Trade Regulation Updates

Changes to US Tariff Stacking and Auto Import Tariffs

April 30, 2025

On April 29, 2025, the US Government issued an Executive Order outlining relief from stacking duties for certain imported items, and a Proclamation providing relief to automakers of cars and light trucks assembled in the US from facing stacked tariffs on auto part imports, both of which were set to take effect at 12:01 EST on May 3rd, 2025. 

Tariff Stacking:

If your imported goods are subject to more than one of the recent orders, the stacking of those tariffs is reduced. Meaning, for example, if your goods are subject to three now, they are only subject to one in some cases:

  • All goods subject to the International Emergency Economic Powers Act (IEEPA) Fentanyl Order on Canada and Mexico tariffs are exempt from the Section 232 Order on Steel and Aluminum.
  • Goods subject to Section 232 tariffs on autos and auto parts are exempt from the IEEPA Fentanyl Order on Canada, Mexico tariffs, and the Section 232 order on Steel and Aluminum.

The Executive Order provides instructions on how the tariffs will be applied and is set to be retroactively effective from March 4, 2025, making it possible for stacked duties paid to qualify for a refund. We recommend contacting our Trade Advisors to learn about the necessary qualifications and begin the process as soon as possible (additional fees may apply). 

Auto Parts Relief:

The Proclamation implements a temporary pause on tariffs imposed on automotive manufacturers. The intention behind this is to give US automotive manufacturers time to adjust their business and move production back to the US. Additionally, the proclamation outlines several augmentations to the original tariffs levied on automotive imports, including details on reimbursement and guidelines surrounding qualification for USMCA/CUSMA/T-MEC. 

  • Automobiles that pay 25% auto tariffs will no longer be subject to other IEEPA Fentanyl, nor any Section 232 steel and aluminum tariffs.
  • Automobiles assembled in the US are eligible for an upfront tariff offset of:
    •  3.75% (or a 15% discount on the MSRP value) for the first year (April 3, 2025 - April 30, 2026), provided the percentage of parts used is 85% US, Canadian, or Mexican made.
    • 2.5% (a discount of 10%) in the subsequent year (May 1, 2026 – Apr 30, 2027), provided the percentage of parts used is 90% US, Canadian, or Mexican made.
  • This offset is only applicable to vehicles assembled in the US and may be used by importers of record authorized by the manufacturer. 
  • The offset may only be applied to the company’s parts tariffs, not other unrelated tariff costs.

The proclamation instructs the US Commerce Secretary to establish a process by which importers can seek an import adjustment offset.

For complete details, you are encouraged to read the entire Executive Order and Proclamation

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