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ARTICLE · 09 FEBRUARY 2026

Commerce Issues Procedures On Applying For The US Content Partial Duty Exemption Under Section 232 MHDV Tariffs

ArentFox Schiff
ArentFox Schiff
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On February 2, the US Department of Commerce issued a Federal Register Notice outlining "US content" exemption procedures and requirements under the Section 232 tariffs on certain medium- and heavy-duty vehicles (MHDVs).

United StatesInternational Law
James Kim
James Kim
Collin M. Douglas
Collin M. Douglas

On February 2, the US Department of Commerce issued a Federal Register Notice outlining "US content" exemption procedures and requirements under the Section 232 tariffs on certain medium- and heavy-duty vehicles (MHDVs).

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Under this notice, upon submission of certain documentation and Commerce's approval, the Section 232 tariffs of 25% will apply only to the non-US content of imported MDHV models that qualify under the United States-Mexico-Canada Agreement (USMCA). The process significantly mirrors that established for the Section 232 automotive tariff regime in May 2025.

What's New and Why It Matters

Under Presidential Proclamation 10984, importers of MHDVs may submit documentation to Commerce identifying the amount of US content in each USMCA-qualifying model imported into the United States. Upon approval by Commerce, the additional tariff may then apply exclusively to the value of the non-US content, potentially mitigating the 25% rate significantly.

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