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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
Proclamation 10984 is the first MHDV-specific Section 232 instrument in US history. It is statutorily and structurally distinct from Proclamation 10908 (the March-2025 light-vehicle 232 instrument): it rests on a separate Section 232 investigation by Commerce focused on Class 3-8 trucks, MHDV parts and buses, and a separate national-security finding by the President. The two instruments have non-overlapping HTSUS scopes — 10908 covers HTSUS 8703 passenger vehicles + light trucks and listed parts, 10984 covers Class 3-8 commercial trucks and HTSUS 8702 buses.
Three substantive design choices shape the impact profile:
1. Bifurcated rate. 25% on Class 3-8 trucks and on listed MHDV parts; 10% on HTSUS 8702 buses. The lower bus rate reflects (a) limited domestic bus-manufacturing footprint and (b) significant transit-agency procurement that would otherwise face severe pass-through. 2. USMCA non-U.S. content carve-out. Mirrors Proclamation 10908: USMCA-qualifying MHDVs are tariffed only on the non-U.S. content portion. This protects integrated North American truck production (PACCAR's Kenworth/Peterbilt Mexicali and Mexicali plants, Daimler Truck's Saltillo Freightliner plant, Volvo/Mack at New River Valley + Ridgeville, Navistar) from full-rate exposure but introduces a heavy CBP-administration burden — operationalised by FR doc 2026-02049 (2 Feb 2026). 3. Parts offset = 3.75% × US-assembled MHDV aggregate value (2025-2030). Same 3.75% structure as Proclamation 10925's light-vehicle offset, but with a longer six-year window (vs Proclamation 10925's two-year window). Effectively a six-year domestic-assembly subsidy denominated in tariff credits — fiscally not a budgetary outlay because it offsets duty revenue rather than appropriating cash.