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President Trump issued a proclamation on Oct. 17 to impose new global Section 232 tariffs on trucks and parts. New tariffs will apply to Class 3 through 8 vehicles, which include medium- and heavy-duty vehicles (MHDVs), parts used to make those vehicles, as well as buses that include school buses, city buses, motor coaches and similar vehicles.

• The full list of applicable HS codes is found in Annex I to the proclamation.

Two tariff rates: MHDVs and MHDV parts will be assessed a 25% ad valorem rate.

• Buses and other vehicles under HS 8702 will be assessed a 10% ad valorem rate.

Timing: Tariffs will apply to goods entered for consumption or withdrawn from warehouse for consumption on Nov. 1.

USMCA-qualifying goods: For trucks (not buses) that qualify for United States–Mexico–Canada Agreement treatment, documentation can be provided to the Commerce Department identifying the amount of U.S. content in each imported truck or bus model. Then the value of the U.S. content can be subtracted from the total value of the truck for the purpose of assessing the 25% Section 232 tariff.

• For MHDV parts that qualify for USMCA treatment, no Section 232 tariff will apply until such time that the Commerce Department, with Customs and Border Protection, can establish a process to exclude U.S. content from the 25% calculation.
• The Section 232 tariff will apply to MHDV knock-down kits regardless of USMCA qualification.

Steel and aluminum: The Oct. 17 proclamation modifies the March 8 proclamations imposing Section 232 tariffs on steel and aluminum products.

• The Secretary of Commerce can reduce steel and aluminum tariffs by up to half the applicable rate, but no lower than 25% for aluminum and steel producers that operate production facilities in Canada or Mexico and that supply U.S. auto or MHDV producers.
• Aluminum and steel must qualify for USMCA preferential tariff treatment and meet “smelting and cast” or “melted and poured” in Canada or Mexico rules.
• Tariff adjustments must be limited to quantities of aluminum or steel “equal to newly committed U.S. production capacity” as determined by the Secretary of Commerce. How this will be calculated is not elaborated in the proclamation.

Other provisions: The NAM’s trade experts outlined the other provisions of this detailed proclamation here . Please send any feedback or questions about the proclamation to NAM Vice President of International Policy Andrea Durkin.