Proclamation 10925 creates import-adjustment offset for auto manufacturers

On 29 April 2025 President Donald J. Trump signed Proclamation 10925, “Amendments to Adjusting Imports of Automobiles and Automobile Parts Into the United States,” amending Proclamation 10908 of 26 March 2025 to create an import-adjustment offset administered by the Secretary of Commerce for US-based final- assembly manufacturers.¹² On application to and approval by Commerce, an eligible manufacturer’s designated importer(s) of record receive an offset against duties otherwise owed at HTSUS subheading 9903.94.05 (parts of passenger vehicles and light trucks) per Note 33 to subchapter III of Chapter 99, equal to 3.75 per cent of the aggregate Manufacturer’s Suggested Retail Price of all automobiles assembled in the United States between 3 April 2025 and 30 April 2026, declining to 2.5 per cent from 1 May 2026 through 30 April 2027.¹³⁴ On the same day, the President signed Executive Order 14289 (“Addressing Certain Tariffs on Imported Articles”), establishing anti-stacking precedence rules so that the Section 232 auto/parts tariff excludes the Canada and Mexico IEEPA fentanyl tariffs and the Section 232 steel and aluminum tariffs on the same article.⁵

1. The offset is conferred by CBP on the manufacturer’s approved importer of record against parts duties otherwise owed at HTSUS 9903.94.05, not against vehicle-assembly duties or supplier-borne parts duties. The 25 per cent auto-parts duty under Proclamation 10908 became effective 3 May 2025; the 3 April 2025-30 April 2026 measurement window for the offset begins from the auto-tariff effective date, with parts-duty incidence beginning 30 days later.²⁶

2. Proclamation 10925 invokes Section 232 of the Trade Expansion Act of 1962, 19 U.S.C. § 1862(c) (the President’s “adjust imports” authority on an affirmative national-security finding), alongside § 604 of the Trade Act of 1974, 19 U.S.C. § 2483 (HTSUS-modification authority).⁷⁸ USMCA-certified vehicles continue to be taxed only on non-U.S. content under Proclamation 10908, after Commerce certification.⁹

3. The Commerce administering notice (90 Fed. Reg. 25027, 13 June 2025) provides that unused offset amounts may be carried forward beyond the 30 April 2027 sunset until the approved amount is exhausted, but the proclamation does not provide for cash refund of unused balances.⁴ The declining-incentive schedule (3.75 per cent → 2.5 per cent → zero) sets the offset’s two-year sunset.