A recent presidential proclamation announced 232 tariffs be applied to imports of lumber, timber, and their derivative products. A later proclamation extended the tariffs to include medium- and heavy-duty vehicles and their parts—previously limited to passenger vehicles and light trucks.
What is the scope?
Called out in the Lumber and Timber 232 Annex are certain softwood timber and lumber products found in Harmonized Tariff Schedule headings 4403, 4406, and 4407 tariffed at 10%. Also, certain upholstered wooden furniture products in subheading 9401.61 and certain completed kitchen cabinets and vanities in heading 9403 tariffed at 25%.
Annex I details the impact on medium- and heavy-duty vehicles, including buses, and their parts. The annex captures numerous classifications, but the tariffs only apply if the parts are used in these vehicle types. While the buses and other vehicles classifiable in heading 8702 are tariffed at 10%, the other vehicles and parts are tariffed at 25%. Vehicles and buses included in this proclamation that were manufactured at least 25 years prior to the date of entry can receive a 232 duty of 0%.
What is the cumulative tariff impact?
Lumber and Timber 232 impacted articles, while subject to any applicable antidumping and countervailing duties, are exempt from Automotive 232 measures and the following IEEPA-related tariffs: Reciprocal tariffs, Fentanyl (Canada and Mexico), Brazil, and India.
Medium- and Heavy-Duty 232 impacted articles, while also subject to any applicable antidumping and countervailing duties, are exempt from additional duties applied to other Automotive 232 measures, as well as those on steel, aluminum, copper, lumber/timber, and the IEEPA tariffs listed above.
How do these interact with USMCA and trade agreements?
Medium- and heavy-duty vehicles, including buses, and their parts (hereafter referred to as MHDVs and MHDVPs), eligible for special tariff treatment under the United States-Mexico-Canada Agreement (USMCA), may qualify for reduced duty rates.
For USMCA-eligible MHDVs with U.S. content, only the non-U.S. content is subject to Section 232 duties. Until the Department of Commerce and U.S. Customs and Border Protection establish a process for reporting this distinction, the full USMCA value should be entered duty-free.
MHDVPs claiming USMCA—excluding MHDV knock-down kits or parts compilations—may be entered under a 0% Section 232 tariff. For MHDVPs produced in the EU or Japan, if the Harmonized Tariff Schedule (HTS) duty rate is lower than 15%, the total duty rate will be capped at 15%. No Section 232 duty will be assessed on MHDVPs with an HTS rate higher than 15%. The same applies to goods of UK origin, with the cap set at 10%.
While there is no USMCA provision for the Lumber and Timber 232 measures, goods of the United Kingdom, Japan, and member countries of the European Union are afforded country-specific duty rates on certain upholstered wooden furniture products, completed kitchen cabinets and vanities, and their parts. Products from Japan and the EU are subject to a 15% duty, while goods from the UK are subject to a 10% duty.
5 steps to take regarding these tariff changes
- Contact your C.H. Robinson representative to review your projected duty impact, based on your import history where C.H. Robinson was your customs broker. This will allow you to forecast accurately and strategize for potential mitigation.
- Verify your products are properly classified, as the HTS code determines whether a product is subject to additional tariffs. Inaccurate product classifications may result in unnecessary duties owed and potential compliance risks.
- Review your products’ countries of origin and assess USMCA eligibility, ensuring you receive proper duty capping or deferment where applicable under trade agreements.
- Be aware of previously mentioned stacking limitations to ensure that other exempted Trade Remedy tariffs are not applied when subject to these 232 tariffs.
- Review our client advisories for more details on potential overlap:
Staying prepared for future changes
As regulations shift and new tariffs emerge, staying proactive is essential for navigating the complexities of international trade. Connect with C.H. Robinson for personalized guidance and resources to ensure your operations remain compliant and competitive.
Stay informed
Developments in customs and trade continue to evolve—stay informed to be prepared:
