The Automotive Body Parts Association (ABPA) joined 30 other national trade associations in submitting comments to the Office of Management and Budget regarding the U.S. Department of Commerce’s Section 232 tariff inclusion process for steel and aluminum derivative products.
The coalition raised concerns that the current process places significant compliance burdens on U.S. importers while providing limited opportunity for meaningful industry input. Under the existing framework, stakeholders are given only 14 days to comment on proposed inclusions, with no public hearing and little clarity on the criteria used to evaluate submissions.
Of particular concern to ABPA members is the expanding scope of products deemed “derivative,” including items with minimal—or no—meaningful steel or aluminum content. Recent expansions added more than 400 HTS codes with just 48 hours’ notice, forcing importers to rapidly trace material content well beyond Tier 1 suppliers and risking Section 232 duties on the full value of products if documentation is incomplete.
The coalition also warned that these challenges will grow as the inclusion process expands to additional materials and sectors, including potential future reviews of auto parts. Without reforms, the process risks supply chain disruption, increased costs, and unnecessary impacts on downstream industries.
ABPA and its coalition partners urged the Department of Commerce to improve the Section 232 inclusion framework by providing clearer criteria, adequate transition periods, transparent guidance, and a meaningful stakeholder consultation process. ABPA will continue working with allied organizations to ensure trade policies do not unfairly burden aftermarket collision parts distributors and the consumers they serve.
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