Section 232 Tariff Offset Program for Autos, MHDVs and Engines
Frequently Asked Questions About the Section 232 Vehicle Offset Programs
Additional information useful to applicants of the Section 232 Offset Programs related to on-road motor vehicles is provided on this page of frequently asked questions (FAQs). Click on an individual question to expand to the answers. This page is updated periodically. For additional questions, please contact AutoOffset@trade.gov.
The Section 232 Offset program allows manufacturers of medium- and heavy-duty vehicles (MHDV), automobiles, and MHDV and automobile engines to offset against Section 232 tariffs owed on automobile and MHDV parts imports; it is not a cash refund. Offsets are earned based on U.S. assembly of automobiles, MHDVs, and their engines, and can be used by approved manufacturers and their authorized importers of record.
Generally speaking, the maximum amount of offset one manufacturer can accrue is equal to the lesser of 3.75% of the value of eligible U.S.-assembled automobiles, MHDVs, and auto and MHDV engines, or that manufacturer’s Section 232 automobile and MHDV part (Section 232 parts) tariff liability; providing offset amounts in excess of such tariff liability would allow for increased reliance on imported parts in future years. The cost of engines incorporated into an automobile or MHDV cannot be included in the calculation of the value of U.S. assembled automobiles or MHDVs, as engine manufacturers have their own offset program.
When applying for the offset program, a manufacturer submits forecasts of its production and Section 232 parts tariff liability for the approval period. Commerce uses those forecasts to calculate the initial offset award. In the next approval cycle, Commerce will compare the forecasts with the manufacturer’s actual results for that prior period and adjust the next year’s award if necessary to account for any difference.
The Offset program covers imports of automobile parts and medium- and heavy-duty vehicle (MDHV) parts that are subject to Section 232 duties under Proclamations 10908 and 10984. Section 232 tariffs apply to HTSUS subheadings explicitly identified in those Proclamations. Additionally, manufacturers or their designated Importers of Record may declare that a good is an automobile or MHDV part, and thus subject to Section 232 tariffs that may later be offset, as long as the good is:
- Not already subject to tariffs under the Section 232 automobile and MHDV proclamations, as amended,
- Not classified in HTSUS Chapters 72, 73, or 76, and
- Certified by the importer of record as intended for automobile or MHDV production or repair activity in the United States.
Please refer to the current HTSUS and up-to-date CBP guidance to confirm whether a specific article is eligible for an offset.
A manufacturer applies by submitting an application covering production for one of the time periods specified in the relevant procedures electronically to the Department of Commerce at autooffset@trade.gov. Commerce reviews the application for completeness, may request supplemental documentation or clarification, and then transmits the approved offset and authorized Importer of Record (IOR) data to CBP.
Generally speaking, the application includes:
- A production forecast detailing U.S. plant, make, and model for eligible vehicles, plus a description of U.S. manufacturing activities
- Aggregate vehicle value, applicable engine cost/value deduction or exclusion
- A projected tariff liability estimate, separated into direct manufacturer costs and supplier-incurred costs
- The requested offset calculation
- A list of all authorized IORs with their specific allocated amounts
- Where applicable, prior-year actual production and value data and details on super-core part incorporation
- A sworn certification from a senior officer, made under penalty of perjury, that the submitted information is true, accurate, complete, and based on reasonable diligence
See this Federal Register Notice for further details on the automobile and MHDV offset application, and this Federal Register Notice for further details on the automobile and MHDV engine offset application.
For the Commerce application: the manufacturer must submit the IOR number and the offset amount allocated to each IOR. The manufacturer may request this information from the IOR in order to complete its application; the IOR does not provide information to Commerce directly.
Completed applications must be submitted electronically to autooffset@trade.gov. Once submitted, Commerce will review for completeness and may request supplemental documentation or clarification from the applicant.
After receiving an application, Commerce evaluates the submission for completeness, may request supplemental documentation or clarification, and notifies the manufacturer in writing of approval and the granted offset amount before transmitting data to CBP. Manufacturers should plan for potential follow-up inquiries after submitting an offset application. While the Commerce procedures do not specify a time period for consideration, Commerce endeavors to respond expeditiously to each application.
No specific calendar deadline exists for applying for offsets. Instead, manufacturers must submit separate applications for each annual reporting period:
- Automobiles: The initial reporting period covers automobiles assembled in the United States between April 3, 2025, and April 30, 2026; all other reporting periods are annual and close on April 30 of the relevant year. The relevant annual periods are:
- Year 1: Automobiles assembled between April 3, 2025 and April 30, 2026;
- Year 2: Automobiles assembled between May 1, 2026, and April 30, 2027;
- Year 3: Automobiles assembled between May 1, 2027, and April 30, 2028;
- Year 4: Automobiles assembled between May 1, 2028, and April 30, 2029; and
- Year 5: Automobiles assembled between May 1, 2029, and April 30, 2030.
- MHDVs: The relevant annual periods are:
- Year 1: MHDVs assembled between November 1, 2025, and October 31, 2026;
- Year 2: MHDVs assembled between November 1, 2026, and October 31, 2027;
- Year 3: MHDVs assembled between November 1, 2027, and October 31, 2028;
- Year 4: MHDVs assembled between November 1, 2028, and October 31, 2029; and
- Year 5: MHDVs assembled between November 1, 2029, and October 31, 2030.
- Engines: The relevant annual periods for MHDV engines are:
- Year 1: MHDV engines assembled between November 1, 2025, and October 31, 2026;
- Year 2: MHDV engines assembled between November 1, 2026, and October 31, 2027;
- Year 3: MHDV engines assembled between November 1, 2027, and October 31, 2028;
- Year 4: MHDV engines assembled between November 1, 2028, and October 31, 2029; and
- Year 5: MHDV engines assembled between November 1, 2029, and October 31, 2030.
- The relevant annual periods for automobile engines are:
- Year 1: Automobile engines assembled between May 1, 2026 and April 30, 2027;
- Year 2: Automobile engines assembled between May 1, 2027 and April 30, 2028;
- Year 3: Automobile engines assembled between May 1, 2028 and April 30, 2029; and
- Year 4: Automobile engines assembled between May 1, 2029 and April 30, 2030.
Yes. A separate submission is required for each annual reporting period; periods should not be combined into a single submission.
A manufacturer is not required to allocate the full approved offset amount among identified IORs at the time the initial application is filed. While the application must list authorized IORs and their allotted amounts, manufacturers may submit electronic updates to Commerce at autooffset@trade.gov at any time to allocate previously unallocated balances or adjust existing allocations.
Yes. Submit the Department of Commerce offset license number in ACE’s Importer Additional Declaration Field (54 record), Type Code 11, format AANNNNNN. If an Importer of Record (IOR) is seeking to use an offset for a part that not listed in the Section 232 automobile and MHDV proclamations, the IOR must certify that the automobile or MHDV part will be used for automobile/MHDV production or repair activity in the United States and be prepared to provide supporting documentation to CBP upon request.
It is up to the manufacturer to notify its suppliers of the license number and offset amount associated with a given license number.
No. Pursuant to Proclamation 10984 (Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses into the United States, 90 FR 48451), the self-certification provision applies only to goods imported on or after November 1, 2025. Consequently, companies are not permitted to apply offsets to entries prior to November 1, 2025.