USMCA MHDVs: Process to Apply 232 Tariff Only on Non-U.S. Content
Commerce published procedures allowing importers of USMCA-qualifying medium/heavy-duty vehicles to document U.S. content so the 25% Section 232 tariff applies only to non-U.S. content value.
What this affects
United States
Canada
Mexico| Chapter 87 | Vehicles other than railway rolling stock, including MHDVs |
Codes are a starting point, not a classification. Confirm your own 10-digit HTS before you rely on a rate, using our HTS classification guide.
The update
Commerce published submission procedures for importers of USMCA-qualifying medium and heavy-duty vehicles (MHDVs) to document U.S. content so the 25% Section 232 tariff can apply exclusively to the non-U.S. content value.
Impact
This can materially reduce duty exposure for compliant USMCA MHDVs by shrinking the dutiable base, but it is documentation-heavy and requires consistent valuation and certification.
What to watch
The process is documentation-heavy. An approval reduces the dutiable base rather than the rate, so the benefit varies by model and sourcing mix.
How to prepare
- 1Document U.S. content by value
The benefit is proportional to what you can prove, not to what the vehicle contains.
- 2Line up officer-level certification
Submissions require CFO or general-counsel level certification, so build the review time in.
- 3Keep valuation consistent across entries
Inconsistent content values between filings undermine every submission in the set.
- 4Assess retroactive treatment
Retroactivity to November 1, 2025 is possible but discretionary.