Section 232 Investigation of Trucks | Sandler, Travis & Rosenberg, P.A.

New! On October 17, 2025, President Trump issued a proclamation imposing the below tariffs, effective on 12:01 am November 1, 2025.

25% tariff on medium- and heavy-duty vehicles. According to a White House fact sheet, subject trucks include Class 3 to Class 8 vehicles like large pickup trucks, moving trucks, cargo trucks, dump trucks, and tractors for 18-wheelers (see Annex 1 for HTSUS codes).
25% tariff on medium- and heavy-duty vehicle parts. This includes engines, transmissions, tires, and chassis, and could be expanded to other parts in the future (see Annex 1 for HTSUS codes).
10% tariff on buses. This includes school buses, transit buses, and motor coaches (see Annex 1 for HTSUS codes).

Additional details on the proclamation are below.

USMCA qualification exemption. Vehicles qualifying under USMCA are eligible for a U.S. content exemption. Parts qualifying for USMCA treatment are exempt until a process is established to apply duties only to non-U.S. content.

Tariff offset. To incentivize domestic production, the proclamation offers a tariff offset equal to 3.75 percent of the aggregate value of all subject trucks assembled in the U.S. from Nov. 1, 2025, through Oct. 31, 2030. This offset can be used to adjust the Section 232 tariff on truck parts owed by a truck manufacturer. The White House said an equivalent offset will be established for truck engines.

Compliance and penalties. If CBP finds overstatement of U.S. content, the full 25% tariff applies to the declared vehicle and all vehicles of the same model imported by the same party until compliance is verified.

Tariff stacking. The fact sheet notes that products subject to tariffs under this proclamation will not be subject to (1) additional or existing Section 232 tariffs on steel, aluminum, copper, automobiles and automobile parts, and lumber, (2) “reciprocal” tariffs, or (3) tariffs imposed on Canada, Mexico, Brazil, or India. The proclamation also allows importers to declare a part to be subject to the Section 232 tariffs on automobiles or medium- or heavy-duty trucks if it is (1) not currently subject to such tariffs, (2) not classifiable under HTSUS Chapters 72, 73, or 76, and (3) used for auto or truck production or repair in the U.S.

Tariff reduction. The proclamation allows the DOC to reduce by up to 50 percent the Section 232 tariffs on steel and aluminum imported from Canada or Mexico and used by U.S. auto and truck manufacturers provided that those materials qualify under the USMCA and are smelted and cast or melted and poured in Canada or Mexico.

Scope expansion. The Secretary of Commerce can add more parts (MHDVPs) to the tariff list if imports threaten national security.

Foreign Trade Zones. Products admitted to an FTZ after 12:01 am on November 1 must be admitted in privileged foreign status.

Exemptions. Vehicles and buses manufactured 25+ years prior to entry are exempt.

ST&R offers a three-pronged approach for avoiding, mitigating, and/or recovering these and other tariffs. For more information on which of these strategies might be most effective for your business, please contact ST&R.

Section 232 Investigation

These actions result from a Section 232 investigation initiated April 25, 2025. The investigation assessed the national security risks related to imports of cargo trucks. The Secretary of Commerce concluded the investigation and transmitted a report with recommendations to the President.

This investigation covers the following:

medium-duty trucks; i.e., those with a gross vehicle weight of more than 10,000 and under 26,001 pounds
heavy-duty trucks; i.e., those with a gross vehicle weight rating of 26,001 pounds or more
individual components and systems of such trucks, including engines and engine parts, transmissions and powertrain parts, and electrical components