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New heavy truck tariffs: What to know about the Section 232 proclamation

Date of publication: October 22, 2025

Summary

On October 17, 2025, President Trump signed a proclamation imposing significant new tariffs on medium- and heavy-duty vehicles (MHDVs), medium- and heavy-duty vehicle parts (MHDVPs), and buses under Section 232 of the Trade Expansion Act of 1962. The tariffs,
effective November 1, 2025
, impose a 25% ad valorem duty on MHDVs and key MHDVPs and a 10% ad valorem duty on buses, based on national security grounds.
This proclamation represents a major expansion of Section 232 trade actions and will significantly impact supply chains for commercial vehicles, parts manufacturers, and companies relying on heavy truck transportation.
Section 232 investigation
The Secretary of Commerce transmitted a report finding that MHDVs, certain MHDVPs, and buses are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States.

Tariff structure and rates

Base tariff rates
All imports of MHDVs and the MHDVPs specified in Annex I shall be subject to a 25 percent ad valorem duty rate, except for buses and other vehicles classified in HTSUS heading 8702, which shall be subject to a 10 percent ad valorem duty rate, effective November 1, 2025 at 12:01 a.m. eastern daylight time.
Covered products
MHDVs
: The tariffs apply to medium- and heavy-duty vehicles including Class 4-8 trucks classified under numerous HTSUS subheadings including:
  • 8701.21.00-8701.29.00 (tractors)
  • 8704.10.10-8704.90.01 (motor vehicles for transport of goods)
  • 8706.00.03-8706.00.50 (chassis fitted with engines)
Buses
: Vehicles classified under HTSUS heading 8702 (motor vehicles for transport of ten or more people)
MHDVPs
: A comprehensive list of parts specified in Annex I, including:
  • Engines and engine parts (8407.34.xx, 8408.20.xx, 8409.xx.xx)
  • Transmissions and powertrain components (8483.10.10)
  • Electrical components (8501.xx.xx, 8511.xx.xx, 8512.xx.xx)
  • Body parts and assemblies (8708.xx.xx series)
  • Tires, batteries, brakes, and numerous other components
Additional MHDVP designation process
The Secretary shall establish a process for including additional MHDVPs within the scope of the tariffs, and may add MHDVPs if it is determined that inclusion of the import will reduce or eliminate the national security threat, considering factors including whether imports have increased in a manner that threatens national security or undermines the objectives of the proclamation. The process may include provisions for receiving information and requests from domestic producers or other interested parties.

Special provisions for USMCA-qualifying products

U.S. content calculation for MHDVs
For MHDVs (except buses) that qualify for preferential tariff treatment under USMCA, importers may submit documentation to the Secretary identifying the amount of United States content in each model, and the Secretary may approve imports to be eligible to apply the 25 percent duty rate exclusively to the value of the non-United States content of the MHDV.
Critical requirements
:
  • Documentation must be submitted to the Secretary of Commerce
  • U.S. content refers to value attributable to U.S.-based activity supporting domestic production.
  • Non-U.S. content = Total value - U.S. content
  • Secretary approval required before preferential treatment applies.
MHDVP treatment under USMCA
Imports of individual MHDVPs that qualify for preferential tariff treatment under USMCA shall not be subject to the additional ad valorem duty rate until the Secretary establishes a process to apply the tariff exclusively to the value of the non-United States content and publishes a notice in the Federal Register.
important
Exception
: Imports of MHDV knock-down kits or equivalent parts compilations shall continue to be subject to the additional ad valorem duty rate regardless of USMCA preferential treatment qualification.

Integration with other Section 232 tariffs

Tariff stacking rules
The application of multiple tariffs (stacking) for imports of MHDVs, MHDVPs, and buses shall follow the same rules for stacking for imports subject to Proclamation 10908 (automobile tariffs).
Exemptions from other Section 232 & reciprocal tariffs
The proclamation specifically exempts MHDVs and MHDVPs from:
  • Additional duties on semi-finished copper products (heading 9903.78.01)
  • Additional duties on aluminum products (headings 9903.85.02, 9903.85.12)
  • Additional duties on derivative aluminum products (headings 9903.85.04, 9903.85.07, 9903.85.08, 9903.85.13, 9903.85.14, 9903.85.15)
  • Additional duties on iron or steel products (headings 9903.81.87, 9903.81.88, 9903.81.94, 9903.81.95)
  • Additional duties on derivative iron or steel products (headings 9903.81.89, 9903.81.90, 9903.81.91, 9903.81.93, 9903.81.96, 9903.81.97, 9903.81.98, 9903.81.99)
  • Additional duties on articles from Canada (heading 9903.01.10)
  • Additional duties on articles from Mexico (heading 9903.01.01)
  • Additional duties on lumber/wood products (headings 9903.76.01, 9903.76.02, 9903.76.03)
  • Additional duties for India-specific tariffs (heading 9903.01.84)
  • Additional duties for Brazil-specific tariffs (heading 9903.01.77)
  • Reciprocal tariffs covering all countries.
This exemption structure prevents excessive duty accumulation but requires careful classification analysis.

Import adjustment offset program

Eligibility and calculation
For MHDVs assembled in the United States, MHDV manufacturers may apply to the Secretary for an import adjustment offset amount equal to 3.75 percent of the aggregate value of all MHDVs assembled in the United States by that manufacturer from November 1, 2025, through October 31, 2030.
Key program features
Rationale
: The percentage rate reflects the total duty that would be owed when a 25 percent duty is applied to parts accounting for 15 percent of an MHDV's value.
Restrictions
:
  • Only MHDVs that undergo final assembly in the United States are eligible to be included in this calculation.
  • A manufacturer's import adjustment offset amount may be used only to offset tariff liability related to that manufacturer's MHDVP tariff liability.
  • The manufacturer's import adjustment offset amount may be used only by importers of record authorized by that manufacturer.
Engine manufacturer program
: The Secretary shall establish a process for MHDV engine manufacturers equivalent to the MHDV manufacturer process, with import adjustment offsets based on the aggregate value of MHDV engines assembled by that manufacturer in the United States.
Secretary authority
: If the Secretary finds that the import adjustment offset program for a particular product is inconsistent with addressing the threat to national security, the Secretary may publish in the Federal Register a notice that prospectively prohibits MHDV or MHDV engine manufacturers from using offset amounts for imports of those products.
Knock-down kit exclusion
: Imports of MHDV knock-down kits or other equivalent parts compilations shall not be eligible for import adjustment offsets.

Conforming changes to automobile tariff program

Import adjustment offset modifications
The proclamation revises Proclamation 10925 to establish that automobile manufacturers may apply for an import adjustment offset amount equal to 3.75 percent of the aggregate MSRP value of all automobiles assembled in the United States from April 5, 2025, through April 30, 2030.
Cross-program offset usage
A manufacturer's import adjustment offset amount may be used only to offset tariff liability related to that manufacturer's automobile parts tariff liability under Proclamation 10908 or under the MHDV proclamation.This creates flexibility for manufacturers producing both automobiles and MHDVs to utilize offsets across programs.

Steel and aluminum tariff modifications

Reduced rates for USMCA suppliers
The Secretary is authorized to reduce tariffs owed under Proclamation 9704 (aluminum) and Proclamation 9705 (steel) by up to half the applicable rate for aluminum or steel producers that operate production facilities in Canada or Mexico and supply United States automobile or MHDV manufacturers, limited to quantities of aluminum or steel equal to newly committed United States production capacity.
Limitations
:
  • In no cases shall the adjusted rate be lower than 25 percent.
  • Rate adjustments shall be limited to imports of aluminum and steel that qualify for preferential tariff treatment under USMCA and that were smelted and cast or melted and poured in Canada or Mexico.

Automobile and MHDV parts declaration provision

New classification option
An importer of record may declare an automobile part or MHDVP as subject to the automobile parts tariff or to the MHDVP tariff if the part meets specified conditions, including that it cannot be presently subject to these tariffs, cannot be classifiable in Chapters 72, 73, or 76 of the HTSUS, and must be used for automobile- or MHDV-related production or repair activity in the United States. This provision creates flexibility but requires careful certification and recordkeeping.

Drawback limitations

As of the effective date, only manufacturing drawback claims made in accordance with subsections (a) and (b) of section 313 of the Tariff Act of 1930 shall be available with respect to the duties imposed on MHDVPs and automobile parts. The Secretary may adjust a company's offset accrual amount as necessary to avoid awarding excessive offset accrual benefits for United States-assembled vehicles production that receives drawback benefits upon exportation.

Foreign Trade Zone treatment

Any product subject to tariffs pursuant to this proclamation that is admitted into a United States foreign trade zone on or after November 1, 2025, must be admitted in "privileged foreign status" and will be subject upon entry for consumption to any duties related to the classification under the applicable HTSUS subheading. This eliminates the ability to defer duties through FTZ admission in domestic status.

Antidumping and countervailing duties

The proclamation explicitly states that antidumping, countervailing, or other duties continue to apply in addition to Section 232 tariffs.
Companies must:
  • Continue paying any existing AD/CVD in addition to new 25% MHDV tariff.
  • Monitor for new AD/CVD investigations on MHDVs or MHDVPs
  • Consider total duty burden when making sourcing decisions.

Vintage vehicle exemption

The tariffs shall not apply to MHDVs or buses that were manufactured in a year at least 25 years prior to the date of entry. This exemption protects collectors and importers of classic commercial vehicles.

Compliance and enforcement provisions

Verification and penalties
If CBP determines that the declared value of non-United States content is inaccurate due to an overstatement of United States content, the 25 percent tariff shall apply to the full value of the MHDV, regardless of the actual United States content, and shall be applied to the full value of all MHDVs of the same model imported by the same importer from the date of the inaccurate declaration until compliance is verified by CBP.This represents a significant enforcement mechanism that could result in:
  • Retroactive duty assessment on full vehicle value
  • Ongoing enhanced scrutiny of all similar imports
  • Substantial financial penalties for non-compliance

Conclusion

The October 17, 2025, proclamation represents a fundamental shift in the regulatory environment for medium and heavy-duty vehicles, parts, and buses. The 25% tariff on MHDVs and MHDVPs will significantly impact supply chains, pricing, and sourcing decisions throughout the commercial vehicle industry.
Companies should act quickly to:
  1. Assess their exposure and calculate financial impact.
  2. Implement compliance programs to ensure accurate duty payment.
  3. Pursue available mitigation strategies (U.S. content documentation, import adjustment offsets, USMCA qualification)
  4. Make strategic decisions about sourcing, manufacturing location, and supply chain structure.
The complexity of the tariff structure—with its U.S. content calculations, import adjustment offsets, interactions with other Section 232 tariffs, and severe penalties for non-compliance—requires careful attention from trade compliance, supply chain, legal, and finance teams. Companies should consult with customs brokers, trade counsel, and tax advisors to develop comprehensive strategies tailored to their specific circumstances. Additional information is provided on the White House Fact Sheet.
For more information on how ONESOURCE Global Trade solutions can assist you in managing supply chain risk and regulatory compliance, contact your Account Manager or Client Success Manager.