In Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts into The United States,” on March 26, 2025, President Trump ordered the Secretary of Commerce to create a process for including additional automobile parts for passenger vehicles and light trucks to Section 232 tariffs on imports. A new interim final rule published on September 17, 2025 by the Department of Commerce establishes that process and is meant to allow for the submission and review of requests to add additional automobile parts to the tariff list. The rule is effective as of September 17, 2025.

While now in effect, the Department of Commerce’s International Trade Administration (ITA) will be accepting comments on the interim final rule until November 3, 2025. Any comments must be submitted via www.regulations.gov under Docket/ITA-2025-0041. The regulations.gov ID is ITA–2025–0041, and submitters are asked to also refer to RIN 0625–AB30 in all comments.

Going forward, under this interim final rule, the ITA will open two-week submission windows to receive inclusion requests, four times a year. These two-week windows start on the first business day of January, April, July, and October. The first such window is supposed to open on October 1, 2025.

Background

The adoption of these procedures under the Section 232 automobile tariffs allows domestic automobile producers or an industry association representing such a producer to request the inclusion of additional automobile parts under these tariffs implemented by President Trump during his first administration pursuant to Section 232 of the Trade Expansion Act of 1962. Any submitted requests must establish that imports of additional automobile parts articles have increased in a way that threatens to impair the national security or otherwise undermine the objectives of Proclamation 9888 (84 FR 23433, May 17, 2019), the Automobile Proclamation, or a subsequent proclamation that addressed a threat to national security under Section 232. See Thompson Hine Updates of May 17, 2019 and March 27, 2025 for additional background.

This interim final rule follows a prior press release in June 2025 announcing the process and scheduling the first window to open on October 1. See Thompson Hine Update of June 27, 2025, announcing that ITA was establishing four two-week submission windows per year that was originally set to begin on July 1, 2025. 

Submission Process

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.

Upon receiving such a request, the ITA will review for completeness and then post a non-confidential version of all valid requests allowing for a 14-day public comment period.

The Secretary is required to make a determination on whether to include the requested articles within 60 days of receiving the request.

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Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.