On March 26, 2025, President Trump issued Proclamation 10908—Adjusting Imports of Automobiles and Automobile Parts into the United States—that imposed an additional 25% tariff on all imports of automobiles and certain automobile parts pursuant to Section 232 of the Trade Expansion Act of 1964, as amended (19 U.S.C. § 1862), based on the Section 232 investigation carried out by the Secretary of Commerce during the first Trump administration.
When the Proclamation was initially issued, it did not include Annex I, which would identify the automobile parts subject to the new tariff. On April 3, 2025, Proclamation 10908—attaching Annex I—was published in the Federal Register.
Proclamation 10908 imposes the following additional tariffs:
With respect to automobiles described in the Harmonized Tariff Schedule (HTS) subheadings listed in paragraph A.a of Annex I[1] that are entered into the United States for consumption on or after 12:01 a.m. Eastern Daylight Time on April 3, 2025:
- Such automobiles that are not eligible for preferential duty treatment under the United States-Mexico-Canada Agreement (USMCA) are subject to a 25% tariff on their entire customs value;
- Such automobiles that are eligible for USMCA preferential duty treatment are subject to a 25% tariff on the value of all non-U.S. content;
- Vehicles that are not “sedans, sport utility vehicles, crossover utility vehicles, minivans, cargo vans, or light trucks,” and vehicles at least 25 years old at the time of importation, are exempt from the tariff.
With respect to automobile parts described in the HTS subheadings listed in paragraph B.a of Annex I[2] that are entered into the United States for consumption on or after 12:01 a.m. Eastern Daylight Time on May 3, 2025:
- Such parts are subject to a 25% tariff on their entire customs value except that …
- Such parts that are not for “sedans, sport utility vehicles, crossover utility vehicles, minivans, cargo vans, or light trucks” are exempt from the tariff;
- Such parts that are eligible for USMCA preferential duty treatment[3] are presently exempt from the tariff, and will become subject to a 25% tariff on the value of all non-U.S. content once the Secretary of Commerce issues regulations for apportioning the tariffs.
Like the recent steel and aluminum tariff proclamations, Proclamation 10908 also instructs the Secretary of Commerce to establish, within 90 days, a process for the extension of the 25% tariff to additional auto parts.
[1] The listed HTS subheadings encompass all passenger road vehicles except gasoline cars with engines smaller than 1000 cc; all gasoline, diesel, or hybrid cargo vehicles with a gross vehicle weight not exceeding 5 metric tons; and all fully electric cargo vehicles.
[2] The listed HTS subheadings include:
- Metal parts: springs and parts thereof, locks, metal mountings and fittings, bearings, chassis fitted with engines, bodies and parts and accessories thereof, bumpers and parts thereof, wheels and parts thereof, radiators and parts thereof, other cast iron parts;
- Glass parts: glass panels (other than windshields), rear-view mirrors, windshields;
- Rubber parts: brake hoses, tires and inner tubes, rubber mechanical parts, vibration control parts containing rubber;
- Mechanical parts: engines and parts thereof, pumps for liquids and gases, jacks and parts thereof, cranes/lifting machinery, transmission shafts, safety belts, brakes and parts thereof, gear boxes and parts thereof, drive axles and parts thereof, suspension systems and parts thereof, clutches and parts thereof, steering wheels/columns/boxes and parts thereof, wheel hub units, other parts of power trains;
- Electrical parts: computers, air conditioners, electric motors, batteries and parts thereof, ignition or starting equipment and parts thereof, lights and signals and parts thereof, horns and parts thereof, radar detectors and parts thereof, windshield wipers/defrosters/demisters and parts thereof, audio systems/radios/CB radios, signaling flashers, electrical boards and panels, lamps, ignition wiring sets, airbag systems and parts thereof;
- Miscellaneous parts: filters, other parts of trailers, rangefinders, taximeters/odometers/speedometers/tachometers, and seats.
[3] “Automobile knock-down kits” and “parts compilations” are excluded from the USMCA exemption (and would presumably be treated akin to complete automobiles).
