Customs and consulting service alert
Presidential Proclamation raises tariffs on Medium- and Heavy-Duty Trucks, effective November 1
Dear Valued Customer,
On October 17, 2025, President Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, taking significant action to adjust imports of medium- and heavy-duty vehicles (MHDVs), certain vehicle parts (MHDVPs), and buses into the United States. This decision follows a formal investigation by the Department of Commerce, which concluded that the rising volume and growing reliance on foreign-made MHDVs, key parts, and buses threaten to impair U.S. national security.
The Department found that MHDVs and their components play a critical role in supporting military logistics, emergency response, and national infrastructure. The U.S. currently imports nearly half of the Class 8 vehicle market (the heaviest commercial trucks), with foreign penetration reaching 43% across all medium and heavy-duty classes. Additionally, the domestic industry is increasingly dependent on foreign sources for critical parts such as engines, batteries, and drive systems—many of which have limited or no domestic production capacity.
To address these concerns, the President has ordered the imposition of new tariffs. Effective November 1, 2025, a 25% ad valorem duty will apply to covered MHDVs and designated MHDV parts as outlined in Annex I of the proclamation. Buses, classified under HTSUS heading 8702, will be subject to a 10% duty. These rates are in addition to any existing duties or fees.
The proclamation provides some flexibility for importers under the United States-Mexico-Canada Agreement (USMCA). Qualified MHDVs and, in the future, eligible parts, may be assessed the tariff only on the non-U.S. content of the goods, subject to approval by the Secretary of Commerce. A similar provision will be developed for MHDVPs, though implementation details are pending.
Manufacturers with final assembly operations in the United States may benefit from an import adjustment offset, which offers relief equivalent to the duty burden on 15% of a vehicle’s value. Specifically, eligible manufacturers can receive an offset amounting to 3.75% of the total value of U.S.-assembled MHDVs annually through October 2030. These offsets can only be used to reduce tariff liabilities for the specific manufacturer and their authorized importers.
Strict compliance measures will be enforced by U.S. Customs and Border Protection (CBP). Misstatements of U.S. content will result in full tariff liability on the affected goods and potentially on all similar imports from the same importer until the issue is resolved. Furthermore, knock-down kits and similar parts shipments designed for domestic assembly will be fully dutiable, regardless of preferential origin claims or offsets.
Imports into Foreign Trade Zones (FTZs) will also be impacted. Any subject goods admitted into an FTZ on or after the effective date must be placed under privileged foreign status, making them subject to duty upon withdrawal.
Lastly, the proclamation limits the availability of duty drawback. Only manufacturing drawback claims under 19 U.S.C. 1313(a)-(b) will be permitted, excluding other forms of substitution or unused merchandise drawback.
The Proclamation can be found here and the Annex to the Proclamation can be found here.
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