Import Tariffs: The Only Constant Is Change

 

When it comes to importing vehicles in 2025, the only thing you can count on is change. Tariff policy has shifted multiple times this year alone, creating a moving target for anyone trying to calculate landed costs. Here’s a breakdown of where things stand, and how we got here.

Baseline Tariffs (Long-Standing Rates)

• Passenger vehicles (HTS 8703, “cars”): 2.5% MFN duty — in place since the Trade Act of 1930 (Smoot-Hawley, June 17, 1930). The rate was locked into the Harmonized Tariff Schedule in 1989, but the 2.5% base goes all the way back to the 1930s.
  
  
• Trucks (HTS 8704, “light trucks”): 25% MFN duty — in place since the 1964 “Chicken Tax”, a retaliatory measure under the Trade Expansion Act of 1962. This 25% rate was codified into the tariff schedules and has never been reduced in any U.S. trade agreement.
  
  

April 2025 Change: EO 14289

In April 2025, Executive Order 14289 / Proclamation 10908 (effective March 26, 2025) dramatically raised base duties:

• Passenger vehicles: from 2.5% → 25%
  
  
• Trucks: from 25% → 50%
  
  

At the same time, the special 9903.94.04 provision applied to “25-year old vehicles.”

• If you were subject to the 232 Auto tariff, then you were exempt from IEEPA reciprocal tariffs.
  
  
• Between April and June 3, 2025, importers of 25-year old vehicles used 9903.94.04 to avoid the additional 10% IEEPA reciprocal duty.
  
  

June 4, 2025: New Stacking Guidance

On June 4, 2025, CBP issued new stacking rules (CSMS #59120123) and clarified what “subject to” meant:

• “Subject to” now only applies when the tariff rate is greater than 0%.
  
  

Effect: If you paid 0% under 232 (via 9903.94.04), you were no longer considered “subject to” it. That meant the reciprocal 10% IEEPA duty (9903.01.25 / .33) applied instead.

In practice:

• April–June 3, 2025: Cars = 25% (232 Auto), no reciprocal. Cars over 25 years old = 2.5%
  
  
• June 4 onward: Cars ≥25 years old = 2.5% MFN + 10% IEEPA = 12.5%, because 9903.94.04 reduced the 232 rate to 0%.
  
  

September 2025 Shift: Japan

Effective September 15, 2025 (Proclamation 10987; CSMS #60322147):

• Passenger vehicles from Japan moved to a flat 15% tariff.
  
  
• This replaced the 2.5% + 10% reciprocal structure that had applied since June.
  
  
• Trucks from Japan remained at 50% under 232 Auto.
  
  

Ongoing Issues

Ambiguity of “Subject To”

• Before June 4, many filers reasonably believed “subject to” meant covered, even at 0%.
  
  
• After June 4, CBP redefined it as only when >0% is owed, forcing reciprocal duties in cases where the 232 rate was 0%.
  
  
• Implementation lagged, adding confusion and inconsistent billing between June and September.
  
  

Constant Rule Changes

• April: Cars 25%, Trucks 50%  Cars over 25 yrs old 2.5%
  
  
• June: Cars ≥25 yrs old → 12.5% (2.5% + 10%)
  
  
• September: Japan cars → flat 15%
  
  

This rapid back-and-forth makes landed cost planning extremely difficult for importers.

 

The Bottom Line

• June 4 – September 15, 2025: Passenger vehicles ≥25 years old faced 12.5% (2.5% base + 10% reciprocal).
  
  
• September 15, 2025 onward: Passenger vehicles from Japan moved to a flat 15%, while trucks stayed at 50%.
  
  

Even if you stay on top of every rule change, the implementation and rollout of those changes often ends up confusing for both the ports and the people who ultimately have to pay the tariff.