Foley Automotive Update and the Latest Tariff Developments

Analysis by Julie Dautermann, Competitive Intelligence Analyst

Foley is here to help you through all aspects of rethinking your long-term business strategies, investments, partnerships, and technology. Contact the authors, your Foley relationship partner, or our Automotive Team to discuss and learn more.

Trump Administration and Tariff Policies

• Foley & Lardner’s International Trade and Supply Chain practices will present a comprehensive three-part “Tariff Blitz” webinar Wednesday, April 30, to cover the Trump administration tariffs and how to risk plan for them. Click HERE to register for the event.
• Foley & Lardner provided overviews for multinational companies regarding tariff strategies for sell-side contracts, and customs enforcement and False Claims Act (FCA) risks. Visit Foley & Lardner’s 100 Days and Beyond: A Presidential Transition Hub for more updates on policy analysis and the business implications of the Trump administration’s proposals across a range of areas.
• The U.S. Commerce Department initiated a Section 232 investigation into imports of medium- and heavy-duty trucks and parts, in a development that could serve as a basis for future tariffs. Public comments must be received by May 16, 2025.
• Bloomberg Law provided an explanation of the legal arguments in certain lawsuits that have been filed to challenge the Trump administration’s authority to impose tariffs. Most recently, a dozen states filed a lawsuit on April 23 over tariffs that were allegedly imposed without congressional authority. This follows suits over the legality of the tariffs filed by the New Civil Liberties Alliance, as well as California Governor Gavin Newsom and Attorney General Rob Bonta.
• U.S. House Representative Mike Lawler (R-NY) on April 25 stated Congress “will likely exert more authority” if the White House does not make “significant progress” in ongoing tariff negotiations in the coming weeks.
• President Trump warned he would veto a bipartisan Senate resolution led by Senator Ron Wyden (D-OR) and Senator Rand Paul (R-KY) that seeks to terminate the emergency declaration used as a basis for the president’s tariffs. A vote on the resolution could occur in the coming days.
• A proposal by the U.S. Trade Representative’s office could impose fees on ships built, owned or operated by Chinese entities that dock at U.S. ports. If the proposal is implemented, the fees would begin in six months based on the volume of goods carried, on a per-voyage basis. The proposal intends to restore the U.S. maritime industry and it follows an investigation ordered under the Biden administration into whether Chinese shipbuilding threatens national security.

Automotive Key Developments

• In an April 21 letter to the Trump administration, trade groups including MEMA, the Alliance for Automotive Innovation and the National Automobile Dealers Association outlined their concerns over the impact of import tariffs on automotive parts.
• The Wall Street Journal and Bloomberg reported the Trump administration could ease the impact of certain automotive tariffs in ways that include temporary partial reimbursements and preventing certain auto levies from stacking on other duties.  
• Automotive News provided an overview of the opportunities and barriers involved in major production shifts to underutilized U.S. auto plants. 
• Many auto suppliers are encountering challenges regarding the complexities of calculating U.S. import tariffs on steel and aluminum, according to a report in Automotive News.
• U.S. new light vehicles are projected to reach a SAAR of 17.9 million units in April 2025, representing a 10.5% year-over-year increase, according to a joint forecast from J.D. Power and GlobalData. The anticipated volume increase was attributed to consumers that have been accelerating purchase decisions due to expectation tariffs will lead to higher prices.
• The National Highway Traffic Safety Administration’s (NHTSA) new Automated Vehicle (AV) Framework will expand the Automated Vehicle Exemption Program (AVEP) to include domestically produced vehicles, and streamline rules in regard to the reporting of safety incidents. The framework also intends to facilitate efforts to modernize the Federal Motor Vehicle Safety Standards.
• The U.S. House could vote in the coming days on a measure to revoke a Biden-era Environmental Protection Agency waiver that allowed California to require increasing thresholds of zero-emissions vehicle sales between 2026 and 2035 in the state. U.S. House lawmakers previously introduced several Congressional Review Act resolutions that intend to repeal certain clean-vehicle waivers issued for California under the Biden administration. Senate Republicans are pursuing similar measures.

OEMs/Suppliers 

• Following a two-week shutdown to assess the impact of U.S. automotive import tariffs, Stellantis resumed production at its Windsor Assembly plant in Ontario, Sterling Stamping in Michigan and two transmission plants in Kokomo, Indiana. The automaker’s Jeep plant in Toluca, Mexico, is expected to remain idle through the end of April.
• Volvo Group is preparing to lay off up to 1,000 workers at its North American truck operations in the coming months, amid uncertainty over how President Trump’s tariff policies will affect demand.
• Ford halted exports to China of models that include the F-150 Raptor pickups and Bronco SUVs in response to the nation’s retaliatory import tariffs, according to a report in The Detroit News.
• Volkwagen and Nissan expect to avoid tariff-related increases on U.S. vehicle prices through the end of May, and Ford indicated its vehicles will have higher prices by July or sooner as a result of the levies.
• Hyundai intends to shift an unspecified volume of production of Tucson crossovers from Mexico to the U.S., and the automaker established a tariff task force to mitigate the effects of import duties on its finances.
• GM plans to remove certain equipment for EV drive system production at its Toledo Propulsion Systems plant to increase capacity for gas-powered truck transmissions.
• Toyota is reported to be considering a buyout of its parts supplier Toyota Industries, at an estimated valuation of $42 billion.
• Nissan expects to incur a net loss of up to $5.3 billion for the fiscal year ended March, due to impairments and restructuring expenses, as well as declining sales.
• Volkswagen’s Audi brand is reported to be close to a decision on whether to establish its first U.S. production site.
• GM’s executive vice president of global manufacturing resigned after just over a year in the role.

Market Trends and Regulatory

• The Federal Communications Commission on April 21 dismissed “as unnecessary the remaining cellular vehicle to everything (C-V2X) early transition waivers and confirm[ed] that each of the applicants may now seek a C-V2X authorization under the new rules.”
• The U.S. Department of Transportation (USDOT) and Federal Highway Administration (FHWA) repealed a Biden-era rule that would have required state transportation departments to measure and establish declining targets for carbon dioxide emissions on federally supported highways.
• The California New Car Dealers Association filed a lawsuit against Volkswagen Group and its affiliate Scout Motors over the brand’s plans to sell directly to consumers in violation of the state’s franchise laws.

Autonomous Technologies and Vehicle Software

• Alphabet reported its autonomous vehicle unit Waymo is booking over 250,000 paid robotaxi rides weekly in San Francisco, Los Angeles, Phoenix, and Austin.
• California’s Department of Motor Vehicles announced proposed regulations for the testing and deployment of self-driving heavy-duty vehicles on the state’s public roads.
• Volkswagen will partner with Uber Technologies to launch autonomous rides with the electric ID. Buzz van beginning in Los Angeles next year.
• Huawei Technologies Co. is a leading provider of intelligent driving software in China’s EV market, according to a report in Automotive News.

Electric Vehicles and Low-Emissions Technology

• Automotive News assessed the ramifications of the Trump administration’s tariffs and trade policies on the U.S. EV industry.
• BYD reported its first quarter 2025 revenue rose 36% YOY, supported by strong growth within China and overseas.
• China’s Contemporary Amperex Technology Co. (CATL) debuted a next-generation battery that can reach up to 520 kilometers (323 miles) of range from five minutes of charging time. Competitor BYD recently developed batteries for certain models in China that would enable up to 400 kilometers (249 miles) of range with five minutes of charge time.
• First quarter 2025 registrations of new battery-electric vehicles (BEVs) in the European Union increased 24% YOY for a 15% share of the total EU market. New EU registrations of hybrid-electric vehicles rose 21% YOY for a 35% share of the EU market. New car registrations across all powertrains declined 1.9% YOY in the region.