Foley Automotive Update

Key Developments

• Foley & Lardner partners Vanessa Miller and Alejandro Gómez-Strozzi shared highlights from their participation in a pivotal discussion in Mexico City last month at the 23rd Annual International Automotive Industry Congress (Congreso Internacional de la Industria Automotriz, CIIAM), organized by the Mexican Autopart Industry Association (Industria Nacional de Autopartes, A.C., INA).
• Foley & Lardner provided an overview on supply chain cyber threats, and best practices for mitigating cyber risks.
• The Michigan Supreme Court intends to rule in the months ahead on a dispute over the "legitimacy of Stellantis' supplier contracts," according to an update from Crain's Detroit.
• U.S. new light-vehicle sales in October 2025 fell by over 4% year-over-year to a SAAR of 15.4 million units, according to preliminary analysis from Haver Analytics.
• Foley & Lardner partner Gregory Husisian shared insight on how a possible tariff refund process could play out in the SupplyChainDive article, "What shippers need to know about potential tariff refunds." The U.S. Supreme Court will hear oral arguments on November 5, 2025, regarding the legality of the Trump administration's tariffs as imposed under the International Emergency Economic Powers Act (IEEPA).
• China's Commerce Ministry suggested it will offer exemptions to the recently imposed export restrictions on semiconductors made by Chinese-owned, Netherlands-based Nexperia, which supplies an estimated 40% of certain chips critical to automakers. The company has various issues to resolve with the Dutch government, and uncertainty remains over when the shipments will resume.
• A new trade and economic deal between the U.S. and China includes a reprieve on certain rare-earth export controls recently imposed by China. Despite the two nations' recently announced trade agreement, U.S. Trade Representative Jamieson Greerplans to continue an investigation into China's compliance with a limited trade agreement reached during President Trump's first term. The results of this Section 301 probe could result in new tariffs, or leverage in subsequent trade negotiations.
• S&P Global Mobility assessed the impact of the Section 232 tariffs on truck and bus imports imposed by the Trump administration on November 1. The analysis notes the October 17 executive order announcing the levies also expanded the list of tariffed auto parts, with "more varieties of drive axles, wider application of engine components, and adds items including touch screen displays, certain engine control units and speakers."
• President Trump extended a November 1, 2025 deadline to reach a trade deal with Mexico for an unspecified number of weeks, resulting in a delay of higher tariffs on Mexican goods that do not meet the content rules of the U.S.-Mexico-Canada trade agreement.
• President Trump intends to impose an additional 10% tariff on Canadian imports, and said he does not plan to resume trade negotiations with Canada due to an anti-tariff advertisement aired by the Ontario government. The Trump administration did not provide details on the implementation of the new tariffs or if USMCA-compliant goods would be exempt.
• The U.S. and South Korea are reported to have finalized a trade deal that is expected to establish a 15% cap on U.S. tariffs on Korean goods. This follows a framework agreement the nations announced in July.
• Last month the U.S. Senate narrowly passed three measures opposing President Trump's global "reciprocal" tariffs, as well as the emergency authorities underpinning the tariffs on Canada and Brazil. The U.S. House is not expected to vote on the measures in the near future, and Congress would require a two-thirds majority to overcome a presidential veto.

OEMs/Suppliers

• Revised projections for tariff-related costs in 2025 are between $3.5 billion to $4.5 billion for GM, up to $1.2 billion for Stellantis, and up to $1 billion for Ford.
• Canada intends to reduce the number of vehicles GM and Stellantis can import tariff-free into the country in response to the automakers' plans to reduce vehicle production in the nation.
• A number of major automakers submitted filings to urge the U.S. Trade Representative's Office to extend the USMCA, as it accounts "for tens of billions of dollars in annual savings." The USMCA is scheduled for formal review in 2026.
• Ford estimated the recent fire at a significant aluminum supplier will impact profitability by $1.5 billion to $2 billion in 2025, while noting mitigation efforts are expected to offset half of the cost.
• American Axle plans to invest $133 million to increase production and upgrade its plant in Three Rivers, Michigan.
• Nissan reduced its U.S. output by approximately 7,400 vehicles in October due to parts shortages.
• Geely will acquire a 26.4% stake in Renault do Brasil, and the Chinese automaker expects the partnership will accelerate its plans to expand sales in the market.
• Multiple European automakers have replaced CEOs this year, as ongoing economic and market challenges impact European vehicle sales.

Market Trends and Regulatory

• According to the NADA Data 2025: Midyear Report released in October, there were 16,972 new-car dealerships in the U.S. as of June 2025, and the top five states with the most dealerships were California, Texas, Florida, Pennsylvania, and Ohio. In addition, 90.7% of all new light-vehicle dealers owned one to five stores, down from 95% in 2014.
• WardsAuto provided a list of the top automotive conferences to consider in 2026.
• Vulcan Elements and ReElement Technologies secured $1.4 billion in combined funding from the U.S. government and private investors to establish a domestic rare-earth magnet supply chain.

Autonomous Technologies and Vehicle Software

• Waymo began testing its autonomous vehicles in Detroit. The company currently offers robotaxi service in parts of San Francisco, Los Angeles, Phoenix, Atlanta, and Austin, and it plans to expand services to cities including San Diego and Las Vegas next year.
• Uber announced plans to launch autonomous taxi service in the San Francisco Bay Area in 2026 with vehicles developed in partnership with EV maker Lucid and self-driving technology company Nuro Inc. Uber has also established a goal to have a fleet of 100,000 autonomous vehicles in its fleet that are powered by Nvidia technology beginning in 2027.
• Bloomberg provided an overview of Chinese companies' robotaxi deployment plans within multiple regions.

Hybrid and Electric Vehicles

• J.D. Power predicted U.S. EV sales in October 2025 will decline 3.4 percentage points to a market share of 5.2%, as the market recalibrates following the expiration of federal tax credits.
• On November 4, Automotive News updated its list of U.S. EV models that have been delayed or canceled.
• GM plans to lay off over 3,000 hourly workers across its EV and EV battery plants in Michigan, Ohio, and Tennessee in the coming months. Over half of the layoffs are expected to be indefinite. The automaker also laid off over 200 salaried workers at its Warren Tech Center in Michigan as part of a restructuring of its design-engineering team, and over 300 employees as part of the closure of its Georgia IT center.
• BYD reported its third-quarter 2025 net profit declined 33% year-over-year, and revenue fell 3% YOY.
• LG Energy Solution – Stellantis joint venture NextStar Energy will shift to producing batteries for energy storage systems at its Windsor, Ontario factory instead of EV batteries.
• Volkswagen subsidiary PowerCo started construction on a $7 billion EV battery plant in St. Thomas, Ontario.

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