Annex of Autos and Auto Parts Subject to 25% Tariffs Under Section 232 Is Released

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On April 2, 2025, President Trump published the Annex of automobiles and automobile parts subject to tariffs pursuant to Section 232 of the Trade Expansion Act of 1962. This follows the President’s March 26, 2025 Proclamation announcing the forthcoming 25% tariffs on certain vehicles and related parts, which we previously reviewed here. This Annex now identifies by Harmonized Tariff Schedule (“HTS”) code those autos and auto parts subject to the duties.

Automobiles

Section 232 tariffs on passenger vehicles and light trucks listed in Section A of the Annex will take effect at 12:01 a.m. eastern time on April 3, 2025. The list of covered vehicles includes sedans, sport utility vehicles, crossover utility vehicles, minivans, cargo vans, and light trucks. Vehicles manufactured 25 years or more prior to the year of entry will be exempt from the tariffs.

Vehicles qualifying for preferential treatment under the United States-Mexico-Canada Agreement (“USMCA”) will not be subject to the tariffs until the Commerce Department establishes a process to apply the tariff exclusively to the value of the non-U.S. content of such automobile parts and publishes notice in the Federal Register.

Automobile Parts

Section 232 tariffs on automobile parts listed in the Annex will take effect at 12:01 a.m. eastern time on May 3, 2025.

The full list of auto parts subject to the tariffs is contained in section B of the Annex and includes HTS codes from chapters 40, 70, 73, 83, 84, 85, 87, 90 and 94.

Similar to autos, auto parts qualifying for preferential treatment under the USMCA will not be subject to the tariffs until the Commerce Department establishes a process to pay the duties exclusively on the value of the non-U.S. content of such automobile parts and publishes notice in the Federal Register.

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