On April 23, 2025, the Trump Administration issued a pre-publication federal register notice scheduled to be published on April 25, 2025. The notice seeks public comments following the April 22, 2025, initiation of an investigation targeting imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts, and their derivative products (collectively, “trucks and truck parts”) pursuant to Section 232 of the Trade Expansion Act of 1962. The Trump Administration claims that imports of trucks and truck parts are a threat to national security.
The Section 232 investigation on imports of truck and truck parts covers “medium-duty trucks,” meaning trucks with a gross vehicle weight of more than 10,000 and under 26,001 pounds. The investigation also covers “heavy-duty trucks,” meaning trucks with a gross vehicle weight rating of 26,001 pounds or more, and “medium- and heavy-duty truck parts,” referring to the individual components and systems of medium- and heavy-duty trucks, including engines and engine parts, transmissions and powertrain parts, and electrical components. The Administration is soliciting public comments on the following aspects of the truck and truck parts supply chain:
- The current and projected demand for trucks and truck parts in the United States;
- The extent to which domestic production of trucks and truck parts can meet domestic demand;
- The role of foreign supply chains, particularly of major exporters, in meeting United States demand for trucks and truck parts;
- The concentration of United States imports of trucks and truck parts from a small number of suppliers and the associated risks;
- The impact of foreign government subsidies and predatory trade practices on the competitiveness of the medium- and heavy-duty truck industry in the United States;
- The economic impact of artificially suppressed prices of trucks and truck parts due to unfair foreign trade practices and state-sponsored overproduction;
- The potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over supplies of trucks and truck parts;
- The feasibility of increasing domestic capacity for trucks and truck parts to reduce reliance on imports; and
- The impact of current trade policies on domestic production of trucks and truck parts, and whether additional measures, including tariffs or quotas, are necessary to protect national security.
Comments are due no later than 21 days from the date of publication of the notice in the federal register. In the event the date of publication is April 25, 2025, as anticipated, comments would be due by May 16, 2025. The notice provides specific guidance on submitting comments that include business confidential information.
Importers and manufacturers in the medium- and heavy-duty trucks and truck parts supply chain that may be impacted by potential tariffs are advised to review the notice and consider submitting comments.
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