Section 232 Auto Parts Inclusions Window Opens April 1: A Two-Week Window Importers Cannot Afford to Miss
# Section 232 Auto Parts Inclusions Window Opens April 1: A Two-Week Window Importers Cannot Afford to Miss
On March 24, 2026, the International Trade Administration published a Federal Register notice announcing the opening of a Section 232 automobile parts tariff inclusions window. Submissions are accepted starting April 1 and the window closes at 11:59 p.m. ET on April 14, 2026. That is 14 days to either request that your parts category be added to the Section 232 scope — or to submit public comments opposing inclusions that could raise your costs.
If you import automobile parts, components, or derivative products into the United States, this is an active regulatory process where your participation may directly affect your duty rate.
What Section 232 on Automobiles Actually Covers
Section 232 of the Trade Expansion Act of 1962 allows the president to impose tariffs on imports that threaten national security. The current Section 232 tariff on automobiles and automobile parts has been set at 25% since May 2025. It applies to passenger vehicles, light trucks, and a list of specified derivative parts including engines, transmissions, and body stampings.
Critically, not all auto parts are automatically covered. The statute's implementing proclamation created a defined list of HTS codes subject to the 25% rate — and there is a formal process by which additional parts can be "included" into that list if requested by interested parties and accepted by Commerce.
The inclusions window announced March 24 is exactly that process. If a parts category is not currently subject to Section 232 duties, a manufacturer, importer, or trade association can file a request to have it added. Conversely, the public comment period that follows accepted submissions gives opponents of any specific inclusion a chance to argue against it.
Why the Timing Matters
This is not the first inclusions window under the automobile Section 232, but the context has changed materially since the last cycle. The Supreme Court's February 2026 invalidation of IEEPA tariffs removed the IEEPA-based reciprocal rates, and the administration's Section 122 universal surcharge expires July 24, 2026. Commerce and USTR are actively constructing the tariff architecture that replaces those instruments.
An expanded Section 232 auto parts scope is one of the tools on the table. Parts categories that were previously subject only to MFN base duties plus Section 122's 15% may, if included in Section 232, face a 25% Section 232 rate instead — potentially alongside or in place of Section 122 when it sunsets.
For importers currently benefiting from USMCA treatment on Canadian- or Mexican-origin parts, this matters even more. USMCA partners are exempt from Section 122, but they are not exempt from Section 232. A successful inclusion request would add a 25% duty to parts that currently enter at zero under USMCA.
A Concrete Example
Consider an importer bringing in $300,000 worth of automotive sensors (HTS 8543.70) sourced from Germany. Under today's rates:
- Base MFN duty (0% for sensors): $0 - Section 122 universal surcharge (15%): $45,000 - Total duties: $45,000 | Landed cost: ~$345,000
If a Section 232 inclusion request is accepted and automotive sensors are added to the scope, the new rate structure would be:
- Base MFN duty: $0 - Section 232 (25%): $75,000 - Section 122 exemption applies to Section 232-covered goods (per Feb 24 proclamation) - Total duties: $75,000 | Landed cost: ~$375,000
That's a $30,000 increase on a single shipment. Use our Duty & Tariff Calculator to model your current exposure, and track how it changes if specific parts categories are added to Section 232 scope.
What the Inclusions Process Looks Like
Requests must be submitted by email to AutoInclusions@trade.gov before 11:59 p.m. ET on April 14, 2026. The notice specifies that requests should identify the product by HTS code, describe the national security basis for inclusion, and explain the domestic manufacturing landscape for the product.
Once the submission window closes, Commerce will review requests and publish those accepted for public comment — using Docket ID ITA-2025-0040 at regulations.gov. A two-week public comment period follows each accepted submission. Importers, trade associations, and domestic manufacturers can all submit comments supporting or opposing specific inclusions.
After the comment period, Commerce makes a recommendation to the president, who issues a proclamation modifying the Section 232 scope. There is no statutory timeline for that final step, but prior inclusions cycles have moved within 90–120 days of the comment period closing.
What Importers Should Do Before April 14
Audit your HTS codes against the current Section 232 automotive parts list. If your products are not currently on the list, assess whether they could plausibly be targeted in an inclusion request. The original proclamation covered engines, transmissions, body parts, and electrical components — adjacent categories like sensors, advanced driver assistance system components, and EV-specific parts have been discussed as likely targets.
Monitor Docket ITA-2025-0040. Once accepted requests are posted on regulations.gov, you will have roughly two weeks to submit comments. Missed deadlines mean no formal record of your position before the determination is made.
Model your landed cost at 25% Section 232. For each key automotive product, run the numbers assuming a 25% Section 232 rate and the simultaneous expiration of Section 122. Some parts categories may actually see duties decline if Section 122 (15%) is replaced by a lower effective rate; others will see significant increases.
Engage a customs attorney or broker. Inclusion requests require a formal written submission that addresses national security criteria. A customs attorney experienced in Section 232 proceedings can help you draft effective comments or objections.
The Bottom Line
The April 1–14 inclusions window is a short, high-stakes process with consequences that will outlast the current Section 122 surcharge. Automotive parts importers who engage now — by monitoring accepted requests and submitting timely comments — retain the ability to shape the outcome. Those who don't participate will have no formal voice in a determination that could significantly change their cost structure.
Use our Duty & Tariff Calculator to estimate your updated landed cost under current rates and various Section 232 scenarios.
Related Tools
Need help applying these concepts to your operation?
Our tools and insights help logistics professionals optimize freight, warehouse, and duty costs.
All free. No signup required.