CBP Guidance for Applying Section 232 Tariffs on USMCA Vehicles and Light Trucks

Trade Update • July 17, 2025

Key Points:

• The 25% Section 232 tariff applies only to the non-U.S. content portion of USMCA-qualified passenger vehicles and light trucks.

• This tariff treatment is effective for imports entered on or after April 3, 2025, with approval from the Secretary of Commerce.

• Importers must declare values in two entry lines: non-U.S. content (HTS 9903.94.03) at 25% duty, and U.S. content (HTS 9903.94.02) at 0% duty.

• Other applicable duties, such as antidumping or countervailing duties, still apply and should be reported accordingly.

he U.S. Customs and Border Protection (CBP) CBP has issued guidance on applying Section 232 tariffs to passenger vehicles and light trucks that qualify under the United States-Mexico-Canada Agreement (USMCA). This guidance applies to entries on or after April 3, 2025.

Background

• Presidential Proclamation 10908 (March 26, 2025): Authorized the Secretary of Commerce to approve USMCA-qualifying imports and apply Section 232 tariffs only on non-U.S. content

• Commerce Department Procedures (May 20, 2025): Established the process for importers to submit documentation to verify U.S. content in vehicles

Tariff Application and Classification

• The tariff applies only to the non-U.S. content value after Commerce approval.
• Vehicles and parts not eligible for USMCA preferential treatment may be subject to the full 25% tariff.

Entry Filing Instructions

Importers, brokers, or filers approved by the Secretary of Commerce must submit entries as follows:

First line (non-U.S. content):

• Report the total quantity of vehicles.

• Enter value of non-U.S. content approved by Commerce as entered value.

• Use HTS 9903.94.03 and apply 25% Section 232 duty.

• Report Special Program Indicator (SPI) code “S.”

• Report the country of origin and HTS code consistent with the vehicle’s classification.

Second line (U.S. content):

• Report quantity as zero.

• Enter the value of U.S. content (total vehicle value minus approved non-U.S. content).

• Use HTS 9903.94.02 and apply 0% duty.

• Report SPI code “S,” country of origin, and HTS consistent with the first line.

Additional duties:

• Report any applicable antidumping or countervailing duties on both lines.

Compliance and Penalties

• CBP will review declared content values. If an importer understates non-U.S. content, the 25% tariff will apply retroactively and prospectively to the full vehicle value on affected shipments until correction is verified.
• Duty drawback is not available for Section 232 tariffs.

Additional Information

• Vehicles over 25 years old remain exempt from Section 232 tariffs under HTS 9903.94.04.

• Automobile parts qualifying under USMCA remain temporarily exempt from Section 232 tariffs until further notice; non-USMCA parts face full tariffs starting May 3, 2025.

• Importers experiencing Automated Commercial Environment (ACE) entry rejections should contact their CBP Client Representative or the ACE Help Desk.
• For trade remedy questions, contact TradeRemedy@cbp.dhs.gov or visit CBP Trade Remedies.

Reference

Full CBP guidance is available here:
CBP Guidance on Section 232 Import Duties for USMCA-Qualifying Vehicles and Light Trucks

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