Tariffs and Trade

Below is the latest update on trade and tariffs for Auto Care Association members.

Recent tariff measures require supply chains to maintain a higher level of data granularity, including detailed information on inputs and production, in order to document and support value content declarations with a level of specificity that may not have been previously required.

We encourage you to consult with your customs broker or trade counsel for further guidance and to ensure compliance.

Webinar: Tariffs and Trade Update (as of April 9, 2025)

Wednesday, April 9, 2025 | 2:00 PM ET

This webinar will provide attendees with an overview of the current state of affairs on all tariffs. It will feature some best practice actions companies can take to help ensure compliance and mitigate tariff impact.

Reciprocal Tariffs Announced on April 2

On April 2, referred to by President Trump as “Liberation Day”, the administration released its long-anticipated reciprocal tariff plan, imposing a 10% baseline tariff, effective April 5, on all imports into the United States. Additionally, 57 countries will face increased tariffs ranging from 11% to 50%, effective April 9.

(While earlier reports indicated that 60 countries would face increased tariffs, the list was revised following the president’s announcement to adjust tariff levels for three island nations.)

Calculations: Although the administration initially indicated that tariff rates would mirror those imposed by other countries on U.S. exports, the final rates are based on the U.S. trade deficit in goods (excluding services), as outlined in the USTR’s reciprocal tariff calculation methodology.

Drawback: According to the U.S. Customs and Border Protection CSMS notice on April 5, 2025, drawback is available on duties imposed under the reciprocal tariff order.

Exemptions: Certain goods will be excluded from the reciprocal tariff rates, including:

1. Articles covered by IEEPA general exclusions (50 USC 1702(b)) such as donations, personal mail, informational materials, etc.
2. Articles and derivatives of steel and aluminum currently subject to Section 232 tariffs
3. Autos and auto parts currently subject to Section 232 tariffs
4. Other products listed in Annex II, including copper, pharmaceuticals, semiconductors, lumber, certain critical minerals and energy and energy products
5. Products from a trading partner subject to rates in Column 2 of the HTSUS (Cuba, North Korea, Russia and Belarus)
6. All products that may become subject to future Section 232 tariffs

In other words, if your product is already subject to the steel and aluminum tariffs, the autos and autos parts tariffs or any of the other exemptions listed above, your product is exempt from these reciprocal tariffs.

The new tariffs will be applied in addition to any existing duties, fees, taxes, exactions, or charges—unless an exemption applies.

White Paper: The Auto Care Association has published a reciprocal tariffs white paper examining the history, theory, and potential economic impacts of reciprocal tariffs.

Auto Care Trade Resource Page

Tariffs on Autos and Auto Parts

A Federal Register notice released the list of auto parts HTS codes that would be subject to an additional 25% tariff on imports from all countries, effective May 3, 2025. Please review the notice to confirm if your products are impacted by this tariff action.

List of Auto Parts: Federal Register Notice, Annex I, page 11-12

The list covers a wide range of parts for passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks.

USMCA: For auto parts that qualify for USMCA preferential tariff treatment, tariffs are delayed until the administration establishes a process to apply the tariff exclusively to the value of the non-U.S. content. More information will be released in a forthcoming Federal Register notice. The tariff does not apply to auto knock-down kits or parts compilations.

Retaliation from Trading Partners

In response to recent U.S. trade actions, China announced countermeasures, including a 34% tariff on all U.S. imports. Canada has also imposed retaliatory tariffs on a number of U.S. imports with an exemption for auto parts.

De Minimis Exemption Revoked for China

On April 2, 2025, President Trump signed an executive order revoking the de minimis exemption for low-value imports from China and Hong Kong, effective May 2. As a result, all shipments from these regions, regardless of value, will now be subject to applicable duties.

Postal Shipments: Goods sent via international postal shipments, transportation carriers may elect to apply a 30% duty or $25 per item will apply, increasing to $50 per item after June 1. This is in place of any other duties, including those imposed by prior orders.

Non-Postal Shipments: Goods shipped through non-postal channels, all applicable duties will apply.

De minimis was previously eliminated through the IEEPA order on China but was delayed pending an implementation process.

Lawsuit Filed Challenging IEEPA Tariffs

The New Civil Liberties Alliance (NCLA) has filed a lawsuit on behalf of Simplified, a Pensacola, Florida-based stationery company that imports from China. The lawsuit argues that IEEPA does not authorize the president to impose tariffs and claims the 20% tariff on Chinese goods is unlawful.

IEEPA Lawsuit