Trade and Tariffs Update: April 28, 2025

Recent tariff measures now require supply chains to maintain a higher level of data granularity, including detailed information on inputs and production. Importers must be prepared to document and support value content declarations with a level of specificity that may not have been previously required.

We encourage members to consult with their customs broker or trade counsel for further guidance and to ensure compliance with all applicable tariff programs.

Auto Care Association Launches Tariff Calculator

The Auto Care Association has launched a new tariff calculator, now available exclusively for Auto Care members. This tool is designed to help you identify which recent U.S. tariffs may apply cumulatively to your products, including:

• Section 301 Tariffs on China
• International Emergency Economic Powers Act (IEEPA) Tariffs
• Reciprocal Tariffs
• Section 232 Tariffs on Auto Parts
• Section 232 Tariffs on Steel and Aluminum

The calculator will guide you through a step-by-step process to determine potential tariff exposure based on stacking rules, exemptions and product-specific considerations.

Access the Tariff Calculator

New Section 232 Investigation: Medium- and Heavy-Duty Trucks and Parts

On April 24, 2025, the U.S. Department of Commerce initiated a new national security investigation under Section 232 of the Trade Expansion Act of 1962 into imports of medium-duty trucks, heavy-duty trucks, and related parts and derivative products.

Scope of Investigation:

• Medium-duty trucks: trucks with a gross vehicle weight of more than 10,000 and under 26,001 pounds.
• Heavy-duty trucks: trucks with a gross vehicle weight rating of 26,001 pounds or more.
• Medium- and heavy-duty truck parts: components and systems, including engines and engine parts, transmissions and powertrain parts, and electrical components.

Request for Public Comments:

The Commerce Department is seeking written comments from interested parties on issues including:

• Domestic demand for trucks and parts
• Reliance on foreign supply chains
• Risks from import concentration
• Effects of foreign subsidies and unfair trade practices
• Expansion of U.S. production capacity
• Whether additional measures are necessary to protect national security

A full list of issues under review can be found in the Federal Register notice linked below.

We encourage members who are impacted by potential tariffs or other trade actions on medium- and heavy-duty vehicles and parts to provide feedback to the Auto Care Association for inclusion in our industry comments. We also encourage members to submit their own comments so that individual business impacts are fully represented in the public record.

The deadline for written comments is June 10, 2025.

Submit a Comment

Reminder: Section 232 Tariffs on Auto Parts Go Into Effect May 3

As a reminder, the 25% Section 232 tariff on auto parts is scheduled to go into effect on May 3, 2025. The tariff applies to parts for passenger vehicles and light trucks, as listed in Annex I (pages 11-12) of the Federal Register notice.

• Parts qualifying under USMCA rules are currently exempt, pending a future notice establishing how tariffs will be applied to only the non-U.S. content.
• Importers should review their affected products and ensure compliance.

Products for heavy-duty vehicle applications are not included in the Section 232 tariffs on auto parts.

Auto Parts List (pages 11-12)

More Lawsuits Over IEEPA Tariffs

In last week's trade update, we shared that four lawsuits had been filed challenging the Trump administration's use of IEEPA to impose tariffs.

In a new development, twelve states have joined a new lawsuit filed at the U.S. Court of International Trade, arguing that the president acted arbitrarily and exceeded his legal authority.

The twelve states participating in this lawsuit are:

• Oregon
• Arizona
• Colorado
• Connecticut
• Delaware
• Illinois
• Maine
• Minnesota
• Nevada
• New Mexico
• New York
• Vermont

BBC - A dozen US states sue to halt Trump's tariffs

USTR Trade Negotiations

The United States is accelerating bilateral negotiations with major trading partners following the temporary 90-day pause on reciprocal tariffs. According to reports, the administration plans to engage approximately 18 major trading partners on a rolling basis over the next two months.

Negotiations are being organized into three-week cycles, with six nations participating each week. This rotation is expected to continue until the administration's July 8 deadline. If no agreements are reached by that time, reciprocal tariffs could be imposed unless the administration further extends the pause period.

Negotiations are expected to cover a broad range of issues, including:

• Tariffs and quotas
• Non-tariff barriers to trade (such as regulations on U.S. goods)
• Digital trade
• Rules of origin for products
• Economic security and other commercial concerns