In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.
TC Trade Alerts will serve as a central resource for identifying the policy changes, executive orders, and necessary information and context regarding government actions affecting international trade.
See below for more information on the last TC Trade Alerts. If you have any questions about how this affects your business, please don't hesitate to contact one of our attorneys.
Additional Resources
Trade Compliance Handbook | Checklists of Foreign Countries Subject to Sanctions | Our International Trade Practice
| THOMPSON COBURN TRADE ALERT – IMPORTS | |
| HEADLINE | Trump Imposes 25% Tariffs on Automobiles & Parts |
| DATE | 26 March 2025 |
| AGENCY | Trump Administration; Department of Commerce; United States Trade Representative; Customs and Border Protection |
| EFFECTIVE DATE | 12:01 am ET on 3 April 2025 for
Automobiles To be determined, prior to 3 May 2025 for Automobile parts |
| BACKGROUND | In 2019, Commerce conducted Section 232 investigations into imports of vehicles and Trump directed the USTR to pursue negotiations regarding vehicles and vehicle parts from Europe, Japan, and other countries as deemed appropriate. The negotiations did not result in agreements. |
| DETAILS | In light of the investigations in his first term, Trump has
announced 25% tariffs on: " Automobiles entered on or after April 3, 2025, and " Automobile parts, as listed in a yet-to-be-published Annex (at a date to be specified, no later than May 3, 2025) Although the order does not enumerate specific tariff provisions affected by the action, the preamble suggests the order will affect passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks (collectively, automobiles) and certain automobile parts (engines and engine parts, transmissions and powertrain parts, and electrical components) (collectively, automobile parts). Several additional points: " The 25% tariff will apply only to the non-U.S. content of automobiles that qualify for USMCA treatment. " If CBP determines that the declared value of U.S. and non-U.S. content of an automobile is inaccurate due to an overstatement of U.S. content, the 25% tariff will apply to the entire vehicle and will apply retroactively and prospectively to the full value of all automobiles of the same model. " The action on automobile parts applies only to individual automobile parts as defined by Annex I (not yet published), but does not apply to "automobile knock-down kits or parts compilations." " Automobile parts remain eligible for USMCA treatment temporarily, until such time that the Secretary of Commerce & CBP establish a process to apply the 25% to non-U.S. content, similar to whole automobiles. " No duty drawback is available for the 25% imposed on automobiles and specified parts. " The tariff is in addition to any other duties, fees, and charges applicable to such imported automobiles and automobile parts. |
| BASIS | Section 301 of title 3, United States Code; section 604 of the Trade Act of 1974, as amended; and section 232 of the Trade Expansion Act of 1962, as amended. |
| HTS/PRODUCTS | Automobiles and auto parts (to be defined later) |
| COUNTRY | All |
| CITE | Adjusting Imports of Automobiles and Autombile Parts Into the United States – The White House |
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.
