Mobility & Advanced Technology

For organizations competing in fast‑moving sectors [e.g., electric mobility, battery, supply chain, electronics, aircraft, critical minerals], the difference between margin pressure and competitive advantage increasingly depends on making the “right” global supply chain decisions. 

But how to make the right decision. 

Tackling tariffs. They are no longer a simple calculation. The duty rates that ultimately applies to a product hinge on a matrix of legal determinations—classification, customs valuation, country of origin, and eligibility for trade preferences such as the USMCA. All of these require evaluation on top of the interweb of multiple tariff regimes (Section 232, Section 301, IEEPA, etc.) that quickly move the bottom-line number. 

We can help. The ArentFox Schiff Electric Mobility team is comprised of former senior attorneys at key US trade agencies, including the US Department of the Treasury and Customs and Border Protection. We work seamlessly with corporate divisions and executive offices towards the right tariff mitigation approach and add value to supply chain decisions. We understand that every company and every product is different, and so are the strategies for near and long-term advantage. 

This reality is especially acute for the sectors served by ArentFox Schiff’s Mobility & Advanced Technology Group:

• Electric mobility—from passenger EVs to commercial vehicles, micromobility, and charging infrastructure—this sector sits at the intersection of multiple tariff regimes and material origin rules. 
  The battery and energy supply chain – a rapidly evolving technology faced with distinct import regulations, for inputs such as cathode/anode materials, electrolytes, separators, cells, packs, and battery management systems.
• Electronics and power electronics – the power behind the power – enabling propulsion, autonomy, connectivity, and safety and built with semiconductors, sensors, inverters, converters, wiring harnesses, PCBs, and software‑rich modules. Each of these are subject to finely grained tariff lines that reward careful engineering and sourcing decisions.
• Aircraft and defense technologies face their own high‑stakes compliance environment, where national security agendas intersect with US tariff policy. The industry faces unique origin determination calculations, tariffs on specialty metals rules, and government procurement standards (including TAA and Buy American/Buy America requirements) intersecting with national security‑driven trade measures.
• Critical minerals and materials – where the promise of technological advances begins - are frequent targets of US tariff policy, content rules, and traceability expectations. These inputs include essential elements such as steel and aluminum, as well as lithium, nickel, cobalt, graphite, manganese, copper, and rare earths (including permanent magnets) that are central to modern mobility platforms. 

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Bridging the gap between policy and the bottom line. 

Every company and every product is different, and so are the strategies for achieving near- and long-term advantage. These include:

• Mitigating the effect of high US tariffs, such as  Section 301 China duties and Section 232 tariffs, as well as aluminum and steel duties, through the use of strategic tariff exclusion requests, product origin and classification analysis, and supply chain restructuring.
• Increasing the competitiveness of a company’s electric mobility products in the US market by an analysis of USMCA qualification status, i.e., the ArentFox Schiff USMCA Diagnostic.
• Determining a company’s product’s eligibility under the Trade Agreement Act (TAA) for federal government procurement opportunities.
• Taking advantage of duty-savings programs like duty drawback or special tariff classification (HTS Chapter 98).
• Adopting reasonable care and liability standards to your supply chain to mitigate the risk of onerous CBP and government agency enforcement actions.
• Contracting effectively within a company’s supply chain (suppliers and logistics service providers) for the movement of goods into the US.
• Contracting effectively with domestic partners for the distribution of electric mobility products and their components, including the siting of charging stations.

For Us, Smart In Your World Is Not Simply a Tagline

While many of these strategies may be familiar, the current risks facing the industry demand a strategic rethinking of a company’s approach to compliance, due diligence and “reasonable care”.

This is where our team at ArentFox Schiff comes in.

Areas of Focus

• USMCA automotive rules of origin
• US import rulings, regulations and enforcement risk mitigation
• US 301 tariffs on parts imported from China
• US 232 tariffs on certain steel and aluminum imports
• US IEEPA tariffs
• The Agreement on Trade in Civil Aircraft (Aircraft Agreement)
• NHTSA standards and proposed rulemaking
• International and domestic manufacturing and supply chain strategies