Automotive & Parts Auto parts import compliance
Know which 232 bucket each part is in.
One aluminum housing can land in the auto-parts tariff, the metals tariff or USMCA relief. GingerOS keeps the call, the reason and the full stack on every part number, for every plant.
GingerOS- HTS
8507.90.8000- Origin
- Mexico
- Imported by
- Saltillo plant, MX
- Entry
- 10/06/2026
Duty stackTotal duty28.4%
- Base duty (MFN)
3.4% - Section 232, auto parts
9903.94.0525% - Section 232, aluminumNote 33(f): listed auto parts stay outside the metals duty
9903.82.02Not applied - Section 301, forced laborNote 52(f): Section 232 auto parts are exempt
9903.05.55Not applied
Plus MPF 0.3464%, and HMF 0.125% by ocean
Why As a battery part (CBP ruling N348886) it is in the 25% auto-parts bucket, not the 50% aluminum one. If the Saltillo plant's USMCA claim holds, it enters under 9903.94.06 and the 28.4% drops to zero.
A GingerOS part record with demo data for automotive & parts: Aluminum EV battery housing, HTS 8507.90.8000, from Mexico. Each duty layer is listed with its rate or exemption, for a total duty of 28.4%.
What tariffs hit imported auto parts now?
Section 232 sets the bucket: 25% for listed auto parts, 50% or 25% for metal articles, and USMCA can zero the auto-parts duty.
Imported auto parts on the Section 232 list pay 25% on top of the base rate, or nothing extra when the part qualifies under USMCA. A part coded as a steel or aluminum article pays the metals duty instead, 50% or 25% on full value since April 6, 2026, with no USMCA relief. Section 232 auto parts are exempt from the forced-labor Section 301 that took effect July 24, 2026. Chinese parts still pay their China-list 301, and Korean parts pay a combined 15%.
Recent Policy UpdatesNotices that touch auto parts
- Presidential ProclamationProclamation 10984Truck parts at 25%, auto-part drawback, a declare-in heading and a 2030 offset
Manufacturing drawback now covers Section 232 auto-part duty, and a certified part off the list can be declared into the 25% auto tariff.
9903.74.01 to .10; 9903.94.07Read the explainer - Federal Register Notice90 FR 55964Korean cars and covered auto parts move to a 15% all-in Section 232 rate
Korean parts on the auto list pay a combined 15%, or nothing extra when the base rate is already 15% or more.
9903.94.60 to 9903.94.63 - Presidential ProclamationProclamation 11021Metals 232 moves to full value; parts off the auto list pay 50% or 25%
A part coded to an aluminum or steel line pays the metals duty on its whole value; listed auto parts stay outside it.
Ch. 72, 73, 74, 76 and listed derivativesRead the explainer - Federal Register Notice91 FR 47318Forced-labor Section 301 replaces Section 122; Section 232 auto parts are exempt
Parts outside both the 232 lists and USMCA pay 10% from Mexico and Canada and 12.5% from China.
9903.05.20 to 9903.05.84; exemption 9903.05.90Read the explainer
A Compliance Radar feed of 4 recent policy updates that touch automotive & parts, each with its source, reference and effective date.
Is this housing a battery part or aluminum?
As a battery part it sits in the 25% auto bucket, with USMCA relief; as an aluminum article it pays 50% on full value.
Die-cast aluminum bottom enclosure that holds the EV battery modules. Made at our Saltillo plant.
Ginger asksDoes it only hold and protect the battery modules, or is it also a load-bearing body or chassis member?
It only holds the modules. No body or chassis mounts.
8507.90.8000HTS rate 3.4%
Parts of electric storage batteries: other
Section 232 auto parts: 25%, or 0% under USMCA (9903.94.06)
7616.99.5190HTS rate 2.5%
Other articles of aluminum: other
Section 232 aluminum: 50% of full value, no USMCA relief
Deciding rule Section XV Note 1(f) keeps Section XVI goods out of Chapter 76; Section XVI Note 2(b) sends a part used solely or principally with one kind of machine to that machine's heading. CBP ruling N348886 (May 29, 2025) put a die-cast aluminum EV battery housing in 8507.90.8000.
A Classification Researcher conversation with demo data. Ginger asks: Does it only hold and protect the battery modules, or is it also a load-bearing body or chassis member? From the answer it picks HTS 8507.90.8000 over 7616.99.5190.
What does this mean for a tier-1's trade team?
Every new program, plant or supplier change reopens a part's bucket, so each one becomes a recheck with a named next step.
GingerOSWhich Section 232 bucket does this aluminum battery housing fall in, and does the Mexico plant's USMCA eligibility hold?
Open rechecks3
8507.90.8000Saltillo plant, MXNew OEM program at the quote gateConfirm the bucket: battery part, not aluminum articleRuns in Classification ResearcherReview8507.90.8000Saltillo plant, MXCasting supplier changedCompare USMCA and non-USMCA landed costRuns in Parts LibraryNeeds answer7604.29.1090Ontario plant, CAProclamation 11065: Section 338 on Canadian extrusionsRecalculate tariffs for the listed linesRuns in Compliance RadarRunningA GingerOS window with demo data. Someone asks: "Which Section 232 bucket does this aluminum battery housing fall in, and does the Mexico plant's USMCA eligibility hold?" It lists 3 open rechecks, each with the part, HTS code, trigger, tool and status.
Questions about auto parts compliance
Which Section 232 bucket does an aluminum EV battery housing fall in?
If it is classified as a part of a storage battery (8507.90.8000), it falls in the auto-parts bucket: 25% under 9903.94.05, or no added duty under 9903.94.06 when the part qualifies for USMCA (CBP ruling N348886, May 29, 2025). Coded instead as an aluminum article (7616.99.51), it falls in the metals bucket at 50% of full value, with no USMCA relief (Proclamation 11021).
Does a USMCA claim on a Mexico-made auto part still remove the Section 232 auto duty?
Yes, for parts in the Section 232 auto-parts scope. A USMCA-originating part enters under 9903.94.06 with no added Section 232 duty, and the same duty-free USMCA entry is also exempt from the 10% forced-labor Section 301 duty on Mexican goods (HTS 2026 Revision 20, U.S. note 52(h)). The relief holds only if the origin claim does, so keep the rule-of-origin analysis and certification for each part.
Do steel and aluminum Section 232 duties stack on the 25% auto-parts duty?
No. Parts entered under 9903.94.05 or 9903.94.07 are not subject to the steel, aluminum or copper duties in headings 9903.82.02 through 9903.82.26 (U.S. note 33(f)). Base duty, China Section 301 and any antidumping or countervailing duty still apply on top. The forced-labor Section 301 duty does not, because U.S. note 52(f) exempts Section 232 auto parts.
Can a part that is not on the auto-parts list go under the 25% auto tariff instead of the metals tariff?
Yes, if three conditions hold: the part is not already covered by the auto or truck parts tariffs, it is not classifiable in Chapters 72, 73 or 76, and the importer of record certifies it will be used for U.S. automobile production or repair (Proclamation 10984, clause 12, effective November 1, 2025). It then enters under 9903.94.07 at 25% and falls outside the metals duties.
Is the Section 232 auto-parts duty recoverable through drawback now?
Partly. Since November 1, 2025, manufacturing drawback under 19 U.S.C. 1313(a) and (b) is available for Section 232 duties on automobile parts and on medium and heavy-duty vehicle parts, and no other type of drawback is (Proclamation 10984, clause 15). A claim depends on matching import, production and export records, so those records have to be kept from the day of entry.
What does a China-origin auto part pay now that Section 122 has expired?
A covered China-origin part pays its base duty plus 25% Section 232 plus its China Section 301 list rate, for example 25% for lines on List 1 or List 3 (HTS 2026 Revision 20). The 12.5% forced-labor Section 301 duty that took over from Section 122 on July 24, 2026 does not apply to Section 232 auto parts (91 FR 47318, U.S. note 52(f)).
What changed for Korean auto parts?
Korean auto parts in the Section 232 scope pay a combined 15% (Column 1 duty plus Section 232) instead of 25%, for entries from November 1, 2025 (90 FR 55964; headings 9903.94.62 and 9903.94.63). U.S. note 33(r) sets similar certified-parts headings for EU, Japanese and Taiwanese parts, but they cannot be used for articles in Chapters 72, 73 or 76.
Do aluminum extrusions from our Canadian plant carry the new Section 338 duty?
Yes. Since September 15, 2026, Canadian aluminum profiles, bars and rods (7604), aluminum tubes (7608) and certain steel structures (7308.90) carry the 50% Section 338 duty in addition to Section 232 (Proclamation 11065). The Section 338 duty has no USMCA exemption, so a qualifying Canadian extrusion can carry 100% in added duty.
How is a vehicle classified as 8703 versus 8704?
It turns on whether the vehicle is principally designed for the transport of persons (8703, 2.5%) or goods (8704, 25%), judged on design and use at the time of importation, not on marketing. The Marubeni (Nissan Pathfinder) and Ford (Transit Connect) cases both applied this design-intent test. Source: 35 F.3d 530; Fed. Cir. No. 18-1018.
