Ensuring a Trusted, Domestic Industrial Base is Vital to Military Readiness, Civil Emergency Response, and Infrastructure Resilience
WASHINGTON — The Coalition for a Prosperous America (CPA) today publicly released comments submitted to the Department of Commerce for its Section 232 National Security Investigation of the Domestic Trucking Sector. CPA’s submission documents how the domestic trucking sector underpins U.S. commerce, and that ensuring a domestic industrial base for producing these trucks is vital to military readiness and civil emergency response.
Read CPA’s full submission here.
The U.S. heavy-duty truck manufacturing base is increasingly concentrated among foreign-controlled original equipment manufacturers (OEMs), two of which have moved the bulk of their U.S.-market production to Mexico, where they enjoy duty free access to the U.S. market. Several companies still operate U.S. factories, but the majority of Class 8 trucks — a heavy-duty long-haul truck with a gross vehicle weight rating (GVWR) exceeding 33,001 pounds including its cargo — sold here are now made elsewhere.
CPA specifically documented a number of critical areas which need to be addressed including: national security risks and red flags; a present structure which introduces unacceptable procurement risk; cybersecurity risks from foreign-controlled truck platforms; tariff asymmetry and significant risk exposure for both domestic supply chains, as well as strategic capacity; market share and industrial footprint; and U.S.-built production vs. U.S. registrations.
“CPA is proud to be the leading voice for a domestic trucking sector in addressing this critical national security threat. America’s dependence on foreign-made parts, components, and assembly directly contributes to employment consequences for U.S. truck manufacturing that could be severe and irreversible,” said Jon Toomey, President of CPA. “U.S. heavy-duty truck manufacturing directly supports hundreds of thousands of jobs ranging from assembly, to supplier networks, to dealership operations, and logistics services. As foreign-built trucks displace U.S.-made vehicles, and as production shifts to Mexico, this skilled workforce is placed at immediate risk. This reliance jeopardizes transportation and infrastructure safety, undermines our national security, and weakens the broader U.S. economy.”
CPA advocates for both tariffs and quotas to protect and revive domestic production. They recommend targeted actions to reduce import dependency, particularly from adversarial nations, and incentives to expand domestic manufacturing. Specifically, U.S. government procurement policy should more carefully weigh supplier governance and ownership structures. Contracts involving sensitive military and emergency logistics functions should prioritize firms with clear U.S. governance and domestic production capabilities.
Additionally, federal procurement policies should evaluate the risk exposure of firms with substantial international joint ventures — especially in China — given the potential for foreign government influence over proprietary vehicle systems and data infrastructure. In addition to their foreign ownership, most of the major truck OEMs operating in the U.S. today maintain active joint ventures or substantial commercial ties with Chinese firms. As heavy-duty trucks become increasingly software-defined and connected to the internet, new national security threats — particularly in the cybersecurity space — have emerged. These risks are especially serious in platforms controlled or influenced by foreign adversaries such as China.
“China-linked parts and components are re-entering U.S. defense supply chains, and trucks built in Mexico, where enforcement of rules of origin and component sourcing is weaker, often include components of Chinese origin,” continued Toomey. “These parts would be restricted under direct import, but they enter the U.S. indirectly via Mexican-assembled vehicles. There is no firewall between commercial and defense business. The same Mack-branded platforms being supplied to the U.S. military are being produced by a corporation with growing production and governance exposure to both Mexico and China. That risk posed should raise significant national security red flags for this Administration, while simultaneously falling in line with their stated goal of reshoring American manufacturing.”
The United States’ ability to respond to crises — whether military, logistical, or civil — depends heavily on its capacity to produce and maintain medium- and heavy-duty trucks domestically. These are vehicles that are essential for troop mobilization, FEMA deployment, emergency fuel and food distribution, and critical infrastructure repair. Today, only one U.S.-headquartered company maintains a high volume of domestic production and ownership, and yet faces a significant competitive disadvantage due to current U.S. trade policy. Meanwhile, despite multiple companies participating in this industry, foreign-controlled OEMs now account for approximately 70% of Class 8 truck sales in the U.S. — a reversal from prior decades when American ownership was dominant.
In addition to tariff avoidance, and also significantly lower labor costs in Mexico, the cost differentials for truck assembly incentivize OEMs to offshore production — even when domestic capacity exists – simply to maintain margin competitiveness. These trends are not driven by a lack of U.S. capacity — as truck plants in Ohio, Pennsylvania, Texas, Virginia, and other states could be expanded with the right incentives or the necessary relief. The shift to Mexico is a choice, enabled by trade loopholes, wage differentials, and the erosion of tariff protections. The result is a growing reliance on Mexican labor to supply the U.S. truck market, at the direct expense of American workers and industrial reinvestment here at home.
Key Recommendations from CPA’s Comments:
- A temporary exclusion from tariffs for select components used to build trucks in the United States.
- Retroactive duty drawback on qualifying imports dating back to March 4, 2025.
- Affirmation in the Section 232 investigation that medium- and heavy-duty truck manufacturing is essential to national security.
- Consideration of a Section 232 tariff on fully assembled trucks imported from countries that benefit from trade distortions, including Mexico.
CPA advocates that Commerce use this Section 232 investigation to ensure that there are strong measures put in place to rebuild America’s domestic trucking sector, underpinning U.S. strategic mobility, and ending the dangerous overreliance on foreign sources that threaten our national security and sovereignty.
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