On June 24, 2025, in a press release, the Department of Commerce’s International Trade Administration (ITA) announced new procedures for U.S. producers of auto parts to request that additional auto parts be included in the list of auto parts that are subject to 25% tariffs under the Section 232 review of automobiles and auto parts. These procedures are established pursuant to President Trump’s Proclamation issued on March 26, 2025. For additional background, see Thompson Hine Update of March 27, 2025 and Update of April 30, 2025.
ITA is establishing four two-week submission windows per year in January, April, July, and October respectively. The first ever window is scheduled to open on July 1, 2025. During each window, the ITA will review requests on a rolling basis. After the closing of each window, a non-confidential version of each valid request will be posted and open to public comment for fourteen days. The ITA will make a determination within sixty days of receiving the request.
Each request must include (1) the requester’s identification, (2) a description of the item, (3) the eight or ten-digit classification number from the Harmonized Tariff Schedule of the United States (HTSUS) requested for tariff inclusion, (4) an explanation of why the item is an auto part, (5) information on the domestic industry affected by imports of the item, (6) statistics on imports and domestic production of the item, and (7) a description of how and to what extent imports of the item have increased in a manner that threatens to impair national security or undermine the objectives of the automobile tariffs under Section 232.
In addition to this request mechanism, the Secretary of Commerce can also add more auto parts to the tariff list without requests from producers, according to the March 26, 2025 Proclamation. Parties interested in pursuing tariffs on imported auto parts may consider submission of a request. However, parties wishing to exclude tariffs on imported auto parts may plan to monitor the requests during every quarterly period and consider submission of public comment opposing the requested tariffs.