U.S. Issues
Guidance on Duty Offset for Auto and Heavy Vehicle Parts Imports
·
U.S. Customs
issued updated guidance on claiming Section
232 import duty offsets for automobile and medium/heavy-duty vehicle
(MHDV) parts.
·
Offset
applies only to importers approved
by the U.S. Department of Commerce (DOC).
·
Eligible
importers must declare the relevant Chapter
99 HTSUS codes, report zero
Section 232 duty, and pay only the applicable Column 1 customs duty.
·
Offset
claims require a valid DOC-issued
8-character offset license number in the entry summary.
·
Importers
must monitor offset usage to avoid exceeding approved limits, or face duty recovery and possible penalties.
·
Special
calculation rules apply to imports from Japan,
the UK, the EU, South Korea, and Taiwan, where only the Section
232 portion of the tariff can be offset.
·
Importers
can also file Post Summary
Corrections (PSC) to claim credits for previously paid eligible
Section 232 duties.
·
CBP has
updated the ACE system and
CATAIR guidance to support the new offset license requirements.
[ABS News Service/30.06.2026]
The purpose
of this message is to provide guidance on the import adjustment offset applicable
to Section 232 duties on automobile and medium and heavy-duty vehicle parts.
This message
updates CSMS #6684128 relating
to the import adjustment offset for Section 232 duties on automobile parts and provides
new guidance on the offset for Section 232 duties on medium and heavy-duty vehicle
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 established an import
adjustment offset program applicable to Section 232 duties on imported medium
and heavy-duty vehicle (MHDV) parts. 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). On May 15, 2026, the U.S. Department
of Commerce published procedures to administer the offset on automobile and MHDV
parts. See Amending the Procedures
to Administer Import Adjustment Offset Amounts for Certain Imports of Automobile
Parts Under Proclamation 10908 To Include Medium- and Heavy-Duty Vehicle Parts,
91 FR 27914 (May 15,
2026).
The functionality
for the Section 232 import adjustment offset for both automobile and MHDV parts
is available in the Automated Commercial Environment (ACE).
ENTRY FILING
INSTRUCTIONS
Importers
that have been granted a Department of Commerce (DOC) import adjustment offset established
by Presidential Proclamations 10925 and 10984 should follow the instructions listed
below when filing entries with U.S. Customs and Border Protection (CBP) of automobile
parts and medium and heavy-duty vehicle parts subject to Section 232 duties under
Proclamation 10908 and 10984, as amended.
The import
adjustment offset may only be claimed by importers 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 be used
to offset automobile or medium and heavy-duty vehicle parts tariff liability under
Proclamations 10908 and 10984, as amended.
Importers
should track the usage of each import adjustment offset license so they do not exceed
the total offset amount of each license.
The TR-015 report is available in ACE to assist importers to track their
usage of offset licenses. Importers who exceed
the amount of offset licenses are liable for the Section
232 duty amounts on the overages and may be subject to penalty action under 19 USC
1592.
When claiming
the import adjustment offset:
·
continue to
file automobile parts HTSUS 9903.94.05 or 9903.94.07 or MHDV parts 9903.74.08 or
9903.74.09;
·
file zero
(0) for the duty amount on HTSUS 9903.94.05, 9903.94.07, 9903.74.08 or 9903.74.09
on the Chapter 99 HTSUS; and
·
file the column
one duty amount on the Chapter 1 to 97 HTSUS when the license number is submitted
on the entry summary line.
For automobile
parts from Japan, the United Kingdom, 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), South Korea, and Taiwan, the additional tariff rate for automobile parts
is calculated based on the difference between the column one duty rate and the 232
duty rate. 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 imports
of automobile parts from Japan, the United Kingdom, member countries of the European
Union, South Korea, and Taiwan, when claiming the import adjustment offset:
·
continue to
file automobile parts HTSUS 9903.94.43, 9903.94.55, 9903.94.32, 9903.94.33, 9903.94.53,
9903.94.45, 9903.94.63, 9903.94.65, 9903.94.67 or 9903.94.69;
·
file zero
(0) for the duty amount on Chapter 99 HTSUS;
·
file the column
one duty amount on the Chapter 1 to 97 HTSUS when the license number is submitted
on the entry summary line.
When claiming
an import adjustment offset, if submitting HTSUS 9802.00.40, 9802.00.50, 9802.00.60,
9802.00.80 on the same entry summary line with the automobile or MDHV parts Chapter
99 classification, file zero (0) for the duty amount on these Chapter 98 classifications.
Importers
claiming the import adjustment offset should list the offset license number provided
by DOC on the entry summary lines for automobile parts or medium and heavy-duty
vehicle parts subject to Section 232 duties.
The automobile or MHDV parts offset license number should be submitted in
the Importer Additional Declaration Field (54 record), Type Code 11 (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
automobile/MHDV parts offset license number.
For the avoidance
of doubt, the imported automobile or MHDV part is still considered to be “subject
to” the Section 232 duties under Proclamation 10908 and 10984, as amended, when
the import adjustment offset amount is used to reduce the otherwise applicable Section
232 duties under Proclamation 10908 and 10984, as amended, on the imported automobile
or MHDV part.
Importers
filing automobile or MHDV parts Chapter 99 HTSUS with the offset license number
are not subject to Section 232 metals or wood duties. No Chapter 99 HTSUS is needed for the exemption
from the other remedies noted above.
POST SUMMARY
CORRECTION
Importers
claiming an offset license on the automobile or the MHDV part may submit a post
summary correction to amend previous entry summaries where section 232 duties were
paid to be credited against the offset license credit amount.
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.