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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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In Proclamation 10908, &ldquo;Adjusting Imports of Automobiles and Automobile Parts into The United States,&rdquo; on March 26, 2025, President Trump ordered the Secretary of Commerce to create a process for including additional automobile parts for passenger vehicles and light trucks to Section 232 tariffs on imports. A new <a href="https://www.federalregister.gov/documents/2025/09/17/2025-18015/adoption-and-procedures-of-the-section-232-automobile-parts-tariff-inclusions-process" target="_blank" rel="noreferrer noopener">interim final rule</a> published on September 17, 2025 by the Department of Commerce establishes that process and is meant to allow for the submission and review of requests to add additional automobile parts to the tariff list. The rule is effective as of September 17, 2025.
While now in effect, the Department of Commerce&rsquo;s International Trade Administration (ITA) will be accepting comments on the interim final rule until November 3, 2025. Any comments must be submitted via <a href="http://www.regulations.gov" target="_blank" rel="noreferrer noopener">www.regulations.gov</a> under Docket/ITA-2025-0041. The regulations.gov ID is ITA&ndash;2025&ndash;0041, and submitters are asked to also refer to RIN 0625&ndash;AB30 in all comments.
Going forward, under this interim final rule, the ITA will open two-week submission windows to receive inclusion requests, four times a year. These two-week windows start on the first business day of January, April, July, and October. The first such window is supposed to open on October 1, 2025.
<h2 class="wp-block-heading">Background</h2>
The adoption of these procedures under the Section 232 automobile tariffs allows domestic automobile producers or an industry association representing such a producer to request the inclusion of additional automobile parts under these tariffs implemented by President Trump during his first administration pursuant to Section 232 of the Trade Expansion Act of 1962. Any submitted requests must establish that imports of additional automobile parts articles have increased in a way that threatens to impair the national security or otherwise undermine the objectives of Proclamation 9888 (84 FR 23433, May 17, 2019), the Automobile Proclamation, or a subsequent proclamation that addressed a threat to national security under Section 232. See Thompson Hine Updates of <a href="https://www.thompsonhinesmartrade.com/2019/05/president-trump-delays-implementation-of-section-232-tariffs-on-imports-of-automobiles-and-automobile-parts/">May 17, 2019</a> and <a href="https://www.thompsonhinesmartrade.com/2025/03/president-trump-announces-section-232-tariffs-of-25-on-imports-of-automobiles-and-certain-auto-parts/">March 27, 2025</a> for additional background.
This interim final rule follows a prior <a href="https://www.trade.gov/press-release/department-commerce-announces-new-auto-parts-tariff-inclusions-process" target="_blank" rel="noreferrer noopener">press release</a> in June 2025 announcing the process and scheduling the first window to open on October 1. See Thompson Hine Update of <a href="https://www.thompsonhinesmartrade.com/2025/06/department-of-commerce-announces-new-procedures-to-request-tariffs-on-auto-parts/">June 27, 2025</a>, announcing that ITA was establishing four two-week submission windows per year that was originally set to begin on July 1, 2025.&nbsp;
<h2 class="wp-block-heading">Submission Process</h2>
Each request must include (1) the requester&rsquo;s identification, (2) a description of the item, (3) the eight or ten-digit classification number from the Harmonized Tariff Schedule of the United States (HTSUS) requested for tariff inclusion, (4) an explanation of why the item is an auto part, (5) information on the domestic industry affected by imports of the item, (6) statistics on imports and domestic production of the item, and (7) a description of how and to what extent imports of the item have increased in a manner that threatens to impair national security or undermine the objectives of the automobile tariffs under Section 232.
Upon receiving such a request, the ITA will review for completeness and then post a non-confidential version of all valid requests allowing for a 14-day public comment period.
The Secretary is required to make a determination on whether to include the requested articles within 60 days of receiving the request.

New Process Announced for Adding Automobile Parts to Section 232 Tariffs

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