U.S. Customs and Border Protection issued on May 6 guidance on applying the 25 percent Section 232 tariff imposed by Proclamation 10984 exclusively to the value of the non-U.S. content for approved imports of medium- and heavy-duty vehicles that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement.
In October 2025 President Trump issued a proclamation imposing a Section 232 tariff of 25 percent on MHDVs. That proclamation also provided that for MHDVs that qualify for preferential tariff treatment under USMCA, 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. The Department of Commerce subsequently issued a notice setting forth procedures for the submission and review of such documentation.
CBP indicates that subheading 9903.74.03 applies to the non-U.S. content of MHDVs for special tariff treatment under USMCA, upon DOC approval, to apply the 25 percent duty rate exclusively to the value of the non-U.S. content of the MHDV. Subheading 9903.74.06, meanwhile, applies to the U.S. content of MHDVs that received DOC approval.
The non-U.S. content and the U.S. content value of the MHDV must be reported on two lines, as follows.
Non-U.S. content (first line)
- report the total quantity of the imported goods
- report the value of the non-U.S. content approved by the DOC for entered value
- report the Section 232 duties based on the value of the non-U.S. content with HTSUS 9903.74.03
- report Special Program Indicator code “S”
- report Ch. 1-97 HTSUS (same HTSUS must be reported on both lines)
- report country of origin (same country of origin must be reported on both lines)
- report all other applicable duties, such as AD and CVD duties
U.S. content (second line)
- report 0 for quantity
- report the entered value of the U.S. content by subtracting the value of the non-U.S. content from the entered value of the article
- report the 0 duties based on the value of U.S. content with HTSUS 9903.74.06
- report Special Program Indicator code “S”
- report the same Ch. 1-97 HTSUS reported on the first line
- report the same country of origin reported on the first line
- report all other applicable duties, such as AD and CVD duties
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