CBP Issues Guidance on USMCA-Eligible Vehicle Import Tariffs

With the 25% duty only applying to non-U.S. content, the new filing rule offers cost-saving opportunities for importers of USMCA-eligible vehicles.

CBP has issued new guidance for U.S. importers on how to apply vehicle import tariffs, following the signing of Proclamation 10908 on April 3, 2025.

The updated rule allows passenger vehicles and light trucks that qualify for preferential treatment under USMCA to be assessed the 25% Section 232 tariff only on their non-U.S. content.

The U.S. Department of Commerce has also issued a supporting rule on May 20, 2025, with details on submission requirements.

How to apply the new tariff structure

To benefit from the revised tariff rule, importers must split each customs entry into two lines as shown below: 

HTSUS 9903.94.03 applies the 25% Section 232 duty to the non-U.S. content of USMCA-qualifying passenger vehicles and light trucks, provided the vehicle has been approved by the Secretary of Commerce.

HTSUS 9903.94.02 applies 0% duty on imports classified under Chapter 87 HTSUS that fall under U.S. Note 33(b) to Subchapter III of Chapter 99, subject to Section 232 duties. This includes:

1. Imports that are not passenger vehicles or light trucks, and
2. The U.S. content of passenger vehicles and light trucks that have received approval under HTSUS 9903.94.03.

Both entry lines must report the same Chapter 1-97 HTSUS, country of origin, and all other applicable duties (such as anti-dumping or countervailing duties).

For U.S. content entries, report the entered value of the U.S. content by subtracting the value of the non-U.S. content from the entered value of the article.

Note that the 25% tariff will apply to USMCA-qualifying goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on April 3, 2025.

To prevent entry rejections or delays, please ensure your ACE formatting is correct. You can contact your CBP Client Representative for any questions about entry rejections.

Submission guidelines for entire model lines

When seeking preferential tariff treatment for the U.S. content of your automobiles, you may submit documentation on a model line basis for your automobile imports that qualify for preferential treatment under the USMCA.

You must, however, identify the type and value of U.S. content attributable to each model line.

To meet CBP requirements, the following must be included in each submission:

1. The total declared customs value of a vehicle in the model line at the time of importation (based on 19 U.S.C. 1401a). If customs values vary across a model line, importers can use averaging methods as defined under Annex 4-B, Article 5 of the USMCA Automotive Appendix.
2. The total value of U.S. content, calculated based on parts wholly obtained, produced entirely, or substantially transformed in the U.S. Averaging is also allowed when values vary across the model line.
3. The total value of non-U.S. content, calculated by subtracting the U.S. content from the vehicle’s total value. Averaging rules also apply here.
4. Vehicle production locations and the country of final assembly, which may include several countries.
5. Proof of USMCA eligibility, including a signed origin certification and evidence that the vehicle meets both the North American steel and aluminum requirements and the North American labour value content requirements. If the model line follows an approved Alternative Staging Regime, this should also be indicated (as outlined in Article 8 of Chapter 4 of the USMCA Automotive Appendix).
6. Basic vehicle and importer information, including importer name and importer of record number, manufacturer details, country of origin, and year/make/model for each model line. If requesting retroactive relief, entry numbers for previously imported vehicles must also be provided.

All submissions must be signed by a senior company officer, such as a CFO or General Counsel, and sent to the Department of Commerce at Autos232USMCAContent@trade.gov. 

It is important to note that this tariff relief is available only for vehicles imported from Canada or Mexico that fully qualify under USMCA rules of origin.

Next steps for U.S. importers

To ensure compliance with the rules of USMCA-eligible vehicle import tariffs, we recommend that you take immediate action.

Here are the steps to follow:

• Review your supply chain and supporting documentation to confirm that your imported vehicles qualify for preferential treatment under USMCA.
• Coordinate with your customs broker to implement the required dual-line entry format in ACE.
• Keep detailed records to support the declared non-U.S. content value (as required by the Department of Commerce). 

How Cole International can help

At Cole International, we constantly monitor changing trade regulations and offer customs and compliance consulting services to help businesses navigate these changes.

Additionally, we provide timely and efficient customs brokerage services to help U.S. importers streamline their customs clearance and other import processes. 

Please reach out to one of our trade professionals to discuss how we can help streamline the entry of your USMCA-eligible vehicles and ensure you only pay duties on non-U.S. components.