ARTICLE
22 October 2025

56. October 17, 2025 | Trump Administration Publishes Proclamation Setting 25% Tariffs On Medium And Heavy Trucks And Their Parts, 10% Tariffs On Busses

TC
Thompson Coburn LLP

Contributor

For almost 100 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. With more than 400 lawyers and 50 practice areas, we serve clients throughout the United States and beyond.
Trump Administration publishes Proclamation setting 25% tariffs on medium and heavy trucks and their parts, 10% tariffs on busses...
United States International Law
Thompson Coburn LLP are most popular:
  • within Energy and Natural Resources and Intellectual Property topic(s)
  • with readers working within the Utilities industries
TRUMP ADMINISTRATION TRADE ALERT – IMPORTS 
HEADLINE  Trump Administration publishes Proclamation setting 25% tariffs on medium and heavy trucks and their parts, 10% tariffs on busses
DATE  October 17, 2025
AGENCY  Trump Administration, Department of Commerce
EFFECTIVE DATE  Goods entered or withdrawn from warehouse for consumption on or after November 1, 2025
BACKGROUND Earlier in 2025 the Trump Administration implemented p 232 tariffs on passenger vehicles, light trucks, and their parts and announced a p 232 investigation on medium and heavy duty trucks, and busses
DETAILS 

Applicable duties. The Trump Administration announced implementation of additional p 232 tariffs for imports of:

  • Medium- And Heavy-Duty Vehicles (MHDVs) (Class 3 – Class 8 trucks) – 25% duty rate;
  • Medium- And Heavy-Duty Vehicle Parts (MHDVPs) – 25% duty rate, and
  • Buses (e.g., school buses, transit buses, and motor coaches) – 10% duty rate. The tariffs apply to goods entered or withdrawn from warehouse after 12:01 am EDT November 1, 2025. The Proclamation lists the HTS classifications covered by these tariffs in Annex I (see below).

Implementation and exceptions. The Proclamation specified special rates and exceptions depending on the product category.

  • MHDVs that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA) will be subject to the tariffs on the value of the non-U.S. content, pending presentation of supporting documentation.
  • Imports of MHDV knock-down kits or equivalent parts compilations are subject to the additional duties regardless of USMCA preferential treatment qualification.
  • Imports of MHDVPs within the scope of the tariffs that qualify for USMCA preferential treatment are not subject to the additional duty rates until the Department of Commerce and CBP "establishes a process to apply the tariff exclusively to the value of the non-United States content of such MHDVPs and publishes a notice in the Federal Register."
  • MHDV manufacturers in the United States will be able to apply for a tariff offset based on 3.75% of the aggregate value of all MHDVs assembled in the United States by that manufacturer, as determined annually by the Secretary, from November 1, 2025, through October 31, 2030. This offset is only available for MHDVs that undergo final assembly in the United States, and only if claimed by importers of record authorized by that manufacturer.
  • The tariffs in this action do not apply to MHDVs or buses and other vehicles classified in HTSUS heading 8702 that were manufactured in a year at least 25 years prior to the date of entry of those MHDVs or buses.
  • The Proclamation directs the Secretary of commerce to establish additional implementation processes for MHDV engine manufacturers, identification of additional products subject to the tariff action, and accounting for U.S. content in USMCA part importation.

Unstacking for products subject to other tariffs.  Affected products will not be subject to additional or existing sectoral tariffs on steel, aluminum, copper, automobiles and automobile parts, and lumber, nor will they be subject to reciprocal tariffs or the tariffs imposed on Canada, Mexico, Brazil, or India, per the WH Fact Sheet.

Reduced p 232 steel and aluminum duty rate for newly committed, USMCA-compliant MHDV production. The proclamation provides the Department of Commerce may reduce tariffs owed under Proclamation 9704 (aluminum 232 tariff) and Proclamation 9705 (steel 232 tariff) by up to half the applicable rate (currently, 50%) for producers that operate production facilities in Canada or Mexico and supply United States automobile or MHDV manufacturers. Rate adjustments are limited to " quantities of aluminum or steel equal to newly committed United States production capacity; and " imports of aluminum and steel that qualify for preferential tariff treatment under the USMCA and that were smelted and cast or melted and poured in Canada or Mexico.

Drawback and Foreign Trade Zones. Manufacturing drawback claims may be made in accordance with subps (a) and (b) of p 313 of the Tariff Act of 1930, as amended, 19 U.S.C. 1313(a)–(b), but no other drawback shall be available with respect to the duties imposed on MHDVPs. Products admitted into a United States foreign trade zone on or after the effective date must be admitted in "privileged foreign status" unless they are eligible for admission under "domestic status" as defined in 19 C.F.R. 146.43.

BASIS  p 232 of the Trade Expansion Act of 1962; IEEPA
HTS/ PRODUCTS  Medium- and heavy-duty (Classes 3-8) trucks and their parts, and busses, as listed in Annex I of the Proclamation.
COUNTRY  All; USMCA favorable treatment for imports of MHDVPs and the U.S. content of MHDVs; Japanese and EU truck parts or heavy-duty engine parts will be subject to a 15% all-inclusive duty, per White House comments, but does not appear to have been implemented yet.
CITE  Proclamation:  https://www.whitehouse.gov/presidential-actions/2025/10/adjusting-imports-of-medium-and-heavy-duty-vehicles-medium-and-heavy-duty-vehicle-parts-and-buses-into-the-united-states/ Annex I (HTS classification list):  https://www.whitehouse.gov/wp-content/uploads/2025/10/2025MediumandHeavyDutyVehicles.Parts_.Buses_.p232.prc_.rel-ANNEX.pdf WH Fact Sheet:  https://www.whitehouse.gov/fact-sheets/2025/10/fact-sheet-president-donald-j-trump-addresses-the-threat-to-national-security-from-imports-of-medium-and-heavy-duty-vehicles-parts-and-buses/

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More