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Auto parts & vehicles

DOT and EPA conformance on high-line-count parts entries.

A container of parts is a thousand small decisions. Most of the duty exposure sits in whether a given item counts as a part of a vehicle at all.

Tariff reference
Ch. 87
Agencies
CBP · NHTSA · EPA · Commerce ITA
Built from
A held part master

Chapter 87 is smaller than people assume

Heading 8708 covers parts and accessories of motor vehicles, but Section XVII of the tariff excludes a long list of things that are physically bolted to cars. Fasteners go to Chapter 73. Bearings go to 8482. Springs, chain, seals, hoses and general-purpose articles of base metal all leave Chapter 87 by legal note rather than by anyone exercising judgement. Engines and their parts sit in Chapter 84. Lighting, sensors, harnesses and control units sit in Chapter 85. What survives into 8708 is narrower than the catalogue suggests.

This matters more in 2026 than it used to, because the tariff programmes attach at different places in the schedule. A stamped bracket classified in Chapter 73 is a steel derivative under Section 232. The same bracket filed in 8708 is not, and that entry is now wrong in a way CBP can find with a database query rather than an examination. Classification stopped being an argument about two and a half per cent some time ago.

What a parts entry costs

Three programmes can reach the same line. The Section 232 action on automobile parts has applied to the listed subheadings since May 2025 at 25%, with separate treatment for parts qualifying under the USMCA. Section 232 on steel and aluminium reaches parts that are not on the automotive list but are made of those metals, on their metal content only. Section 301 puts 25% on most China-origin parts under List 3. Underneath all of it sits the ordinary rate, generally 2.5% in 8708, plus any antidumping deposit.

They do not all stack. Published precedence rules stop an article paying both the automotive 232 and the metals 232, and applying that correctly line by line across an invoice with a thousand SKUs is where the money is. Applying it by hand is where the errors are. The mechanics of the metal content split are on the Section 232 page.

There is real AD/CVD exposure in this commodity: container chassis and subassemblies, steel wheels, truck and bus tyres, and passenger and light truck tyres from several countries all sit under active orders. Coverage is decided by the scope language, not by your part number, so a supplier quietly changing a rim source can move a line inside an order and nobody finds out until liquidation. See AD/CVD duties.

The parts that are not only parts

Some items are regulated as equipment in their own right. NHTSA regulated equipment, which includes brake hoses, glazing, lighting, tyres and child restraints, needs a DOT HS-7 declaration and the correct conformance marking on the goods themselves. A tyre without a DOT symbol moulded into the sidewall is not a classification problem, it is a refusal.

Emissions hardware belongs to EPA. Aftermarket catalytic converters have to meet EPA requirements to be imported and sold, California adds its own, and any device whose purpose is to defeat an emissions control is prohibited outright rather than merely dutiable. Those shipments are seized, and seizure is the cheap outcome.

Then there is intellectual property. Automotive parts are among the highest-volume categories in CBP trademark enforcement. Recorded marks, part numbers and packaging are all checked, and a genuine component in counterfeit packaging is still a detention. If you buy outside the OEM channel, tell us before the container ships rather than after the notice arrives.

How we handle high line counts

You send a part master once: part number, description, material, origin, and a classification if you already have one. We classify what is missing, hold the table, and reconcile every shipment against it. New part numbers are flagged for classification when they enter your catalogue, not on the invoice we are trying to file on a Friday. Repeat containers become an exception report instead of a rebuild.

You get a draft 7501 to review before we transmit. That is the point at which to argue with a classification, when changing it costs an email rather than a post-summary correction.

What we need from you

  • Commercial invoice with a unique part number, description, material, quantity and unit value on every line.
  • Country of origin per line rather than per invoice. Mixed-origin consolidations are normal and they have to be filed that way.
  • Steel or aluminium content value on any part that falls inside a 232 derivative annex.
  • DOT and EPA status on regulated items, with the conformance marking visible in a photograph.
  • The purchase channel for anything carrying a brand you do not own.

Next step

Send the part master, not the container

Give us your catalogue in a spreadsheet and we will come back with classifications, the 232 and 301 exposure per line, and where an AD/CVD scope reaches you. Then the first shipment files itself.