Aircraft parts imports have enjoyed duty-free status for many years. That changed with last year’s IEEPA tariffs, which initially imposed their tariff burden on aircraft parts imports (but were ultimately found to violate the law and struck down). These tariffs on aircraft parts violated the Agreement on Trade in Civil Aircraft (“ATCA”), which requires the duty-free entry of aircraft, engines, and their parts; so as the Administration’s tariff strategy became more sophisticated, new tariffs started to exclude aircraft parts from the new tariff burdens (consistent with America’s obligations under the ATCA).
In addition to prohibiting tariffs that would apply duties to aircraft parts imports, ATCA also prevents technical regulations that represent hidden restrictions on trade in civil aircraft parts. This has allowed aircraft parts to move relatively freely in global commerce.
While ATCA may prohibit he imposition of import duties on aircraft parts, the Administration continues to see tariffs as an important foreign policy tool for the President. IEEPA does not permit a violation of the ATCA, but other laws might permit aircraft parts tariffs. With this in mind, the Administration opened a Section 232 investigation into the state of aviation, last year. It was an open docket to which many aviation companies contributed, emphasizing the strengths created by globalization. Industry comments explained that as U.S. commercial aviation manufacturing become more deeply integrated with the global aerospace supply chains, the industry found that cross-border collaboration helped to drive innovations and improvements in aviation safety, performance and efficiency. ASA’s comment to the section 232 docket can be found here. The ASA comments emphasized:
- Current civil aviation import operations are largely separate from – and thus do not affect – the defense aircraft industry.
- The United States should focus on retaining highly specialized production and manufacturing skills rather than focusing on foreign imports of parts for which there is concurrent domestic capability.
- U.S. data shows a history of growth in exports of US manufactured aircraft and aircraft parts, and this doesn’t even include exports by U.S. based aircraft parts distributors; this growth suggests a growing positive balance of trade in the aviation industry that could be undermined by new tariffs on aviation that might lead to reciprocal foreign tariffs.
- The international and domestic legal regime implementing the Agreement on Trade of Civil Aircraft created a duty-free trade environment for civil aircraft and parts which has been a significant factor in the continued growth of the U.S.-based industry. Interference in this regime contradicts the international agreement in place as well as existing Acts of Congress.
On July 9, 2026, the White House released its response to the Department of Commerce’s Section 232 investigation into aircraft parts imports. The response focused on whether reliance on foreign-sourced components and materials poses a risk to U.S. national security, particularly in terms of supply chain resilience and domestic production capacity.
The published findings identify the administration’s issue: the U.S. aerospace sector remains dependent on foreign suppliers for key inputs, including high-spec engine components, avionics, and specialized materials. That dependency is a function of the industry’s efforts to create a global supply chain; in addition to creating more opportunities for innovation, the global supply chain also helped to promote the sale of aircraft and engines to foreign markets that were participating in that global supply chain.
Global dependency, according to Commerce, has been found to have the potential to become a liability. The Administration explained that it intends to protect and strengthen domestic manufacturing as a means to address this perceived liability.
The Commerce Department has not yet recommended tariffs. Nonetheless, the White House made it clear that tariffs on aircraft parts and other aviation inputs remain an option. The July 9 communication outlines the first step: a 180 period of directed negotiations with partner countries. The future outcome may include a more targeted, phased approach—potentially including selective tariffs, supply chain restrictions, and incentives to shift production back to the U.S. or to trusted partner countries.
Aircraft parts distributors in the United States should be concerned because potential measures could eventually include (1) new tariffs on aircraft parts imports and/or (2) newly negotiated impediments (such as impediments on countries that have not agreed to additional terms with the United States). Such new impediments could also be alleged to be technical barriers to trade, which might create further problems if the United States is accused of fomenting such barriers. New tariffs and new barriers create the potential for cost increases, sourcing disruptions, or new compliance requirements for United States companies that rely on foreign-sourced parts.