Section 232 Auto Parts Tariffs: Inclusions Process, Offsets, and What Importers Need to Know

What are Section 232 auto parts tariffs?

Section 232 tariffs impose a 25% duty on imported automobiles and certain automobile parts, authorized under Section 232 of the Trade Expansion Act of 1962 based on a finding that automotive imports threaten U.S. national security. The tariff on finished vehicles took effect April 3, 2025, with auto parts tariffs following on May 3, 2025. The scope of covered auto parts continues to expand through a quarterly inclusions process.

How does the Section 232 auto parts inclusions process work?

The Department of Commerce has established recurring two-week windows each quarter (January, April, July, and October) during which domestic manufacturers can submit requests to add new auto parts to the list of products subject to the 25% Section 232 tariff. The April 2026 window is open from April 1 through April 14, with accepted requests posted for a two-week public comment period.

Section 232 auto tariffs represent one of the most significant changes to the U.S. automotive trade landscape in decades. With a 25% duty on top of existing tariffs and an expanding list of covered parts, importers face growing compliance complexity. The tariff program interacts with USMCA preferences, bilateral trade deals (U.K., EU, Japan), and a temporary import adjustment offset designed to support domestic assembly. As the administration opens new quarterly windows for adding parts to the covered list, importers must continuously monitor which products fall within scope.

Last updated: March 2026

Which Vehicles and Parts Are Subject to Section 232 Tariffs?

Vehicles: Commercial vehicles including sedans, SUVs, crossover utility vehicles, minivans, cargo vans, and light trucks are subject to 25% Section 232 duties under HTS heading 9903.94.01. Medium and heavy-duty vehicles (MHDVs) and buses are also covered following a separate Section 232 investigation completed in early 2026.

Auto parts: The initial scope covered specific auto parts for passenger vehicles and light trucks. The parts list is not static. Through the quarterly inclusions process, domestic manufacturers can petition to add new parts to the tariff's scope. The International Trade Administration (ITA) reviews each request and posts accepted applications for public comment before making final determinations.

Key CBP clarifications:

Commercial vehicles are not excluded from Section 232 duties regardless of commercial use
Only auto parts for passenger vehicles and light trucks subject to Section 232 as of May 3, 2025 qualify for exemption from reciprocal tariffs under HTS heading 9903.01.33
U.S. government employees and service members returning from foreign assignments may bring personal vehicles duty-free under Chapter 98

There is currently no established process to remove parts from the Section 232 list once they are added, meaning tariff inclusions have potentially long-term consequences for pricing, availability, and competition.

How Do Trade Deals Affect Section 232 Auto Tariffs?

Several bilateral agreements modify the baseline 25% tariff rate for specific trading partners.

Country/Region	Auto Tariff Rate	Key Terms
General (no agreement)	25%	Full Section 232 rate
United Kingdom	10% (up to 100,000 vehicles)	25% above quota
European Union	15% (most vehicles)	Conditioned on EU implementing commitments
Japan	15%	Effective September 16, 2025
Canada/Mexico (USMCA)	0% on qualifying content	USMCA rules of origin apply

USMCA interactions: Auto parts that qualify for preferential treatment under USMCA may be eligible for HTS 9903.94.06, which can reduce or eliminate Section 232 duties. In January 2026, nearly 85% of imports from Canada and Mexico claimed USMCA exemptions, producing effective tariff rates below 5%. Proper origin documentation is critical; errors in USMCA qualification frequently trigger holds and additional duties.

What Is the Import Adjustment Offset?

The administration has implemented a two-year import adjustment offset designed to temporarily reduce Section 232 tariff costs for auto manufacturers that assemble vehicles in the United States.

The offset works as follows:

Year 1 (April 3, 2025 to April 30, 2026): Eligible manufacturers can apply for an offset equal to 3.75% of the aggregate Manufacturer's Suggested Retail Price (MSRP) of all U.S.-assembled vehicles
Year 2 (May 1, 2026 to April 30, 2027): The offset decreases to 2.5% of aggregate MSRP

Applications require detailed documentation, including final production forecasts by make, model, and plant location; aggregate MSRP values; projected tariff costs for imported auto parts; total offset amount calculations; importer of record information; and accuracy certifications. The Department of Commerce reviews each submission for completeness and monitors compliance.

Approved offset amounts remain valid until fully used, provided they were granted based on qualifying vehicles assembled in the U.S. during the applicable period.

How Do Section 232 Auto Tariffs Stack with Other Tariffs?

Tariff stacking is one of the most common sources of confusion and overpayment in the auto sector.

Section 232 automotive tariffs are assessed in addition to:

MFN (most-favored-nation) base duties
Antidumping and countervailing duties
Section 301 tariffs on Chinese-origin goods

Section 232 auto tariffs do not stack with:

Other Section 232 tariffs (e.g., steel/aluminum)
Section 122 tariffs

This means an auto part from China could face base duty + Section 232 (25%) + Section 301, but would not also face Section 122. Steel and aluminum tariffs under Section 232 follow separate stacking rules and can layer on top of each other for products subject to both.

GingerControl's Tariff Calculator covers the full U.S. tariff stack, including base duty, Section 232, Section 301, Chapter 99, and Section 122 tariffs across 200+ countries. For automotive importers navigating complex stacking rules, the calculator shows every duty component transparently and lets you compare total landed costs by origin country. Try the Tariff Calculator

What Should Automotive Importers Watch For?

Expanding parts scope. Each quarterly inclusions window adds new parts to the 25% tariff. Monitor the April 2026 window (April 1-14) and the subsequent public comment period. If parts relevant to your business are proposed for inclusion, submit comments during the two-week review period via Docket ID ITA-2025-0040 on Regulations.gov.

USMCA qualification audits. With nearly 85% of Canadian and Mexican auto imports claiming USMCA preferences, CBP is likely to increase scrutiny of origin documentation. Ensure your rules of origin calculations and supporting records are audit-ready.

Offset program transitions. The offset rate drops from 3.75% to 2.5% on May 1, 2026. Manufacturers should model the financial impact of this reduction and plan import timing accordingly.

HTS classification accuracy. Whether an auto part falls within the Section 232 scope depends on its HTS classification. Misclassification can result in either overpayment (applying Section 232 to non-covered parts) or underpayment and penalties (failing to apply Section 232 to covered parts). GingerControl is a pre-classification research tool that follows GRI logic and asks clarifying questions before assigning a classification, producing audit-ready reports grounded in Section Notes, Chapter Notes, and relevant cross rulings. Try the Classifier

FAQ

What is the Section 232 auto parts inclusions process?

The Department of Commerce holds quarterly two-week windows (January, April, July, October) during which domestic manufacturers can petition to add new auto parts to the 25% Section 232 tariff scope. After the submission window closes, accepted requests are posted for public comment before ITA makes final determinations.

Are all auto parts subject to Section 232 tariffs?

No. Only auto parts specifically listed in the scope of the Section 232 proclamation are subject to the 25% tariff. The list expands through the quarterly inclusions process. Importers should check whether their specific HTS codes fall within the current scope before each entry.

How does USMCA affect Section 232 auto tariffs?

Auto parts that meet USMCA rules of origin may qualify for reduced or eliminated Section 232 duties under HTS 9903.94.06. Nearly 85% of imports from Canada and Mexico were claiming USMCA exemptions as of January 2026. Proper documentation is essential, as errors frequently trigger duty assessments and shipment holds.

What is the import adjustment offset for auto manufacturers?

The offset allows U.S. vehicle assemblers to reduce Section 232 tariff costs on imported parts. The rate is 3.75% of aggregate MSRP for vehicles assembled through April 30, 2026, dropping to 2.5% through April 30, 2027. Applications require detailed production and cost documentation submitted to the Department of Commerce.

Can GingerControl help with HTS classification for auto parts?

GingerControl's HTS Classifier follows GRI logic and asks clarifying questions to converge on the correct classification, producing audit-ready reports with full reasoning chains. This is especially important for auto parts, where classification determines both the applicable duty rate and whether Section 232 tariffs apply. Try the Classifier

Do Section 232 auto tariffs apply to electric vehicles?

Yes. Section 232 tariffs apply to automobiles regardless of drivetrain type. Electric vehicles imported from countries without bilateral agreements face the full 25% tariff. USMCA-qualifying EVs from Canada and Mexico may be exempt, subject to rules of origin compliance.

Section 232 auto tariffs interact with USMCA preferences, bilateral deals, stacking rules, and a shifting inclusions list. GingerControl's Tariff Calculator models every layer so you can see your true landed cost before shipment.

GingerControl is not just a tool. We work with importers and trade compliance teams on process consulting, digital transformation strategy, and end-to-end custom system development. Talk to our team

References

[REF 1] Federal Register, "Notice of the Opening of the Inclusions Window for the Section 232 Automobile Parts Tariff Inclusions Process" Data cited: April 2026 window dates, submission process, docket number Source: Federal Register Published: March 24, 2026

[REF 2] U.S. Department of Commerce, "New Auto Tariff Offset Process" Data cited: Offset rates (3.75%/2.5%), documentation requirements, timeline Source: Commerce Department Published: 2025

[REF 3] CBP, "Section 232 Additional FAQs: Automobiles and Auto Parts" Data cited: USMCA interactions, commercial vehicle scope, government employee exemptions Source: CBP FAQs Published: Updated 2026

[REF 4] Congressional Research Service, "Section 232 Automotive Tariffs: Issues for Congress" Data cited: Trade deal rates (UK, EU, Japan), offset calculations, stacking rules Source: CRS report IN12545 Published: March 2026

[REF 5] Penn Wharton Budget Model, "Effective Tariff Rates and Revenues" Data cited: 85% USMCA claim rate, Canada/Mexico ETR below 5% Source: Penn Wharton Published: March 16, 2026

[REF 6] White & Case, "Trump administration posts proposed automotive parts Section 232 tariff expansion" Data cited: January 2026 inclusions round, ITA review process, October 2025 pending decisions Source: White & Case Published: January 2026