In an Executive Order (EO) issued yesterday, April 29, 2025, the President amended recent tariff actions on products of Canada or Mexico including automotive tariffs, Section 232 steel and aluminum tariffs, and tariffs under the International Emergency Economic Powers Act (IEEPA). The major amendment means these tariffs do not stack on each other.
Per the EO, all Canadian and Mexican goods subject to IEEPA tariffs are exempt from Section 232 Steel and Aluminum and Derivative tariffs. Additionally, if goods are subject to Section 232 Autos and Auto Parts, those goods are exempt from IEEPA and Section 232 Steel and Aluminum and Derivative tariffs.
Any required changes to the HTSUS needed to comply with the EO will be issued by May 16, 2025. The order applies retroactively to all entries, as outlined, made on or after March 4, 2025. Additional guidance from CBP is expected regarding the refund process.
| If goods are | Subject to: | Not Subject to: |
| Auto/ Auto parts | 2(a) Automobile and Automobile Parts tariffs | CA or MX IEEPA, Section 232 Steel and Aluminum and Derivatives or Reciprocal Tariffs |
| Non-Auto/Auto parts and CA/MX Non-USMCA | 2(b) Canada IEEPA tariffs 2(c) Mexico IEEPA tariffs | Section 232 Steel and Aluminum and Derivatives Tariffs |
| Non-Auto/Auto parts and if CA/MX USMCA | N/A | CA or MX IEEPA |
| Steel Products and Derivatives (Section 232) (Not Auto/ Auto Parts) | Aluminum Products and Derivatives (Section 232) if applicable | CA or MX IEEPA or Reciprocal Tariffs |
| Aluminum Products and Derivatives (Section 232) (Not Auto/ Auto Parts) | Steel Products and Derivatives (Section 232) if applicable | CA or MX IEEPA or Reciprocal Tariffs |
In another Presidential Proclamation on automobiles and automobile parts, Original Equipment Manufacturer (OEM) may be eligible to apply for an import adjustment offset amount equal to 3.75 percent of the aggregate Manufacturer’s Suggested Retail Price (MSRP) value of all automobiles assembled in the U.S. in the next year. The Commerce Secretary will establish a process within 30 days on how to apply for this credit. Manufacturers who are approved will be able to list their suppliers who may also be eligible for the credit.
Tariffs on automobiles have been in place since April 3, 2025. Tariffs on automobiles are set to go into effect on May 3, 2025, at 12:01 a.m. EDT.
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