New Process Can Help Lower Section 232 Tariffs on Cargo Trucks

Effective Feb. 2 importers can begin submitting documentation that will help lower Section 232 tariffs on cargo trucks. Such tariff reductions may be retroactive to Nov. 1, 2025.

In October 2025 President Trump issued a proclamation imposing a Section 232 tariff of 25 percent on medium- and heavy-duty vehicles and parts thereof. That proclamation also provided that for MHDVs that qualify for preferential tariff treatment under the U.S.-Mexico-Canada Agreement, importers may submit documentation identifying the amount of U.S. content in each model imported into the U.S., which will not be subject to the Section 232 tariff.

Documentation Requirements

The Department of Commerce has now issued a notice establishing procedures for the submission and review of such documentation. This notice specifies that importers must provide the following information.

– the total declared customs value of the MHDV at the time of importation

– the total value of U.S. content in the vehicle (i.e., U.S. production and U.S. production-related activities directly supporting the manufacture of the imported vehicle and in a manner consistent with the definition of “production” in Article 4.1 of the USMCA)

– the total value of non-U.S. content in the vehicle

– vehicle production location(s) and country of final assembly

– certification of eligibility for USMCA preference as submitted to U.S. Customs and Border Protection

– importer name, importer of record number, manufacturer name and facility, country of origin, and model information for every model requested

Retroactivity

DOC states that the Section 232 tariff will apply exclusively to the value of the non-U.S. content for the relevant model and that it may retroactively extend this treatment to qualifying models for vehicles imported on or after Nov. 1, 2025, at its discretion, in which case it will provide CBP with the entry numbers of the previously imported MHDVs subject to any retroactive treatment. As a result, if an importer is seeking retroactive treatment its documentation submission should include such entry numbers.

Validity

According to DOC, eligibility determinations issued in 2026 are only valid for vehicles imported in 2025 or 2026 and importers seeking eligibility for a model imported in 2027 must submit new documentation no later than Oct. 1, 2026, to ensure timely processing.

Eligibility determinations issued for imports after Dec. 31, 2026, will only be valid for one calendar year. Importers seeking eligibility for a model imported after that date will have to submit documentation supporting eligibility no later than the Oct. 1 before the start of the calendar year of importation to ensure timely processing.

Importers of a new model may apply at any time for a U.S. content eligibility determination, which will remain valid only until the end of the calendar year in which the application is made.

Misreporting

DOC states that if CBP determines that the declared U.S. content is overstated or inconsistent with a U.S. content figure approved by the DOC, the 25 percent tariff will apply retroactively (from Nov. 1, 2025, to the date of the inaccurate overstatement) and prospectively (from the date of the inaccurate overstatement to the date the importer corrects it, as verified by CBP) to the full value of all MHDVs of the same model imported by the same importer. Such action will not apply to or otherwise affect any other applicable fees or penalties.