CBP Releases Updated Guidance on 232s for USMCA Medium and Heavy Vehicles

May 11, 2026
By: Austin J. Eighan

On May 6, U.S. Customs and Border Protection (CBP) issued updated guidance on applying the 25% Section 232 tariff covering medium- and heavy-duty vehicles (MHDVs) exclusively to the value of their non-U.S. content for eligible imports.

In his October 2025 Proclamation implementing the Section 232 tariff on MHDVs, President Trump authorized the Secretary of Commerce to construct a mechanism through which importers of MHDVs that qualify for preferential duty treatment under the United States-Mexico-Canada Agreement (USMCA) could apply for reduced tariff rates. In February 2026, the Department of Commerce published procedures allowing importers to request tariff reductions for MHDVs entered on or after November 1, 2025, based on non‑U.S. content calculated by subtracting U.S. content from the vehicle’s total value. Commerce instructed importers seeking approval to submit documentation electronically on a model basis, certified by a senior officer (e.g., CFO or General Counsel), detailing:

1. The total declared customs value of an MHDV in the model at the time of importation;
2. The total value of U.S. content attributable to U.S. production or U.S. production-related activities;
3. The total value of non-U.S. content;
4. MHDV production location(s) and country of final assembly;
5. Certification of USMCA eligibility (e.g., the signed origin certificate); and
6. The importer name, importer of record number, manufacturer name, manufacturer facility, country of origin, and model information for every model requested in the submission.

CBP’s latest guidance outlines how importers and their designated brokers should file import entries after receiving approval from Commerce. For eligible MHDVs, CBP instructs filers to report the values on two lines. The first line reports the non‑U.S. content subject to the 25% Section 232 tariff under Heading 9903.74.03, while the second line reports the approved U.S. content excluded from that tariff under Heading 9903.74.06.

If your company would like support in applying for Section 232 MHDV tariff relief or would like assistance in verifying its application to your entries, please reach out to one of our attorneys at Barnes, Richardson & Colburn.