Procedures for Submissions by Importers of Medium- and Heavy-Duty Vehicles Qualifying for Preferential Tariff Treatment Under the USMCA To Determine U.S. Content
Published Date: 2/2/2026
Notice
Summary
Starting February 2, 2026, importers of medium- and heavy-duty vehicles that qualify under the USMCA can submit proof showing how much U.S. content their vehicles have. This helps them get special tariff breaks despite new tariffs aimed at protecting national security. If you import these vehicles, this means you can save money by proving your U.S. content and following the new submission rules.
Analyzed Economic Effects
5 provisions identified: 1 benefits, 4 costs, 0 mixed.
Submit U.S.-content to limit tariffs
Starting February 2, 2026, importers of medium- and heavy-duty vehicles (MHDVs) that qualify for USMCA preferential treatment can submit documentation to the Department of Commerce showing the vehicle's U.S. content. If Commerce approves, the additional tariff will be applied only to the value of the non-U.S. content rather than the vehicle's full value.
Eligibility limited to USMCA-qualified imports
Only MHDVs imported from Mexico and Canada that qualify for preferential tariff treatment under the USMCA may be eligible to have the additional tariff applied only to non-U.S. content. Vehicles from non-USMCA countries and MHDVs from Canada and Mexico that do not qualify under USMCA are not eligible for this treatment.
Retroactive and prospective penalty for misreporting
If U.S. Customs and Border Protection (CBP) finds that an importer overstated U.S. content, the 25 percent tariff will apply retroactively (from November 1, 2025) and prospectively to the full value of all vehicles of the same model imported by that importer from the date of the inaccurate overstatement until corrected. This applies to the same model imported by the same importer.
Documentation and certification burden
Submissions must include model-level documentation certified by a CFO, General Counsel, or equivalent senior officer and must list customs value, U.S. content value, non-U.S. content calculation, production locations, USMCA preference certification, and importer and model details. The Department estimates an average public reporting burden of 20 hours per response, with an estimated 40 responses annually (total annual burden 800 hours).
Timing and validity rules for eligibility
Eligibility determinations issued in 2026 are valid only for vehicles imported in 2025 or 2026; importers seeking eligibility for a model imported in 2027 must submit new documentation no later than October 1, 2026. For imports after December 31, 2026, determinations are valid only for one calendar year and must be supported by documentation submitted no later than the October 1 before the calendar year of importation. New-model applications may be made anytime but are valid only until the end of that calendar year.
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