USTR Imposes 100% Tariffs on Ship-to-Shore Cranes Under Section 301

Effective November 9, 2025, the United States will impose additional duties of 100% on certain ship-to-shore (“STS”) cranes and certain cargo handling equipment from China under Section 301 of the Trade Act of 1974. These tariffs follow the Office of the U.S. Trade Representative (“USTR”)’s original proposal in April 2025.

The tariffs will also be imposed on STS cranes that contain certain components, assemblies, or subassemblies that are products of China, in addition to cranes manufactured outside China by a company owned or controlled by a Chinese person or entity. The new HTSUS codes covering these cranes and related equipment are contained in the USTR’s Notice. STS cranes that were under contract before April 17, 2025, and are delivered to the U.S. before April 18, 2027, will not be subject to these tariffs.

While not yet implemented, USTR indicated that it is also weighing imposing up to 150% tariffs on additional types of Chinese cranes, including rubber tire and rail mounted gantry cranes, automatic stacking cranes, reachstackers, straddle carriers, terminal tractors, top handlers, and certain components of these cranes.

In the same Notice, the USTR announced it will no longer seek penalties that allowed for the revocation of liquefied natural gas (“LNG”) export licenses of LNG companies that failed to start using U.S.-built tankers by certain dates.

U.S. Announces Tariffs on Medium- and Heavy-Duty Vehicles

On October 17, 2025, President Trump issued a Presidential Proclamation (the “Proclamation”) announcing the imposition of new tariffs on imports of medium- and heavy-duty vehicles (“MHDVs”), key vehicle parts (“MHDVPs”), and buses. Following a Section 232 investigation under the Trade Expansion Act of 1962, the Secretary of Commerce concluded that rising import levels in these sectors pose a threat to U.S. national security. The Secretary found that these vehicles and components are critical to military readiness, emergency response, and the continuity of essential infrastructure.

Effective November 1, 2025, a 25% ad valorem duty will apply to most MHDVs and designated parts, while buses and other vehicles classified in HTSUS heading 8702 will face a 10% duty. The specific list of HTSUS codes covered by these new tariffs can be found in Annex I to the Proclamation. Under the Proclamation, for MHDVs, except buses and other vehicles classified in HTSUS heading 8702, that qualify for preferential treatment under the USMCA, importers may submit documentation identifying the amount of US content in each model imported into the US. After submitting that documentation, the Secretary may approve imports of MHDVs to be eligible for the ad valorem rate to apply exclusively to the value of the non-US content. Imports of MHDVPs that are eligible for preferential treatment under the USMCA shall not be subject to the additional tariffs imposed by this Proclamation, until and unless a process is established to apply the tariff exclusively to the non-US content of such imports.

Furthermore, the Proclamation provided an offset mechanism to run from 2025-2030 as follows:

• For MHDVs assembled in the United States, MHDV manufacturers shall be eligible to receive an import adjustment offset equal to 3.75% the aggregate value of all MHDVs assembled in the US by that manufacturer from November 1, 2025 through October 31, 2030. The 3.75% reflects the total duty owed when a 25% duty is applied to parts accounting for 15% of an MHDV’s value.
• Only MHDVs that undergo final assembly in the United States are eligible to be included in this calculation. The manufacturer’s import adjustment offset amount may be used only by importers of record authorized by that manufacturer.
• The Commerce Secretary shall establish a process for MHDV engine manufacturers equivalent to the process described above. Import adjustment offsets for these engine manufacturers shall be based on the aggregate value of MHDV engines assembled by that manufacturer in the United States and shall follow the same accrual percentage rate and United States assembly requirement as the import adjustment offsets for MHDV manufacturers specified above.
• If the Secretary finds that the import adjustment offset program for a particular product is inconsistent with addressing the threat to the national security found in this proclamation, the Secretary may publish in the Federal Register a notice that prospectively prohibits MHDV or MHDV engine manufacturers from using offset amounts for imports of those products.
• Imports of MHDV knock-down kits or other equivalent parts compilations, as determined by CBP, shall not be eligible for import adjustment offsets of the sort specified in this clause.

This Proclamation also amends Clause 1 of Proclamation 10925 of April 29, 2025 (Amendments to Adjusting Imports of Automobiles and Automobile Parts Into the United States) to reflect those changes above and include the offsets allowed for MHDVs.

Furthermore, the Proclamation also amends Proclamation 9704 of March 8, 2018 (Adjusting Imports of Aluminum Into the United States), as amended; Proclamation 9705 of March 8, 2018 (Adjusting Imports of Steel Into the United States); Proclamation 9888, as amended to allow for modifications of tariffs imposed under such Proclamations, based on increased commitments of certain steel or aluminum products that support US production capacity of key products, including US automobiles and MHDVs. Under this provision, the Secretary of Commerce is authorized to reduce tariffs owed under Proclamations 9704 and 9705 by up to half the applicable rate for producers that operate production facilities in Canada or Mexico and supply the US automobile or MHDV manufacturers. This reduction will be limited to quantities of aluminum and steel equal to the newly committed US production capacity, as determined by the Secretary of Commerce. However, the rate shall never be adjusted to be lower than 25% and will be limited to imports of aluminum and steel which qualify for preferential treatment under the USMCA and were smelted and cast or melted and poured in Canada or Mexico.

The tariffs imposed under the Proclamation apply to those goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01a.m. EDT on November 1, 2025. Only manufacturing drawback claims are available with respect to MHDVPs. 

CBP guidance implementing the tariffs can be found here.

Trade professionals should closely monitor these developments, as they may impact sourcing strategies, supply chain planning, and compliance obligations. Husch Blackwell’s International Trade team continues to monitor developments and will provide additional updates as they arise.