.10 and 9903.94.06 when requirements are met.
The Presidential Proclamation 10984 issued on October 17, 2025, imposed duties on medium‑ and heavy-duty trucks and related parts. The program took effect on November 1, 2025, pursuant to U.S. Customs and Border Protection (CBP) guidance outlined in CSMS # 66665333.
This Section 232 action has also amended Presidential Proclamation 1098 which covers passenger vehicles, light trucks, and parts, as detailed in CSMS # 64624801. Together, these measures significantly impact importers of automotive-related goods.
What Changed: Self‑Certification for Automotive Parts
One key update relates to an importer’s option to voluntarily self‑certify products that are not directly covered by the automotive tariff orders.
Some products have multiple industrial uses, one of which may be as a vehicle part. While these products are not inherently subject to automotive tariffs, they may be sold to customers who ultimately use them in the manufacture or repair of vehicles.
Under this provision, importers may elect to self‑certify such products so that the applicable automotive duties can be applied and paid.
HTSUS Numbers for Self-Certification
Importers using this option must declare the appropriate HTSUS provisions:
- 9903.74.09 – Medium‑ and heavy-duty vehicle part self‑certification
- 9903.94.07 – Passenger vehicle and light truck part self-certification
Conditions for Self-Certification
To qualify, the product must meet all the following requirements:
- Be used in the production or repair of vehicles
- Not be classifiable in HTSUS Chapters 72, 73, or 76
- Not already fall within the scope of an automotive tariff order
Why Self-Certify and Pay the 25% Duty?
While paying an additional duty may seem counterintuitive, self-certification can provide a significant advantage for USMCA‑eligible products.
Self-certification allows qualifying goods to receive duty‑free treatment under USMCA using the following provisions:
- 9903.74.10 – Medium‑ and heavy‑duty vehicle part (USMCA eligible)
- 9903.94.06 – Passenger vehicle and light truck part (USMCA eligible)
Bottom Line
When a product:
- Meets all self‑certification requirements
- Qualifies for USMCA preferential treatment
- Falls within the scope of another Section 232 action
As per the proclamations. The result is fully duty-free treatment.
To support the self-certification process, we have provided the [Required Forms for Download]. If you wish to make this claim, please complete the forms and return them to your Client Care Manager, who can also assist with any questions about entry documentation or self‑certification determinations.
GHY will continue to monitor these developments and provide guidance as the trade landscape evolves. Ensure you’re subscribed to GHY Trade Updates for the latest insights and compliance resources.
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.
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