U.S. Commerce Opens Process for Adding Auto Parts to Section 232 Tariffs Oct. 1
Trade Update • Sept. 17, 2025
Key Points:
- Commerce issued an interim final rule (IFR) to expand Section 232 auto tariffs under Proclamation 10908.
- Establishes a formal process for adding new auto parts subject to tariffs.
- First request window: Oct 1–15, 2025; future windows open quarterly.
- Requests reviewed by ITA with public comment periods; Secretary issues determinations within 60 days.
- Newly approved parts added to tariffs via Federal Register notice, effective next day.
- Public comments on the IFR due Nov 3, 2025.
- Process designed to capture new technologies (EV, autonomous, advanced components).
- Could significantly expand tariff coverage, similar to steel/aluminum derivative precedents.
he U.S. Department of Commerce, through its Bureau of Industry and Security (BIS) and International Trade Administration (ITA), has issued an interim final rule (IFR) establishing a formal process to expand the scope of Section 232 tariffs on automobiles and automobile parts. This follows March 26, 2025 proclamation (Proclamation 10908) directing the Secretary of Commerce to create a system for including additional auto parts articles for passenger vehicles and light trucks.
Public comments on the rule must be submitted by November 3, 2025 via the interim final rule outlining the inclusion process (submission process – see section ‘Public Comment on the IFR’ below).
First Inclusion Request Window Opens October 1
The first two-week submission window for inclusion requests will open on October 1, 2025. Domestic producers of automobiles, automobile parts, or industry associations may file requests to add new products to the tariff scope.
Future inclusion request windows will open four times annually, beginning on the first of January, April, July, and October.
Submission Requirements
To be considered valid, an inclusion request must:
- Identify the requestor (producer or association)
- Provide a precise description of the auto part
- Specify the 8- or 10-digit HTSUS classification
- Explain why the article qualifies as an automobile part
- Include information on the affected domestic industry
- Provide import and production data
- Demonstrate how imports threaten to impair U.S. national security
- Be limited to 30 pages, including attachments
Requests must be submitted in PDF format to AutoInclusions@trade.gov. Business confidential submissions must include a non-confidential version marked “PUBLIC.”
Review and Public Comment Phase
Following the close of each two-week submission period, ITA will post non-confidential versions of valid requests on regulations.gov for a 14-day public comment window. Public comments must be submitted under designated docket IDs:
- January – ITA-2025-0039
- April – ITA-2025-0040
- July – ITA-2025-0037
- October – ITA-2025-0038
This public comment process is distinct from the comment process on the interim final rule itself marked “PUBLIC.”
Public Comment on the IFR
Comments on the IFR itself must be filed separately from inclusion requests. Submissions are due November 3, 2025 via regulations.gov, ID ITA-2025-0041. Commenters submitting business confidential information must comply with Commerce Department filing protocols, including the use of “BC” and “P” file naming conventions.
The regulations.gov ID for this rule is: ITA-2025-0041. Please refer to RIN 0625-AB30 in all comments.
Decision Timeline
Once requests are validated, ITA begins analysis. Each request will be reviewed to determine:
Whether the identified HTSUS classification is an automobile part.
Whether increased imports threaten to impair national security.
The Secretary of Commerce or designee must issue a determination within 60 days of receiving the request. Decisions will be published in regulations.gov, along with a memorandum summarizing the rationale.
A subsequent Federal Register notice will amend Proclamation 10908 to add the new subheadings. Newly included articles will become subject to Section 232 tariffs at 12:01 a.m. ET the following day, with enforcement by U.S. Customs and Border Protection.
Implications for Industry
The Commerce Department highlighted that this process allows tariffs to adapt to new automotive technologies such as:
Alternative propulsion systems
Autonomous driving components
Other advanced vehicle technologies
It also provides a mechanism to capture products currently classified under broad HTSUS codes not originally included in the 2025 investigation.
Based on the experience with steel and aluminum derivative tariffs, where BIS accepted roughly over 80% of over 460 requests (see 50% Section 232 Tariffs on 407 New Steel and Aluminum Derivatives Take Effect Aug. 18 – CBP Guidance Available), the auto parts inclusion process could lead to significant expansion of tariff coverage.
Key Dates
Sept. 17, 2025 – IFR effective date
Oct. 1, 2025 – First submission window opens (14 days)
Oct. 15, 2025 – First submission window closes
Oct. 16–30, 2025 – Public comment period on requests
Nov. 3, 2025 – Deadline for comments on the IFR
By Dec. 14, 2025 – Secretary to issue determinations on October requests
Following Day at 12:01 a.m. ET – Tariffs take effect on newly included products
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