The President has issued a proclamation invoking a Section action covering buses, medium- and heavy-duty trucks, and their parts. The new tariffs are scheduled to be effective on November 1. The proclamation sets the additional tariff for medium- and heavy-duty trucks and their parts at 25% and adds a 10% tariff on buses, transit buses, and motor coaches.
Class 3 to Class 8 vehicles — such as large pickups, moving trucks, cargo trucks, and tractors for 18-wheelers — are covered by this action. Medium- and heavy-duty trucks will be assessed the tariff based on their full value unless they qualify for entry under USMCA. These vehicles, if USMCA eligible, will have the tariff assessed only on the value of the non-US content of the vehicle, if provided. According to the White House fact sheet announcing the tariffs, truck parts are said to apply to major parts, such as engines, transmissions, tires, and chassis. However, the annex includes a significant number of HTS codes that will be considered to be under these tariffs. Parts eligible for entry under USMCA will not be subject to the additional tariffs until the Department of Commerce (DOC) establishes a process to allow the tariffs to be applied to the non-US content, as is being done with the full vehicles. The annex including all the HTS codes which fall under the additional tariffs and the rules governing their application may be found here. The full text of the Presidential Proclamation can be found here and the fact sheet issued by the White House can be found here.
There are provisions to exempt parts that are not for use with medium- or heavy-duty trucks; however, these parts may fall under the recent Section 232 action on light trucks and passenger vehicles.
The proclamation offers incentives to domestic manufacturers by offering offsets to a portion of the tariffs on medium- and heavy-duty truck parts based on the value of all trucks assembled in the US. This offset is scheduled to apply from 2025 to 2030, and it can be used to adjust the Section 232 tariffs owed by a truck manufacturer. A similar offset will be established for domestic manufacturers of engines for medium- and heavy-duty trucks.
According to the fact sheet, products subject to these tariffs will not be subject to other Section 232 tariffs (steel, aluminum, etc.), the IEEPA reciprocal tariffs, and the additional IEEPA tariffs imposed on Canada, Mexico, China, Brazil, and India.
Best Regards,
Sam McClure, LCB
Director of Compliance & Customs Services