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Update on Automobile Tariffs

MSK Client Alert
April 3, 2025

The Executive Order for the auto and auto parts tariffs was published today (April 3, 2025) in the Federal Register and includes Annex 1. The FR notice makes clear that vehicles classified under the following provisions are impacted (generically these are passenger vehicles and light trucks): 8703.22.01, 8703.23.01, 8703.24.01, 8703.31.01, 8703.32.01, 8703.33.01, 8703.40.00, 8703.50.00, 8703.60.00, 8703.70.00, 8703.80.00, 8703.90.01, 8704.21.01, 8704.31.01, 8704.41.00, 8704.51.00 and 8704.60.00, HTSUS.

9801 and 9802 benefits are granted, except when it comes to 9802.00.60 (metal articles manufactured or processed in the U.S. and exported for further processing). Goods classified under this tariff provision are subject to duty on the full value of the imported good(s).

These tariffs will be on vehicles which arrive on or after 12:01 a.m. EDT April 3, 2025. See 9903.94.01 - 9903.94.04, HTSUS. The tariff on auto parts is said to take effect on or after 12:01 a.m. EDT on May 3, 2025. See 9903.94.05 and 9903.94.06, HTSUS. For these purposes, auto parts, "include engines and engine parts, transmissions and powertrain parts, and electrical components, and parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks classified under the HTS provisions enumerated in subdivision (g)" see note 33 to subchapter III of chapter 99. A list of relevant tariff numbers is included.

Link to Federal Register Notice

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