International Trade Administration Publishes USMCA Preferential Treatment Criteria For Auto Importers

On Tuesday, May 27th, 2025, the International Trade Administration published guidance on how automobile importers can determine the amount of U.S. content within a vehicle and thus qualify for United States-Mexico-Canada Agreement (USMCA) preferential treatment.

Background

On March 26, the President imposed tariffs on imports of certain automobiles and automobile parts. The proclamation stated that for USMCA-compliant autos, importers may submit documentation to the Department of Commerce identifying the amount of US content in the model to reduce the tariffs. 

The International Trade Administration has now released guidance on how auto importers can determine the amount of US content for this preferential treatment.

Criteria

Auto importers must provide the following information: 

1. The total declared customs value of an automobile in the model line at the time of importation based on 19 U.S.C 1401a. If the customs value varies within the model line, the importer may provide an average value consistent with an averaging methodology set forth in Article 5 of the Appendix to Annex 4-B, “Provisions Related to the Product-Specific Rules of Origin for Automotive Goods,” of Chapter 4 of the USMCA (“Automotive Appendix”) (available here.)
2. Total value of U.S. content for an automobile in that model line based on 19 U.S.C. 1401a attributable to parts wholly obtained, produced entirely, or substantially transformed in the United States for a vehicle in the model line. If the U.S. content attributable to such parts varies within a model line, the importer may provide an average value consistent with an averaging methodology set forth in the USMCA Automotive Appendix Article 5.
3. Total value of non-U.S. content of an automobile in the model line, calculated by subtracting the value of the U.S. content for an automobile in the model line from the total value of the automobile. If the value varies within the model line, the importer may provide an average consistent with an averaging methodology set forth in the USMCA Automotive Appendix Article 5.
4. Vehicle production location(s) and country of final assembly. Vehicle production locations may include more than one country.
5. Certification of eligibility for USMCA preference (the signed origin certification that supports the import meeting the rules of origin requirements as well as the approved producer-submitted auto certifications, jointly reviewed/approved by U.S. Customs and Border Protection and the Department of Labor, for meeting North American steel and aluminum content, and North American labor value content requirements) for the model line as submitted to U.S. Customs and Border Protection, including whether the model line is subject to an approved Alternative Staging Regime outlined in the USMCA Automotive Appendix Article 8 of Chapter 4 of the USMCA (available here).
6. The importer name, importer of record number, manufacturer name, manufacturer facility, country of origin, and year, make, and model information for every model line requested in the submission. If retroactive treatment is requested, the importer should provide entry numbers for previously imported automobiles.

More information is available on the Federal Registrar’s website. For questions, please contact the RV Industry Association’s Director of Federal Affairs Samantha Rocci at srocci@rvia.org.