Auto parts tariff engineering involves HTS Chapter 87 subheadings, Annex II inclusion (Section 122 exemption), Section 232 derivative scope, and USMCA alignment. Reclassification can move parts in or out of various tariff programs simultaneously.
This guide covers Tariff Engineering for Auto Parts. Tariff engineering is the legal modification of products to fit HTS subheadings with lower duty rates.
For SMB importers, the practical implementation depends on volume, sector, and specific operational structure.
HTS Chapter 87 boundaries
Auto parts can classify in Chapter 87 (vehicles) or in adjacent chapters (84 for engines, 85 for electronics). Classification choice affects multiple programs.
Annex II inclusion
Some auto parts are listed in Section 122 Annex II (Section 122 exempt). Reclassification can move parts into the Annex II exemption.
Section 232 derivative scope
Section 232 steel/aluminum derivatives can apply to specific auto parts at certain HS subheadings.
USMCA alignment
Reclassification can affect USMCA RVC math, particularly for goods at the qualifying threshold.
Frequently asked questions
When is this most relevant?
For SMB importers with active duty exposure or those evaluating duty mitigation options.
What documentation is required?
Varies by topic. Core: CBP Form 7501, supplier certificates, BOM analysis, manufacturing process documentation.
How long does this take to implement?
Simple cases 2-4 weeks; complex setups 8-16 weeks. Some moves require binding rulings adding 30-90 days.
What does this cost?
Project scope: $5,000-$25,000 for most engagements. Ongoing retainer for active operations.
How do I begin?
Book a 15-minute scoping call. We confirm fit and scope before any engagement.
Get started
Run a tariff engineering analysis on your top SKUs. Fixed-fee $5,000-$15,000.