On December 16, 2025 the Bureau of Industry and Security (BIS) announced that it will provide an opportunity for interested parties to submit requests to add additional products to the list of auto parts that are subject to Section 232 duties under the Trade Expansion Act of 1962. The inclusions window will open on January 1, 2026, and close at 11:59 p.m. ET on January 14, 2026.
In an interim final rule published on September 17, 2025, the Department of Commerce established a process by which interested parties could request the inclusion of additional automobile parts subject to Section 232 tariffs. Under that process, domestic producers of automobiles or automobile parts, or any industry association representing one or more such producers, may submit inclusion requests during a two-week submission window that will open four times a year at the beginning of each January, April, July, and October.
For the request to be considered valid, the requestor must provide the following in their request:
- Clear identification of the requestor (i.e., producer of an automobile or automobile parts article, or an industry association of such producers);
- A precise description of the automobile parts article that is the subject of the request;
- The eight or ten-digit HTSUS classification requested to be included in the scope of the tariffs;
- An explanation of why the article is an automobile parts article;
- Pertinent information on the domestic industry affected;
- Statistics on imports and domestic production;
- A description of how and to what extent imports of the article have increased in a manner that threatens to impair the national security or otherwise undermines the objectives set forth in Proclamation 9888, the Automobile Proclamation, or any subsequent proclamation addressing the threatened impairment to the national security;
- Any business confidential submissions must also include a non-confidential public version; and
- All information submitted must be limited to 30 pages inclusive of all attachments.
The International Trade Administration (ITA) will review the received requests on a rolling basis during a two-week submission window. After the conclusion of the two-week submission window ITA will publicly post non-confidential versions of all valid requests for a 14-day public comment window.
ITA is expected to make a determination with respect to every request. ITA will post a determination memorandum on regulations.gov for each inclusions request within 60 days of receiving the requests that: (1) states whether the request was approved or denied; and (2) summarizes the rationale for making this determination.
Companies seeking to submit inclusion requests are advised to submit their request to the automobile parts inclusion inbox at AutoInclusions@trade.gov. Accepted inclusion requests will be posted for comment on Docket ID ITA-2025-0039 on Regulations.gov. If you have any questions on the inclusion process or how this might impact your business, please contact the Husch Blackwell Trade Team.