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On May 6, 2026, U.S. Customs and Border Protection (“CBP”) released new guidance via CSMS #68559236 regarding the application of 25% Section 232 duties for Medium and Heavy-Duty Vehicles (“MHDVs”) that qualify for preferential treatment under the United States-Mexico-Canada Agreement (“USMCA”).  Pursuant to Presidential Proclamation 10984, the Secretary of Commerce may approve eligible MHDVs to have the 25% tariff applied exclusively to the value of the non-U.S. content.

Entry Filing Instructions:

The special tariff treatment applies to approved USMCA qualifying vehicles entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 a.m. Eastern Time on November 1, 2025.

When filing entries, importers and Customs brokers must report vehicle content using the following Harmonized Tariff Schedule of the United States (“HTSUS”) headings:

  • 9903.74.03: Applies to the non‑U.S. content of an MHDV approved by the Secretary of Commerce for special tariff treatment under the USMCA and is subject to a 25% ad valorem rate of duty.
  • 9903.74.06: Applies to the U.S. content of MHDVs that received approval from the Secretary of Commerce and carries a 0% additional ad valorem rate of duty.

Reporting Instructions:

To apply this special tariff treatment, importers that have received approval from the Department of Commerce must report the vehicle’s non-U.S. content and U.S. content on two separate entry lines.  Each line should be reported in accordance with the instructions below:

  • First Line (Non-U.S. Content):
  • Report the total quantity of the imported goods. 
    • Report the value of the non-U.S. content approved by the Commerce Department for entered value. 
    • Report the Section 232 duties based on the value of the non-U.S. content with HTSUS 9903.74.03. 
    • Report Special Program Indicator (SPI) code “S”. 
    • Report Ch. 1-97 HTSUS, same HTSUS must be reported on both lines. 
    • Report country of origin, same country of origin must be reported on both lines. 
    • Report all other applicable duties, such as antidumping and countervailing duties 
  • Second Line (U.S. Content):
  • Report 0 for quantity.  
    • Report the entered value of the U.S. content by subtracting the value of the non-U.S. content from the entered value of the article. 
    • Report the 0 duties based on the value of U.S. content with HTSUS 9903.74.06. 
    • Report Special Program Indicator (SPI) code “S” 
    • Report the same Ch. 1-97 HTSUS reported on the first line. 
    • Report the same country of origin reported on the first line. 

The guidance notes that importers should report all other applicable duties, such as antidumping (“AD”) and countervailing duties (“CVD”).

The Husch Blackwell International Trade and Supply Chain team will continue to monitor this and provide updates as they become available.  If you have any questions or concerns, please contact your Husch Blackwell attorney.