On November 1, 2025, new import duties on medium- and heavy-duty vehicles (MHDVs), parts, and buses will take effect. These changes, introduced under Presidential Proclamation 10984, are designed to address national security concerns and strengthen the U.S. manufacturing sector. If you’re an importer, it’s important to understand how these changes might impact your business.
Why the new duties were introduced
The U.S. government has determined that imports of MHDVs, certain parts, and buses are entering the country in quantities that threaten national security. These vehicles and parts are critical for military readiness, emergency response, and the continuity of essential infrastructure. However, growing reliance on foreign suppliers has created vulnerabilities in the supply chain.
Key findings from the Department of Commerce’s investigation include:
- MHDVs move over 70% of the nation’s freight by weight, including essential goods like food, fuel, and medical supplies.
- Import penetration in the MHDV market has reached 43%, with 50% in the heaviest-duty truck category (Class 8).
- The U.S. is heavily dependent on foreign suppliers for key components like engines, batteries, and transmissions, creating risks for national security.
What’s changing
Starting November 1, 2025, the following duties will apply:
- 25% ad valorem duty on MHDVs and key parts.
- 10% ad valorem duty on buses and other vehicles classified under HTSUS heading 8702.
These duties apply to goods entered for consumption or withdrawn from warehouses starting 12:01 a.m. Eastern Time, November 1, 2025.
Scope
- Trucks: Large pick-up trucks, moving trucks, cargo trucks, dump trucks, and tractors for eighteen-wheelers, categorized by gross vehicle weight.
- Truck Parts: Engines, transmissions, tires, and chassis, among others.
- Buses: School buses, transit buses, and motor coaches, among others.
- Exception: Trucks and buses manufactured 25 years ago are exempt.
For more details, see Annex I in the Proclamation.
Filing requirements and HTS codes
Entries submitted to U.S. Customs and Border Protection (CBP) from all countries that are provided for in headings 9903.74.01 through 9903.74.11 are subject to tariffs on MHDVs and MHDVPs.
It’s important to note that these HTS codes can apply to other products beyond medium- and heavy-duty trucks, parts, and buses. If you’re importing goods that align with one of the impacted HTS codes, you must determine if your products fall under the scope of this trade remedy.
Exemptions and special provisions
Certain exemptions and adjustments apply, including:
- Trucks, buses and other vehicles under heading 8702 that were manufactured at least 25 years ago are exempt.
- USMCA applicability: Trucks that meet the USMCA rule of origin will only pay the 25% tariff on the non-U.S. content, provided they receive pre-approval from the Department of Commerce. USMCA-qualified truck parts (excluding knockdown kits) will not pay the 25% tariff until a process is established.
- Offset program: For trucks assembled in the U.S., manufacturers can apply to the Secretary of Commerce for an import adjustment offset equal to 3.75% of the aggregate value of all medium- heavy-duty vehicles assembled in the United States.
- Duty rates for EU, Japan, and UK: Adjusted duty rates continue to apply for imports from the European Union (15%), Japan (15%), and the United Kingdom (10%).
For these adjusted rates, importers must report the duty amount under the relevant HTSUS code and ensure proper certification that the parts will be used for automobile production or repair activity in the U.S. - Duty drawback: Only Direct Identification And Substitution Manufacturing drawback claims will be permitted. This includes parts of trucks, buses, and autos.
Stacking of tariffs
Goods subject to the new tariffs under this proclamation will not be subject to additional Section 232 tariffs on steel, aluminum, copper, automobiles, and automobile parts. This ensures that importers won’t face overlapping duties on the same products.
Self-declaring parts as auto parts
Manufacturers can self-declare an auto or truck part to be subject to the Section 232 tariffs on auto parts or on truck parts, as long as that part:
(1) is not currently subject to tariffs under either Section 232 autos or trucks;
(2) the part is not classifiable in Chapters 72, 73, or 76 of the HTS; and
(3) the part is for auto or truck production or repair activity in the U.S.
This may offer parts importers relief from the Section 232 steel and aluminum tariffs on derivative goods.
United States-Mexico-Canada Agreement (USMCA)
Trucks (but not buses) that meet the USMCA rule of origin only pay the 25% tariff on the non-U.S. content in the heavy truck. To qualify, pre-approval from the Department of Commerce is required. Importers must work directly with Commerce for qualification.
If CBP finds that declared U.S. content is inaccurate, the 25% tariff applies to the full value of the heavy truck, regardless of its actual U.S. content, and will continue to apply to that for all models of that type until CBP certifies compliance.
With the exception of knockdown kits, USMCA-qualified truck parts will not pay the 25% tariff until the Secretary of Commerce creates a process to apply the tariff exclusively to the value of the non-U.S. content. The Proclamation does not provide a timeline for when Commerce must establish this process.
The Proclamation contemplates limited Section 232 tariff relief for Canada and Mexico-origin steel and aluminum. If a U.S. car or truck manufacturer uses steel or aluminum from Canada or Mexico, Commerce can cut the tariffs owed on that steel and aluminum up to as much as in half (i.e., from 50% to 25%). This reduction only applies to newly committed U.S. production of cars or trucks. To receive this adjustment, the steel and aluminum must meet the USMCA rule of origin, the steel must be melted and poured in Canada or Mexico, and the aluminum must be smelted and cast in Canada or Mexico. Commerce has not indicated what its intentions are in terms of acting on this rate relief.
What this means for importers
If you’re importing medium- and heavy-duty trucks, parts, or buses, or any other goods that align with the impacted HTS codes, these changes will affect you.
Livingston recommends that importers of products included in the scope of medium- and heavy-duty trucks, their parts, and buses as well as products subject to the existing 232 Automobile and Automobile action carefully review their import activities and determine:
(1) where any overlap exists for the import of parts falling within both 232 remedies,
(2) communicate to your broker (a) which of your products are in scope but not manufactured for trucks and autos and (b) which of your products are in scope and whether they are manufactured for trucks or autos,
(3) USMCA eligibility for parts, and
(4) opportunities to self-declare your products as truck or auto parts. The scopes are HTS driven and may be found on the Federal Registers ‘Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses Into the United States’ and ‘Adjusting Imports of Automobiles and Automobile Parts Into the United States’.
Next steps
- Review the guidance: Detailed instructions are available in the CBP CSMS bulletin #66665333.
- Check the HTS codes: Confirm whether your imported goods align with the impacted HTS codes.
- Consult your broker: Work with your customs broker to ensure proper classification and filing of entries.
- Plan for cost adjustments: Evaluate how these tariffs will impact your operations and pricing.
For more information, you can also refer to the Presidential Proclamation and the White House fact sheet.
If you have any questions or need assistance, feel free to reach out to our team.