News

9903.94.51 Explained: EU Autos 232 Combined 15% Rate

Published: October 6, 2026 · 8 min read

Key Points

HTS 9903.94.51 imposes a combined 15 percent Section 232 duty on passenger vehicles and light trucks originating in the 27 European Union member states, effective August 1, 2025, with no announced end date.
The 15 percent is a combined, all-in rate: it is not added on top of the normal MFN (column 1) duty. The 232 component equals 15 percent minus the column 1 rate, so your total ad valorem burden is 15 percent, not 15 percent plus column 1.
Coverage spans 17 in-force product rules across passenger-car subheadings 8703.xx and light-truck headings 8704.xx, as specified in U.S. note 33(n) of Chapter 99.
Legal authority is FR 2025-18660 and CSMS 66336270; the code migrated into CBP systems on July 24, 2026 at 18:00.
9903.94.51 rides alongside the chapter 1-97 classification line on the entry; both codes must appear for the entry to be correct.

HTS 9903.94.51 is the Chapter 99 duty code that applies a combined 15 percent Section 232 tariff to passenger vehicles and light trucks of European Union origin, effective August 1, 2025. Importers and brokers must report this code alongside the underlying chapter 1-97 vehicle classification on every covered entry. The combined rate means 15 percent is the total ad valorem rate, not an amount stacked on top of the standard MFN duty. As of October 6, 2026, the code is active for 17 product rules with no announced end date.

The links in this article go to the primary documents: the Federal Register notices, CBP guidance, and the official tariff schedule itself. Read the source.

What 9903.94.51 covers and which program created it

The United States imposed Section 232 tariffs on imported automobiles and light trucks under the national-security authority of the trade laws. The EU-specific deal rate was implemented through the legal authority cited in Federal Register document FR 2025-18660 and CBP CSMS message 66336270. The code migrated into CBP's live tariff system on July 24, 2026 at 18:00.

U.S. note 33(n) of Chapter 99 defines the heading and is the controlling statutory text. Importers should verify the current note text in the official Harmonized Tariff Schedule at hts.usitc.gov.

Affected products and HTS subheadings

As of October 6, 2026, 17 product rules are in force under 9903.94.51. One rule, covering heading 8703 broadly, ran from August 1, 2025 through August 1, 2025 and is no longer active. The 17 active rules cover the following subheadings, all effective August 1, 2025 onward with no announced end date:

Passenger vehicles (heading 8703)

8703.22.01 - Spark-ignition internal-combustion, cylinder capacity over 1,000 cc but not over 1,500 cc
8703.23.01 - Spark-ignition internal-combustion, cylinder capacity over 1,500 cc but not over 3,000 cc
8703.24.01 - Spark-ignition internal-combustion, cylinder capacity over 3,000 cc
8703.31.01 - Compression-ignition internal-combustion, cylinder capacity not over 1,500 cc
8703.32.01 - Compression-ignition internal-combustion, cylinder capacity over 1,500 cc but not over 2,500 cc
8703.33.01 - Compression-ignition internal-combustion, cylinder capacity over 2,500 cc
8703.40.00 - Vehicles with both spark-ignition and electric motor
8703.50.00 - Vehicles with both compression-ignition and electric motor
8703.60.00 - Vehicles with electric motor only, external charge
8703.70.00 - Other vehicles with electric motor only
8703.80.00 - Other vehicles with electric motor
8703.90.01 - Other passenger vehicles

Light trucks (heading 8704)

8704.21 - Motor vehicles for goods transport, spark-ignition, GVW not over 5 tonnes
8704.31 - Motor vehicles for goods transport, compression-ignition, GVW not over 5 tonnes
8704.41 - Motor vehicles for goods transport, electric, GVW not over 5 tonnes
8704.51 - Motor vehicles for goods transport, other, GVW not over 5 tonnes
8704.60 - Motor vehicles for goods transport, other electric

If your vehicle subheading is not on this list, 9903.94.51 does not apply. Confirm coverage against the live schedule at hts.usitc.gov before filing.

How the combined 15% rate works, and how it differs from an additive duty

This is the most common source of entry errors for EU vehicle imports under the Autos 232 program. The rate under 9903.94.51 is a combined rate, not an additive rate.

Combined rate: The total duty owed on a covered vehicle is 15 percent of customs value, period. The Section 232 component is calculated as 15 percent minus the applicable column 1 rate. The two figures together equal 15 percent.
Not additive: You do not pay 15 percent on top of the MFN column 1 rate. If, for example, the column 1 rate for a subheading is 2.5 percent, the 232 increment added at entry is 12.5 percent, bringing the combined total to 15 percent.

This combined structure is specific to EU and other deal-country codes under this program. Other Section 232 auto codes for non-deal countries work differently. For comparison, see the Japan deal-rate counterpart at 9903.94.41 Explained: Japan Autos 232 Combined 15% Rate.

Because entry-date classification governs which rate applies, any change in the effective window matters. See Why Does the Entry Date Change the Duty on a U.S. Import? for a full explanation of how CBP determines the applicable rate.

Country scope: all 27 EU member states

9903.94.51 applies to vehicles originating in the following countries, which constitute the 27 European Union member states:

Austria (AT), Belgium (BE), Bulgaria (BG), Croatia (HR), Cyprus (CY), Czech Republic (CZ), Denmark (DK), Estonia (EE), Finland (FI), France (FR), Germany (DE), Greece (GR), Hungary (HU), Ireland (IE), Italy (IT), Latvia (LV), Lithuania (LT), Luxembourg (LU), Malta (MT), Netherlands (NL), Poland (PL), Portugal (PT), Romania (RO), Slovakia (SK), Slovenia (SI), Spain (ES), Sweden (SE).

Origin is determined by standard CBP country-of-origin rules. Assembly or finishing in a non-EU country may affect which code applies. Confirm origin determinations with your broker or a licensed customs attorney if the manufacturing footprint spans multiple countries.

Vehicles from countries not on this list, including the United Kingdom, Japan, and South Korea, fall under separate Chapter 99 codes for this program. The UK has its own deal-rate code; confirm the correct code at hts.usitc.gov.

How 9903.94.51 appears on a CBP entry

Chapter 99 codes are overlay codes. They do not replace the underlying tariff classification; they ride alongside it on the same entry line or as an additional line.

Line 1: The chapter 1-97 vehicle subheading (for example, 8703.23.01), with the column 1 duty rate and the customs value.
Line 2 (or additional code): 9903.94.51, with the Section 232 increment (15 percent minus column 1) applied to the same customs value.

CBP's automated system requires both codes to process the entry correctly. CSMS 66336270 contains CBP's specific filing instructions; brokers should review that message directly at cbp.gov.

The code migrated into CBP systems on July 24, 2026 at 18:00. Entries filed before that migration date for goods with an entry date of August 1, 2025 or later may require post-summary correction or protest review depending on how they were initially processed. Confirm the status of any pre-migration entries with your broker and check liquidation deadlines. For background on tracking those deadlines, see How CustomsGenius Tracks Liquidation and Protest Deadlines.

For general orientation on how Chapter 99 overlay codes work across the 2026 tariff schedule, see our 2026 tariff code overview.

What importers should do

Verify subheading coverage before each shipment. Confirm that your specific vehicle subheading appears in the 17 active product rules under note 33(n) and that the country of origin is one of the 27 EU member states listed above. Use the live schedule at hts.usitc.gov.
Calculate duty as a combined 15 percent total, not an additive stack. Instruct your broker and accounts-payable team that the combined rate is 15 percent of customs value. Do not add 15 percent on top of the column 1 rate; that will overstate the duty owed.
Review pre-migration entries for corrections. Because the code migrated on July 24, 2026 at 18:00, any entry with an August 1, 2025 or later entry date that was filed before migration may need a post-summary correction. Check liquidation status before deadlines pass.
Use the duty calculator for landed-cost modeling. Run scenario analysis at our duty calculator before contracting new EU vehicle purchases to reflect the 15 percent combined burden accurately.

Key references

Federal Register FR 2025-18660 - Legal authority establishing the EU Autos 232 deal rate
CBP CSMS 66336270 - CBP operational guidance and entry filing instructions for this code
Harmonized Tariff Schedule of the United States, hts.usitc.gov - Official current text of Chapter 99 note 33(n) and subheading 9903.94.51
U.S. Customs and Border Protection, cbp.gov - CBP guidance, CSMS messages, and entry processing resources
9903.94.41 Explained: Japan Autos 232 Combined 15% Rate - Parallel combined-rate code for Japan-origin vehicles
Why Does the Entry Date Change the Duty on a U.S. Import? - How entry date governs which Section 232 rate applies
How CustomsGenius Tracks Liquidation and Protest Deadlines - Managing correction windows for pre-migration entries

Working through tariffs on real entries? Try the free duty calculator, then see plans for the full toolkit.

About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.