Foley Automotive Update

Key Legal Insights from Foley’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

Foley is here to help you through all aspects of rethinking your long-term business strategies, investments, partnerships, and technology. Contact the authors, your Foley relationship partner, or our Automotive Team to discuss and learn more. 

Automotive Key developments

• Stellantis is working with its suppliers to assess the cost of moving certain pickup truck model production to Michigan from Mexico, according to a report in Crain’s Detroit.

• The Alliance for Automotive Innovation has urged Congress to enact a permanent ban on the “sale, import and manufacture of Chinese connected vehicles, hardware and software” by the end of the year.

• President Trump again signaledopenness to Chinese automakers building vehicles in the U.S. if they hire American workers, while reaffirming his intent to block vehicle imports from China.

• Average U.S. diesel prices are at a record high of $6.31 a gallonthis week, representing a 70% increase from the same period last year. National average gasoline prices are approximately 36% higher than one year ago. U.S. consumers have paid over $100 billion more for gasoline and diesel during the Iran war than they would have absent the conflict, according to the Climate Solutions Lab at Brown University.

• Goldman Sachs recently predictedoil prices could surpass $120 a barrel if shipping instability persists in the Middle East. This comes as American oil executives warn of heightened price and supply risks, citing depleted commercial fuel inventories and historically low strategic crude reserves.

TRADE/TARIFFS

• Foley & Lardner provided five best practices to help manufacturers prepare for tariff volatility.
• Foley & Lardner attorneys Gregory Husisian, Kate Wegrzyn, and Lindsey Zirkle were featured in International Trade Today for their insights at Foley’s 2026 International Trade & Supply Chain Webinar Blitz. Topics included tariff refund disputes and customs enforcement changes.
• Foley & Lardner provided an overview for multinationals pertaining to securing IEEPA tariff refunds for “finally liquidated” entries, defined as “entries that are more than 80 days beyond liquidation and therefore fall outside Consolidated Administration and Processing of Entries (CAPE) Phase 1.”
• Foley & Lardnerassessed the implications of a recent Department of Justice memo outlining the National Fraud Enforcement Division’s key priorities for fraud investigations and prosecutions.
• In response to Canadian counter-tariffs on certain U.S. goods imposed on September 8, President Trump willban imports of certain Canadian goods including motorcycles later this month. President Trump also modified the scope of some of the existing 50% tariffs imposed on Canada under Section 338 of the Tariff Act of 1930, and added certain Canadian aluminum and other metal products to the list of items subject to the 50% duties.
• Certain auto industry analysts warned that escalating U.S.-Canada trade tensions could derail the regional alignment needed to curb Chinese automakers’ expansion in North America.
• The United States and Mexico hope to reach a bilateral trade agreement before the U.S. midterm elections in November, according to multiple unnamed sources in Reuters.
• Secretary of Commerce Howard Lutnickindicated the U.S. is taking steps to issue a broad tariff on semiconductors, while suggesting that companies that commit to U.S. manufacturing could be exempt. Lutnick did not provide the timing for the new tariffs.
• The Office of the U.S. Trade Representative (USTR) received a letter from the United Steelworkers union requesting an investigation into imported tires under Section 201 of the Trade Act. The USW’s letter notes that as U.S. tire production declines, countries including China have been rapidly expanding their capacity and targeting the U.S. market.

OEMs/SUPPLIERS

• Ford CEO Jim Farley rejected Transportation Secretary Sean Duffy’s claims that the automaker is becoming overly reliant on Chinese companies, including through its CATL technology licensing agreement at a Ford-owned battery plant in Marshall, Michigan. Ford also recently announced a joint venture with Geely in Spain and is reportedly expanding its longstanding partnership with Jiangling Motors in China to boost exports and international sales.
• Chinese automakers’ sales outside of Chinaaccounted for 38% of total retail sales in August 2026, up from 20% one year ago. New vehicle sales within China are down by more than 20% for 2026 year-to-date.
• Hyundairaised its local sourcing goal in North America, and now plans to source 80% of parts for vehicle manufacturing in the region from local suppliers by 2030.
• Fordplans to invest $1 billion to establish a new paint shop at its Kentucky Truck Plant and modernize the facility. Construction is expected to begin later this year.
• South Korea’s Hansae Mobility USA, a manufacturer of driveline systems and other vehicle components, will invest more than $93 million to expand its Michigan operations with a new 400,000-square-foot facility in Chesterfield Township.
• Volkswagen estimated its restructuring initiatives, including job cuts and potential plant closures, will cost up to €16 billion ($18.6 billion), according to a report in Reuters. The automaker plans to eliminate up to 100,000 jobs globally by 2030.
• Stellantissigned a memorandum of understanding that could lead to the sale of the Brampton Assembly Plant in Canada to armored vehicle manufacturer Roshel.

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

• Automotive News shared success stories from smaller suppliers that have utilized AI technologies to improve manufacturing quality and efficiency.
• Hardware or operational constraints could impact suppliers’ and automakers’ plans to increase deployment of AI-enabled functions in vehicles.
• Hyundai is delaying its proprietary driver-assistance software launch by two years, to 2029, and will rely on Nvidia in the interim to speed deployment.
• Ann Arbor, Michigan-based May Mobility plans to go public through a merger with a special purpose acquisition company in a deal valuing the autonomous ride-hailing company at approximately $1.4 billion.
• Santa Clara, California-based PlusAIplans to go public in a SPAC deal valuing the ‌autonomous trucking software developer at approximately $800 million.
• Ford is utilizingAI-enabled sound detection to identify defects before vehicles are shipped to dealers.

MARKET TRENDS AND REGULATORY

• The National Highway Traffic Safety Administration (NHTSA) has proposed delays for testing certain vehicle safety features that support the New Car Assessment Program.
• The Federal Trade Commissionreleased guidance for dealerships to comply with price advertising rules after previously warning dealers about deceptive pricing practices.
• Infotainment accounts for 25% of total vehicle complaints and it was the only category to decline year-over-year, according to the JD Power 2026 U.S. Multimedia Quality and Satisfaction Study.
• In August, the average price ofglobal air freight shipments was $3.13 per kilogram, up 24% from the same period last year.
• The Consultative Shipping Group, an informal alliance of the 18 biggest shipping countries, warned that global conflicts, trade restrictions, and chokepoints were raising costs and spreading uncertainty acrossglobal supply chains, according to a report by The Wall Street Journal. The group, which doesn’t normally issue statements, indicated that changes eroding freedom of navigation were leading to the emergence of “two parallel trade systems,” with one following the rules and another “operating by evading sanctions, attacking vessels and forcing ships to reroute from key waterways.”
• The Journal of Commerce reports Mexico–U.S. trucking rates are rising as tighter U.S. scrutiny of foreign drivers collides with a shrinking pool of Mexican drivers holding B1 visas.

HYBRID AND ELECTRIC VEHICLES

• China’s new Five-Year Plan establishes a goal for 70% of new vehicle sales to beelectric or hybrid by 2030, and for electric models to account for 40% of new commercial vehicle sales over the same period. Over half of the new car sales in China last year were new energy vehicles.
• Ford, Hyundai, and Stellantisplan to debut extended-range EVs (EREVs) in the U.S. beginning in late 2026, which are plug-in vehicles featuring a gas-powered generator to charge the battery.
• Tesla, LG Energy, Ford, and GM are among the companies that are utilizing EV battery production capabilities to pursue revenue growth from energy storage systems that support AI data centers.
• Hondainvested an undisclosed amount in Minnesota-based Niron Magnetics, a developer of rare earth-free magnets for a variety of applications including electrified vehicle powertrains. The majority of electric propulsion motors require permanent magnets made from rare earth metals, which face the risk of supply constraints.
• Google is partnering with electric truck startup Nevoya and the Center for Green Market Activation to deploy 25 electric semi trucks along a key freight corridor in Texas.
• Automotive News provided an update on EV delays or cancelations announced in 2026.
• Electric trucking startup Windrose Technologyreportedly lost most of its Chinese staff amid funding shortfalls