Auto Parts Duty under Sec.232 to be Offset to
Normal Duty to Push Local Manufacturing in US
Import
Adjustment Offset for Section 232 Duties on Automobile Parts:
Purpose
To provide entry filing guidance for
importers claiming the Import Adjustment Offset applicable to Section
232 duties on automobile parts, following recent Presidential
proclamations.
Background
·
Proclamation 10908 (Mar 26, 2025):
Imposed a 25% tariff on certain automobile parts under Section 232,
effective May 3, 2025.
·
Proclamation 10925 (Apr 29, 2025):
Introduced an Import Adjustment Offset to partially offset these duties.
·
Commerce Dept. Procedures (Jun 13, 2025):
Detailed administration of the offset.
·
Proclamation 10984 (Oct 17, 2025):
Expanded coverage to additional vehicle parts; functionality in ACE
available Nov 3, 2025.
Key
Filing Instructions
1.
Eligibility
o
Only importers granted an offset license by
the Department of Commerce (DOC) may claim it.
o
The offset applies only to Section 232 duties
and only up to the approved amount.
2.
Countries Covered
o
Japan, UK, EU members:
§ Tariffs
combine column 1 duty rates + Section 232 duties.
§ Only the 232
portion may be offset.
§ Example:
UK auto parts (HTSUS 9903.94.32) → total tariff 10%; offset applies only
to the difference between 10% and column 1 rate.
o
All other countries:
§ File HTSUS
9903.94.05 or 9903.94.07, enter 0 duty for these lines.
3.
For Japan, UK, and EU
o
File applicable HTSUS 9903.94.43, .45, .32, .33,
.53, or .55 with 0 duty on Chapter 99 HTSUS,
and column 1 duty on the regular (Ch. 1–97) HTSUS line.
4.
Offset License Reporting
o
Report the offset license number in the Importer
Additional Declaration Field (54 record), Type Code 11.
o
Format: AANNNNNN (2 letters + 6 digits).
5.
Interaction with Other Tariffs
o
Entries using an auto parts offset license
are not subject to Section 232 aluminum,
steel, copper, wood, or IEEPA reciprocal/Brazil/Russian oil/India
tariffs.
o
File relevant exemption HTSUS codes for
reciprocal, Brazil, and Russian Oil/India measures.
6.
Post Summary Correction (PSC)
o
Importers can submit a PSC to claim the
offset retroactively and obtain refunds for previously paid
Section 232 duties.
7.
ACE System Updates
o
ACE Entry Summary Create/Update CATAIR (v108) and ACE
Error Dictionary CATAIR (v44) updated to support offset license
submissions.
Effective
Date: November 3, 2025 – functionality available in ACE for
claiming the offset.
Duty Offset for Imports of Automobile
Parts
The purpose of
this message is to provide guidance on the import adjustment offset applicable to
Section 232 duties on automobile parts.
BACKGROUND
On March 26, 2025,
the President issued Proclamation 10908, imposing a 25 percent ad valorem tariff
on certain imports of automobile parts under Section 232, effective May 3, 2025. See Adjusting Imports of Automobiles
and Automobile Parts Into the United States, 90 FR
14705 (April 3, 2025).
On April 29, 2025,
the President issued Proclamation 10925, providing for an import adjustment offset
amount applicable to Section 232 duties on imported automobile parts. See Amendments to Adjusting Imports of Automobiles
and Automobile Parts into the United States, 90 FR 18899 (May 2, 2025). On June 13, 2025, U.S. Department of Commerce’s
International Trade Administration published procedures to administer the offset.
See Procedures to Administer Import Adjustment
Offset Amounts for Certain Imports of Automobile Parts under Proclamation 10908,
as Amended, 90 FR 25027 (June 13, 2025).
On October 17,
2025, the President issued Proclamation 10984, which, among other provisions, amended
Proclamation 10908, and provides for importers to declare that other automobile
parts are subject to the automobile parts tariff. See Adjusting Imports of Medium- and Heavy-Duty
Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses into the United States,
90 FR 48451 (October 22, 2025). This
message includes guidance on the process by which an importer may claim an import
adjustment offset on these other automobile parts. For entry filing guidance on other elements of
the October 17, 2025 Proclamation, see Cargo Systems Messaging Service Message 66665333.The
functionality for the Section 232 import adjustment offset will be available in
the Automated Commercial Environment (ACE) on November 3, 2025.
ENTRY FILING INSTRUCTIONS
Importers of record
that have been granted a Department of Commerce (DOC) import adjustment offset established
by Presidential Proclamation 10925 should follow the instructions listed below when
filing entries with U.S. Customs and Border Protection (CBP) of automobile parts
subject to Section 232 duties under Proclamation 10908, as amended.
The import adjustment
offset may only be claimed by importers of record that have been granted an import
adjustment offset by DOC and only up to the amount granted by DOC. The import adjustment offset amount may only be
used to offset automobile parts tariff liability under Proclamation 10908, as amended.
For automobile
parts from Japan, the United Kingdom, and the member countries of the European Union
(Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia (Czech Republic), Denmark,
Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain,
Sweden), the additional tariff rate for auto parts is calculated based on the column
one duty rates and 232 duty rates. Only the
portion assessed under the 232 duties may be offset.
For example, automobile
parts of the United Kingdom imported under HTSUS 9903.94.32 are subject to a total
tariff of 10 percent (including any column one tariffs). Only the portion assessed under the Section 232
duties, the difference between 10 percent and the column one rate, may be offset.
For all countries
except for Japan, the United Kingdom, and the member countries of the European Union,
when claiming the import adjustment offset, continue to file auto parts HTSUS 9903.94.05
or 9903.94.07, and file zero (0) for the duty amount on HTSUS 9903.94.05 or 9903.94.07.
For imports of
auto parts from Japan, the United Kingdom, and member countries of the European
Union. when claiming the import adjustment offset, continue to file auto parts HTSUS
9903.94.43, 9903.94.45, 9903.94.32, 9903.94.33, 9903.94.53 or 9903.94.55, file zero
(0) for the duty amount on the Chapter 99 HTSUS AND file the column one duty amount
on the Chapter 1 to 97 HTSUS.
Importers claiming
the import adjustment offset should list the offset license number provided by DOC
on the entry summary lines for automobile parts subject to Section 232 duties. The automobile parts offset license number should
be submitted in the Importer Additional Declaration Field (54 record), Type Code
11 (Auto Parts Offset License) of the entry summary data, based on the following
format:
8-character format
= AANNNNNN
“A” represents
the alphabetic characters and “N” represents the numeric characters of the DOC granted
auto parts offset license number.
For the avoidance
of doubt, the imported automobile part is still considered to be “subject to” the
Section 232 duties under Proclamation 10908, as amended, when the import adjustment
offset amount is used to reduce the otherwise applicable Section 232 duties under
Proclamation 10908, as amended, on the imported automobile part.
Importers filing
auto parts Chapter 99 HTSUS with the offset license number are not subject to Section
232 aluminum, steel, copper or wood, International Emergency
Economic Powers Act (IEEPA) Reciprocal, Canada, Mexico, Brazil, or Russian Oil/India
tariffs. For the reciprocal, Brazil, and
Russian Oil/India tariffs, file the corresponding Chapter 99 exemption HTSUS for
Section 232 measures for each of these remedies. No Chapter 99 HTSUS is needed for the exemption
from the other remedies noted above.
Importers may submit
a post summary correction using these entry filing instructions to claim the import
adjustment offset and request a refund of any Section 232 automobile parts duties
paid on previous entry summaries.
CBP has updated
the ACE Entry Summary Create/Update CATAIR (v108) and the ACE Error Dictionary CATAIR
(v44) for implementing the new requirements to submit offset license numbers.