Hot Topics in International Trade - February 2026 - Self-Declaring Under the Section 232 Automotive and MHDVP Programs - JD Supra

Importers of certain automotive and medium- and heavy-duty vehicle parts (MHDVP) are reminded of ongoing self-declaration requirements to avoid the imposition of Section 232 duties. While the United States government previously threatened Section 232 tariffs on these products, agreements with key trading partners led to a mechanism where importers must actively declare that their goods are not subject to these duties. This critical compliance step ensures that the intended tariffs, which could be substantial, are not applied to eligible imports.

Specifically, two distinct programs are in effect. The Automotive Program applies to imports of automotive products originating from Japan, the European Union (EU), and the United Kingdom (UK). Separately, the Medium- and Heavy-Duty Vehicle Parts (MHDVP) Program covers imports of MHDVP products from Japan and the EU. Importers dealing with these specific products from these countries of origin are directly affected and must adhere to the self-declaration protocols to maintain duty-free status under Section 232.

To properly self-declare, importers must utilize Harmonized Tariff Schedule of the United States (HTSUS) subheading 9903.45.20 at the time of entry. This specific subheading acts as the declaration that the imported goods are not subject to the Section 232 duties. Failure to correctly apply this subheading for eligible imports would result in the imposition of a 25% Section 232 duty. As of February 2026, these requirements remain current and are a vital part of trade compliance for the affected product categories and origins.

Given these ongoing requirements, importers should take proactive steps to ensure compliance. It is crucial to meticulously review all import classifications and verify the countries of origin for automotive and MHDVP products. Importers must ensure that their customs brokers or internal compliance teams are correctly applying HTSUS subheading 9903.45.20 for all eligible entries from Japan, the EU, and the UK. Understanding the potential 25% duty rate for non-compliance underscores the financial importance of accurate self-declaration. If there is any uncertainty regarding product classification, country of origin, or the application of this subheading, consulting with a qualified customs broker or trade counsel is highly recommended.