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�鶹ֱ�� Automotive Update

Holly Kane — Wed, 30 Sep 2026 18:07:08 +0000

Key Legal Insights from �鶹ֱ��’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

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

AUTOMOTIVE KEY DEVELOPMENTS

�鶹ֱ�� & Lardner partners Vanessa Miller and Alejandro Gómez Strozzi��were among the speakers at the��24^th International Congress of the Automotive Industry () held September 29–30, 2026 in Mexico City.
September 2026 U.S. new light-vehicle sales are expected to increase 2.2% year-over-year for a SAAR of 16.1 million units, according to a from JD Power and GlobalData. Third quarter 2026 new-vehicle sales are projected to decline 0.5% YOY.

Asian automakers are on track to collectively account for over 50% of U.S. new-vehicle sales for a second consecutive quarter in Q3 2026, supported by a of hybrid vehicles and passenger cars. The Detroit Three are to fall to a record-low 36% combined market share in Q3 2026, as they prioritize higher-margin SUVs and pickups over sales volume.

According to a new report from former “Car Wars” Bank of America analyst John Murphy, the are “the worst three-year new-product drought on record.” The shortfall of new models is to the ramifications of U.S. automakers’ abrupt pullback from EVs. Murphy also predicts that gas-electric hybrids for 34% of U.S. new-vehicle sales by 2030.

Global new-vehicle sales in 2026 are to drop 4.3% YOY to 88.3 million units, due to ongoing sales declines in China and market uncertainty stemming from conflict in the Middle East.
Chinese Tier 1 suppliers are a growing competitive threat to parts makers in a number of regions, according to from the CEO of Bosch North America.
Senators Bernie Moreno (R-OH) and Elissa Slotkin (D-MI) postponed a on legislation that would permanently ban Chinese vehicles from the American market to allow more time to secure the support of an additional senator.
Rising transportation costs are expected to impact “virtually all corners of the U.S. economy,” according to a report in . Prices are rising as conflict-zone diversions drive up ocean freight costs, record diesel prices trigger surcharges, and stricter Trump administration enforcement reduces the pool of truck drivers eligible for commercial licenses.

Under the issued by the National Highway Traffic Safety Administration on September 28 “substantially recalibrating” the Corporate Average Fuel Economy (CAFE) program, automakers are expected to achieve a light-duty fleet average of 34.5 miles per gallon by 2031. This compares to an average of 50.4 miles per gallon required by finalized under President Biden.

TRADE/TARIFFS

�鶹ֱ�� & Lardner LLP partner Gregory Husisian was highlighted in analyzing recent developments in enforcement under the Uyghur Forced Labor Prevention Act (UFLPA).
The fourth round of U.S.-Mexico trade discussions originally for the week of September 21 was postponed, and a new date has not been confirmed.
Mexican President Claudia Sheinbaum to the country’s customs law that could significantly increase scrutiny of declared values for imported goods. Sheinbaum submitted the proposed amendments to the Chamber of Deputies as part of the government’s economic package for 2027.��
Following last week’s summit between President Trump and Chinese leader Xi Jinping, the U.S. and China to extend their existing trade truce for two months, and a plan to lower tariffs on approximately $30 billion of “non-sensitive” imports from each country. The nations to meet twice more this year for continued discussions.
U.S. Customs and Border Protection (CBP) confirmed that Consolidated Administration and Processing of Entries (CAPE) Phase 3 on October 6, 2026. Phase 3 covers refunds of IEEPA duties on certain finally liquidated entries for importers that have filed protective actions at the Court of International Trade.
The reports the CBP has started purging importers of record who provided insufficient or inaccurate information, as part of a broader initiative to understand import supply chains.
The Office of the United States Trade Representative (USTR) is through October 29, 2026, for its annual report on significant foreign trade barriers affecting U.S. exports, services, and foreign direct investment. The USTR seeks input on barriers that include state-owned enterprises, anticompetitive practices, subsidies, duty evasion, circumvention, and transshipment.
President Trump to impose additional tariffs or trade restrictions against European countries over Canada’s planned associate EU membership, calling the move a “hostile act.” In addition, a recent presidential directed agencies to remove Canadian goods from government contracts, citing barriers to U.S. companies seeking access to the Canadian government market through a “Buy Canadian” policy.
President Trump signed a Russian sanctions bill () that grants the president new authority to levy tariffs on the top buyers of Russian crude and natural gas. The law also extends the Iran Sanctions Act of 1996 through 2031. The measure had received , even as certain lawmakers opposed it due to concerns the president could misuse the new tariff authority.
The U.S. Department of Commerce that a type of compacted graphite iron brake drum imported from China was developed to wrongfully evade duty orders on such products from the country.
China expressed opposition to the European Union’s request for a voluntary cap on Chinese hybrid vehicle sales at roughly 15% of the EU market, citing a violation of World Trade Organization rules.
The Trump administration is preparing tariffs on memory-chip imports to spur investment in future U.S. production. The tariffs would likely raise costs for American companies that depend on Asian suppliers, intensifying pressure from a global chip shortage driven by the AI buildout.
More than 200 importers, exporters and transportation groups the USTR to extend the suspension of Section 301 tariffs and fees on Chinese-linked ships before the current one-year suspension expires on November 9.

OEMs/SUPPLIERS

Ford F-150 production was halted for at the Dearborn Truck plant and the Kansas City assembly plant due to an unspecified supplier issue.
Honda is considering Ohio for the site of a new $2.5 billion U.S. plant that would produce hybrid vehicle models.
Hyundai to invest $500 million in its Alabama manufacturing operations to relocate Tucson hybrid production from South Korea to Montgomery, and expand production of engines and hybrid components.
MP Materials is on track to rare earth magnets from its new facility in Texas to GM by the end of this year, fulfilling a supply agreement the companies signed in 2021.
Sales of U.S.-made vehicles in Canada declined by nearly 20% in the compared to the same period last year.
Chinese automakers including and are reportedly searching Europe for production sites ahead of local content rules that could be implemented in the region next year. The European Commission’s proposed Industrial Accelerator Act would establish local-content and low-carbon requirements for products purchased through public procurement, public auctions, or subsidy programs. Chinese brands for a record 11.7% of new-car sales in Europe in August.
Mercedes is considering $911 million in labor cost cuts in Germany to prevent the potential closure of two plants.
Unifor and Stellantis over the automaker’s of the idled Brampton Assembly plant in Ontario to defense contractor Roshel. This follows of the collective agreement on September 20.
Toyota it could cost up to $6.4 billion annually across its group companies and certain suppliers to support factory modernization, logistics automation, and installation of 400,000 humanoid and non-humanoid robots beginning in 2028.
Boston Dynamics has its Robotics Metaplant Application Center at Hyundai Motor Group’s Georgia Metaplant, where it will train humanoid robots for manufacturing tasks. A Hyundai Motor subsidiary since July, Boston Dynamics will support Hyundai’s initial plan to deploy 25,000 Atlas robots across its global plants in the coming years.
On September 17, Lockheed Martin it had received the first delivery of mission-critical components produced by GM Defense for the PAC-3 Missile Segment Enhancement (MSE) interceptor missile. According to from Tomorrow’s Affairs, the initial delivery demonstrates that GM Defense can produce the required components to Lockheed’s specifications, and the next series will help to indicate the volume GM can consistently ship each month.

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

Recent from PwC demonstrated that artificial intelligence investment patterns differ sharply between OEMs and suppliers. Suppliers, representing roughly 20% of AI investment, pursue a focused approach with programs concentrated on “modular, component-level innovations such as perception sensors for ADAS, AI-enabled control units, and AI-enabled manufacturing tools that integrate with OEM systems.”��OEMs are deploying approximately 75% of automotive AI capital in a wide range of areas that include large-scale AI training infrastructure, fleet-wide data platforms, autonomous driving, software-defined vehicles, supply chain, vehicle development, and enterprise functions.
Self-driving technology company Aurora Innovation expects to have more than 30,000 autonomous trucks on the road by the end of 2030, according to updates during its .
Chinese autonomous-driving software developer Momenta with Dongfeng Stellantis Automotive Technology (Wuhan) Co., Ltd. to develop advanced driver-assistance technology for new Peugeot and Jeep models in markets that include China and Europe.

MARKET TRENDS AND REGULATORY

reports a growing number of automakers are adopting “minimum advertising pricing” rules for dealerships, as more consumers express a preference to avoid haggling and amid greater scrutiny from the Federal Trade Commission on dealerships’ advertising tactics.
After the U.S. House of Representatives passed the , Senate Commerce Committee Chairman Ted Cruz (R-Texas) and Sen. Edward J. Markey (D-Mass.) the Senate to advance the measure, which would require automakers to install AM radio tuners in new vehicles.
Deutsche Bank copper prices could increase by 50% from current levels to reach $10 a pound by the second quarter of 2027, amid historic stockpiling by the U.S. and China.

HYBRID AND ELECTRIC VEHICLES

Tesla in a 2,500-truck battery-electric Class 8 order from a new shipper coalition, ZET SCALE, that will deploy the trucks across ten freight hubs over the next few years.
California Governor Gavin Newsom requiring manufacturers to provide suggested retail prices for incentive-eligible, all-electric medium- and heavy-duty trucks by January 1, 2027.
Nissan for hybrids to be its “primary powertrain” in North America by 2030.
Although Canada limits Chinese EV imports, Chinese-made batteries, motors, and other components reportedly continue to enter the market in —and can represent up to half of a vehicle’s value.
Michigan reduced its incentive package for battery maker Our Next Energy after the company lowered hiring targets and shifted its focus from EVs to defense and rail customers, according to a report in .
��󾱲Բ�’s Geely new EV charging technology that can recharge a battery from 10% to nearly full in under five minutes. The technology uses an AI model co-developed with StepFun to predict battery temperatures and adjust charging power.
According to from the European Automobile Manufacturers’ Association (ACEA) released on September 24, hybrid-electric models accounted for 36.6% of the total EU market in the first eight months of 2026, while battery-electric vehicles (BEVs) represented 21.7% and plug-in-hybrid electric vehicles (PHEVs) were 10% of the market.

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Federal Court Enforces Forum-Selection Clause in Dealer Agreement

Taylor Rourke — Wed, 30 Sep 2026 15:58:15 +0000

Background Facts

For nearly a decade, G.W. Van Keppel Company served as the exclusive dealer for Cemen Tech, Inc. — an Iowa-based manufacturer of concrete trucks and mixing equipment — across Oklahoma and several other states. Their written dealer agreement included a mandatory forum-selection clause requiring all disputes to be resolved in Iowa courts. When Cemen Tech terminated the agreement in January 2026, Van Keppel filed suit in federal court in Oklahoma, alleging violations of the Oklahoma Fair Practices Act (OFPA), the Kansas Outdoor Power Equipment Dealership Act, and the Missouri Merchandising Practices Act. Cemen Tech moved to transfer the case to the Southern District of Iowa.

Legal Holding

The Court enforced the forum-selection clause and transferred the case to Iowa. Van Keppel’s central argument was that the clause violated Oklahoma public policy as expressed in the OFPA. The Court, instead, found that the OFPA actually permits dealers to sue suppliers in “a court of competent jurisdiction” without geographic restriction—unlike provisions limiting other plaintiffs to Oklahoma courts. In the Court’s view, a dealer who agrees to a forum-selection clause is simply exercising that statutory venue choice in advance.

The Court also distinguished Alabama’s Heavy Equipment Dealers Act (AHEDA), which the Alabama Supreme Court in Cowin Equipment Co. v. Terex USA found expressed a strong public policy against outbound forum-selection clauses. The key differences: the AHEDA lets aggrieved persons sue in Alabama “[n]otwithstanding the terms, provisions, or conditions of any dealer agreement” and prohibits suppliers from requiring dealers to sign prospective releases of statutory obligations. These are provisions the OFPA simply does not contain. The Court concluded that the AHEDA “provides more unequivocal protections than the OFPA” and, unlike the OFPA, does not permit dealers to pursue claims in any competent jurisdiction — so the two statutes reflect fundamentally different public policies. Because the clause was valid, the court applied Atlantic Marine and held that Van Keppel’s private convenience concerns could not overcome the bargained-for forum.

Lessons Learned

This decision is good news if you include forum-selection clauses in your dealer or distribution agreements. Here are the key takeaways:

Your clause likely controls. Under Atlantic Marine, a valid forum-selection clause is effectively outcome-determinative on a transfer motion — the dealer must show “unusual” circumstances to avoid it.
State dealer-protection statutes are not all the same. There are sharp textual distinctions between Oklahoma’s OFPA — which gives dealers venue flexibility — and Alabama’s AHEDA, which mandates an in-state forum and bars contractual workarounds. The enforceability of your forum-selection clause may turn on the specific language of each state’s dealer-protection statute, so review them carefully wherever your dealers operate.
Draft with precision. The clause here survived despite a typographical error naming two different Iowa counties — but don’t count on every court being as forgiving. Clean, consistent drafting eliminates one more line of attack.

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�鶹ֱ�� Automotive Update

Holly Kane — Wed, 16 Sep 2026 18:57:35 +0000

Key Legal Insights from �鶹ֱ��’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

Automotive Key developments

Stellantis is working with its suppliers to assess the cost of moving certain pickup truck model production to Michigan from Mexico, according to a report in .

The Alliance for Automotive Innovation has Congress to enact a permanent ban on the “sale, import and manufacture of Chinese connected vehicles, hardware and software” by the end of the year.

President Trump again openness to Chinese automakers building vehicles in the U.S. if they hire American workers, while reaffirming his intent to block vehicle imports from China.

Average U.S. diesel prices are at a record high of $6.31 a gallon , representing a 70% increase from the same period last year. National average gasoline prices are approximately 36% higher than one year ago. U.S. consumers have paid over $100 billion more for gasoline and diesel during the Iran war than they would have absent the conflict, according to the at Brown University.

Goldman Sachs recently oil prices could surpass $120 a barrel if shipping instability persists in the Middle East. This comes as American oil executives of heightened price and supply risks, citing depleted commercial fuel inventories and historically low strategic crude reserves.

TRADE/TARIFFS

�鶹ֱ�� & Lardner provided five best practices to help manufacturers prepare for tariff volatility.
�鶹ֱ�� & Lardner attorneys Gregory Husisian, Kate Wegrzyn, and Lindsey Zirkle were featured in International Trade Today for their insights at �鶹ֱ��’s 2026 International Trade & Supply Chain Webinar Blitz. Topics included tariff refund disputes and customs enforcement changes.
�鶹ֱ�� & Lardner provided an overview for multinationals pertaining to securing IEEPA tariff refunds for “finally liquidated” entries, defined as “entries that are more than 80 days beyond liquidation and therefore fall outside Consolidated Administration and Processing of Entries (CAPE) Phase 1.”
�鶹ֱ�� & Lardner assessed the implications of a recent Department of Justice memo outlining the National Fraud Enforcement Division’s key priorities for fraud investigations and prosecutions.
In response to Canadian counter-tariffs on certain U.S. goods , President Trump of certain Canadian goods including later this month. President Trump also the scope of some of the existing 50% tariffs imposed on Canada under Section 338 of the Tariff Act of 1930, and added certain Canadian aluminum and other metal products to the of items subject to the 50% duties.
Certain auto industry analysts that escalating U.S.-Canada trade tensions could derail the regional alignment needed to curb Chinese automakers’ expansion in North America.
The United States and Mexico hope to reach a bilateral trade agreement before the U.S. midterm elections in November, according to multiple unnamed sources in .
Secretary of Commerce Howard Lutnick the U.S. is taking steps to issue a broad tariff on semiconductors, while suggesting that companies that commit to U.S. manufacturing could be exempt. Lutnick did not provide the timing for the new tariffs.
The Office of the U.S. Trade Representative (USTR) received a letter from the United Steelworkers union an investigation into imported tires under Section 201 of the Trade Act. The USW’s letter notes that as U.S. tire production declines, countries including China have been rapidly expanding their capacity and targeting the U.S. market.

OEMs/SUPPLIERS

Ford CEO Jim Farley rejected Transportation Secretary Sean Duffy’s claims that the automaker is becoming overly reliant on Chinese companies, including through its CATL technology licensing agreement at a Ford-owned battery plant in Marshall, Michigan. Ford also recently with Geely in Spain and is its longstanding partnership with Jiangling Motors in China to boost exports and international sales.
Chinese automakers’ sales outside of China for 38% of total retail sales in August 2026, up from 20% one year ago. New vehicle sales within China are down by more than 20% for 2026 year-to-date.
Hyundai its local sourcing goal in North America, and now plans to source 80% of parts for vehicle manufacturing in the region from local suppliers by 2030.
Ford to invest $1 billion to establish a new paint shop at its Kentucky Truck Plant and modernize the facility. Construction is expected to begin later this year.
South Korea’s Hansae Mobility USA, a manufacturer of driveline systems and other vehicle components, will invest more than $93 million to with a new 400,000-square-foot facility in Chesterfield Township.
Volkswagen estimated its restructuring initiatives, including job cuts and potential plant closures, will cost up to €16 billion ($18.6 billion), according to a report in . The automaker plans to eliminate by 2030.
Stellantis that could lead to the sale of the Brampton Assembly Plant in Canada to armored vehicle manufacturer Roshel.

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

shared success stories from smaller suppliers that have utilized AI technologies to improve manufacturing quality and efficiency.
Hardware or operational constraints could suppliers’ and automakers’ plans to increase deployment of AI-enabled functions in vehicles.
Hyundai is its proprietary driver-assistance software launch by two years, to 2029, and will rely on Nvidia in the interim to speed deployment.
Ann Arbor, Michigan-based May Mobility plans to go public through a with a special purpose acquisition company in a deal valuing the autonomous ride-hailing company at approximately $1.4 billion.
Santa Clara, California-based PlusAI to go public in a SPAC deal valuing the ‌autonomous trucking software developer at approximately $800 million.
Ford is AI-enabled sound detection to identify defects before vehicles are shipped to dealers.

MARKET TRENDS AND REGULATORY

The National Highway Traffic Safety Administration (NHTSA) has proposed for testing certain vehicle safety features that support the New Car Assessment Program.
The Federal Trade Commission for dealerships to comply with price advertising rules after previously dealers about deceptive pricing practices.
Infotainment accounts for 25% of total vehicle complaints and it was the only category to decline year-over-year, according to the .
In August, the average price of global air freight shipments was , up 24% from the same period last year.
The Consultative Shipping Group, an informal alliance of the 18 biggest shipping countries, warned that global conflicts, trade restrictions, and chokepoints were raising costs and spreading uncertainty across global supply chains, according to a report by . The group, which doesn’t normally issue statements, indicated that changes eroding freedom of navigation were leading to the emergence of “two parallel trade systems,” with one following the rules and another “operating by evading sanctions, attacking vessels and forcing ships to reroute from key waterways.”
The reports Mexico–U.S. trucking rates are rising as tighter U.S. scrutiny of foreign drivers collides with a shrinking pool of Mexican drivers holding B1 visas.

HYBRID AND ELECTRIC VEHICLES

��󾱲Բ�’s new Five-Year Plan establishes a for 70% of new vehicle sales to be electric or hybrid by 2030, and for electric models to account for 40% of new commercial vehicle sales over the same period. Over half of the new car sales in China last year were new energy vehicles.
Ford, Hyundai, and Stellantis to debut extended-range EVs (EREVs) in the U.S. beginning in late 2026, which are plug-in vehicles featuring a gas-powered generator to charge the battery.
Tesla, LG Energy, Ford, and GM are among the companies that are utilizing EV battery production capabilities to from energy storage systems that support AI data centers.
Honda an undisclosed amount in Minnesota-based Niron Magnetics, a developer of rare earth-free magnets for a variety of applications including electrified vehicle powertrains. The majority of electric propulsion motors require permanent magnets made from rare earth metals, which face the risk of supply constraints.
Google is with electric truck startup Nevoya and the Center for Green Market Activation to deploy 25 electric semi trucks along a key freight corridor in Texas.
provided an update on EV delays or cancelations announced in 2026.
Electric trucking startup Windrose Technology lost most of its Chinese staff amid funding shortfalls

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Maryland Amends Franchise Law — Changes Effective October 1, 2026

Taylor Rourke — Fri, 11 Sep 2026 20:06:04 +0000

Maryland has amended its Maryland Franchise Registration and Disclosure Law. The changes are effective October 1, 2026. Franchisors registered in Maryland or otherwise offering franchises subject to Maryland law should take immediate steps to ensure compliance.

Key Provisions

Extended Enforcement Authority. The period during which the Maryland Securities Commissioner may bring enforcement actions for violations of the franchise law increases from three years to five years after the violation occurs.

Expanded Franchisee Claims Period. The statute of limitations for private civil actions by franchisees changes from three years after the grant of the franchise to the earlier of (i) four years after the franchise is granted or (ii) two years after the franchised business opens to the public.

Jurisdictional Clarification. The private civil action provisions now apply only to franchisees who are Maryland residents or whose franchised business operates, or will operate, in the state.

Franchisee Association Rights. Franchisees now have a statutory right to join and participate in trade associations composed of franchisees of the same brand for any lawful purpose. Franchisors may not restrict or inhibit this right, and franchisees have a private right of action for violations.

Fast-Track Renewal Program Codified. The FDD Renewal Fast-Track Review Pilot Program, introduced during the 2026 renewal cycle, is now formally established by statute.

Filing and Compliance

Registered franchisors are not required to file an amendment or cease offering franchises solely to reflect these changes. However, beginning October 1, 2026, franchisors must use FDDs and franchise agreements that have been updated to comply with the amendments when offering or selling franchises. The Securities Division will review compliance at the franchisor’s next amendment or renewal filing.

Franchisors must include the following disclosure verbatim in the FDD, Maryland addendum, or other appropriate documents: “Any claims arising under the Maryland Franchise Registration and Disclosure Law must be brought by the earlier of: (i) four (4) years after the franchise is granted; or (ii) two (2) years after the date the franchise opened to the public.”.

Action Items

Franchisors should review and update their FDDs, franchise agreements, and Maryland addenda now to ensure that all materials used on or after October 1, 2026 comply with the amended statute.

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Not So Fast: Washington Appeals Court Reverses Dismissal of Case Against Building Maintenance and Janitorial Services Franchisor

Taylor Rourke — Fri, 04 Sep 2026 15:54:06 +0000

Background Facts

From 2006-2017, NMC Franchising, LLC sold franchises to individuals operating building-maintenance and janitorial businesses. Under NMC’s model, franchisees paid an initial fee to “access” a purchased monthly volume of revenue tied to client accounts that NMC secured. Franchisees were responsible for their own equipment, staffing, hours, taxes, and legal compliance.

In 2021, the State of Washington sued NMC and its parent company under the Consumer Protection Act (CPA) and the Franchise Investment Protection Act (FIPA), alleging 16 claims of unfair and deceptive practices. Among other things, the State alleged that NMC failed to disclose material facts to prospective franchisees, concealed how much it earned from customer accounts, charged excessive “office support” fees, forced franchisees to sign releases and convert to LLCs, and imposed unconscionable out-of-state arbitration clauses. The trial court granted NMC’s motion for summary judgment, dismissed all claims, and awarded NMC over $3 million in attorneys’ fees.

Trial Court Reversed

The Washington Court of Appeals reversed the trial court on virtually every point. It held that the trial court committed multiple errors of law, including: (1) improperly requiring a “public interest impact” showing that was already established as a matter of law; (2) creating an improper regulatory “safe harbor” by holding that conduct regulated by FIPA could not also violate the CPA; (3) wrongly applying common law fraud standards to CPA and FIPA claims; and (4) incorrectly narrowing FIPA’s disclosure provision to cover only “vendor kickbacks.” The Court remanded 15 of 16 claims for trial, finding genuine issues of material fact, and directed summary judgment in the State’s favor on NMC’s mandatory out-of-state arbitration clause, which was deemed unconscionable. The $3 million fee award was vacated.

Public Interest Impact Analysis

This portion of the holding is worthy of further discussion. Under Washington’s CPA, when the State brings a claim on behalf of injured residents, it must prove three elements: (1) an unfair or deceptive act or practice, (2) occurring in trade or commerce, and (3) a public interest impact. Because the State’s claims arose from services NMC provided — procuring client accounts for franchisees — the court applied the four-factor test from Hangman Ridge Training Stables, Inc. v. Safeco Title Insurance Co., 105 Wn.2d 778 (1986), which considers whether: (1) the acts were committed in the course of the defendant’s business, (2) the defendant advertised to the public, (3) the defendant actively solicited the plaintiff and others, and (4) the parties occupied unequal bargaining positions.

The trial court dismissed all the CPA claims on the grounds that the State had failed to establish the public interest impact element. The Court of Appeals reversed, holding the State had demonstrated a public interest impact as a matter of law. It found the first and fourth Hangman Ridge factors plainly supported the State’s position: NMC did not contest that its alleged acts occurred in the course of its business, and it conceded that the parties occupied unequal bargaining positions when franchisees entered their agreements. The Court further noted that NMC’s franchise system involved “multiple hundreds” of individual purchasers, demonstrating a likelihood that additional plaintiffs had been or would be injured in the same fashion. While NMC argued the second and third factors favored it because it did not advertise to or actively solicit the general public, the Court held that no single factor is dispositive and NMC failed to identify any specific contested fact that would create a triable issue. The Court also rejected the trial court’s requirement that the State prove NMC’s conduct affected a “substantial portion of the public,” holding that no binding authority imposed such a minimum threshold.

Lessons for Franchisors

This decision underscores that franchisor systems operating in Washington face broad exposure under both the CPA and FIPA. The court of appeals rejected the notion that compliance with franchise-specific statutes immunizes a franchisor from separate CPA liability. Franchisors should ensure robust pre-sale disclosures, transparent fee structures, and good-faith dealings with franchisees. Mandatory out-of-state arbitration clauses remain especially vulnerable to challenge, as the Court ruled such provisions unconscionable as a matter of law when imposed on franchisees of limited means.

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�鶹ֱ�� Automotive Update

Holly Kane — Thu, 03 Sep 2026 18:42:08 +0000

Key Legal Insights from �鶹ֱ��’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

AUTOMOTIVE KEY DEVELOPMENTS

U.S. new-vehicle sales are expected reach a SAAR of 16.8 million units in August, according to . Total vehicle sales in August are forecast to decline 5% year over year because by the Labor Day holiday falling into the August reporting month last year, as well as consumers that accelerated EV purchases ahead of the expiration of federal tax credits. Average monthly payments are expected to increase 3.7% YOY to $812, while interest rates are projected to drop six basis points to 6.55%.

�鶹ֱ�� & Lardner represented autonomous trucking developer Gatik in its $200 million Series D financing, as well as the company’s partnership with PepsiCo. Gatik’s model is built around one of the most commercially compelling applications of autonomy: high-frequency regional routes that connect distribution centers and stores.

Honda has asked suppliers to lower costs as it targets more than $9 billion in savings over the next four years to offset Chinese competition and EV-related losses.
U.S. diesel supplies are at a , according to data released August 26 by the Energy Information Administration, and this could contribute to rising fuel prices in the coming weeks. Nationwide average diesel prices are currently than one year ago.

Chinese regulators have of automakers, suppliers, and third-party testing labs amid that rapid vehicle development cycles in the nation could compromise safety. The inspections will address areas that include durability, production consistency, and driver-assistance and artificial intelligence features.

TRADE/TARIFFS

Auto industry leaders thus far largely view President Trump’s to impose 50% tariffs on autos and parts from Canada beginning in January 2027 as a negotiating tactic, according to commentary featured in . This follows Canadian on $20 billion worth of U.S. imports, including steel and aluminum, beginning September 8 in response to the Trump administration’s August 22 of 50% tariffs on certain Canadian imports under Section 338 of the Tariff Act of 1930 after the breakdown in trade talks.
Toyota and Honda to President Trump’s proposed 50% tariff on Canadian car imports, as they produce more than three-quarters of Canada’s vehicles.
In a recent interview with , U.S. Trade Representative Jamieson Greer indicated that trade talks with Canada remain suspended. Canadian officials see little chance of restarting trade negotiations with the Trump administration before the midterm elections, while cautioning the “situation remains fluid,” according to unnamed sources in .
Despite the collapse of U.S.-Canada trade talks, Mexican President Claudia Sheinbaum for a trade deal with President Trump as her chief negotiator, Economy Minister Marcelo Ebrard, pursues goals that include lowering U.S. tariffs on Mexican steel, aluminum, and automobiles.
U.S. Customs and Border Protection has the launch of the Consolidated Administration and Processing of Entries (CAPE) Phase 3 – originally set for August 20 – until further notice. Phase 3 covers refunds of IEEPA duties on finally liquidated entries for importers that have filed protective actions at the Court of International Trade, a category CBP has at roughly $11.4 billion. The status of CAPE Phases 1 and 2 are unaffected by this delay.
CBP ��ܱ��”�¯�� improve��visibility into the supply chains of goods imported into the U.S. The proposed effort is intended to “help CBP more effectively detect,��stop, and prevent illicit��imports��that evade U.S. customs and trade laws.”��Public comments must be received on or before December 1, 2026.
The Department of Commerce triple-digit tariffs on van-type trailers and subassemblies imported from China after finalizing investigations that determined they are being sold at unfair prices. The Commerce Department set countervailing duties of 134.75%, while trailers are facing an antidumping duty of 130.86%. The Commerce Department is also such trailers imported from Canada and Mexico, preliminarily finding that the goods from those countries are being sold at less than fair value.

OEMs/SUPPLIERS

reports Toyota is closing in on �Ҳ�’s sales lead in the U.S., as the American automaker prioritizes increasing profits while selling fewer vehicles.
Nissan and Honda have to jointly develop standardized electronic control units (ECUs) and software for certain next-generation software-defined vehicles (SDVs) beginning in fiscal year 2029.
Honda it may not build a new plant in North America if the United States-Mexico-Canada Agreement (USMCA) is not extended.
Unifor members at GM Canada a three-year collective bargaining agreement that will bring GMC Sierra heavy-duty pickup production to Oshawa Assembly and prevent the CAMI Assembly Plant from closing. Unifor began contract negotiations with Stellantis , amid concerns the automaker may sell the Brampton Assembly Plant.
In the , Chinese automakers sold more vehicles in Europe than they did during all of 2025. Chinese brands could collectively produce up to one million vehicles annually in Europe .

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

Einride Tesla Semis to its autonomous electric fleet over two years beginning in September, expanding its freight network across corridors in California, Texas, New Jersey, Illinois and Georgia.

MARKET TRENDS AND REGULATORY

The National Highway Traffic Safety Administration into nearly one million GM pickups and SUVs based on complaints about engine failures. NHTSA is also a separate investigation into �Ҳ�’s “eBoost” electronic braking system after complaints that failures may cause a loss of braking and steering assist, potentially affecting more than 1.2 million vehicles.
Consumer complaints to NHTSA about exploding or shattering sunroofs are on pace to . The issue affects all major automakers, but regulators have attributed it largely to road debris rather than safety defects.
The Department of Homeland Security and the Transportation Department are scrutiny of immigrant truck drivers, including by requesting nationwide licensing data to assess driver certifications. The push could further constrain trucking capacity across the U.S., putting upward pressure on freight pricing.
The transportation cost index in the August rose 3.1 percentage points from July, marking the fourth increase in five months and signaling continued upward pressure on freight transport costs.
including Xpeng, BYD and Chery Automobile are among the companies that have recently increased their investments into humanoid robot development, betting that AI advances will eventually enable humanoids to be capable of learning nearly any task.
China expects to build more than 100,000 humanoid robots this year, up from 20,000 in 2025. Analysis in reveals a “widening gap” between the Chinese government’s ambitions and humanoids’ capabilities, “resulting in a market where manufacturing capacity outpaces commercial demand, key players rely on subsidies and prices are falling.”

HYBRID AND ELECTRIC VEHICLES

Hybrid market share is on track to to 18.2% of U.S. new light-vehicle sales in August 2026, representing 35.5% YOY growth. U.S. battery EV market share is estimated at 7.2%.
Stellantis to develop electrified Jeep models with Dongfeng Motor Group, using its Chinese partner’s technology and manufacturing capabilities, marking the American brand’s return to Chinese production after a .

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�鶹ֱ�� Automotive Update

Holly Kane — Thu, 20 Aug 2026 20:58:08 +0000

Key Legal Insights from �鶹ֱ��’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

AUTOMOTIVE KEY DEVELOPMENTS

Mobility Global, a spin-off of S&P Global Mobility, U.S. new light-vehicle sales will reach 15.8 million units in 2026 and 15.6 million units in 2027, with “affordability remaining a key determinant of consumer purchase timing and powertrain choice.”
GM up to $4.5 billion worth of critical parts through a deal with inventory management firm Procura Auto Parts. GM will pay Procura interest and certain fees in advance to buy components from suppliers, with payment for the parts due when they are needed, or no later than July 31, 2029. The automaker did not disclose which parts it will target.
New light-vehicle inventory at the start of August was at 2.73 million units, representing a 75 days’ supply industrywide. This is similar to inventory levels at the same time last year.
Automotive assembly jobs increased in the last year, amid an overall decline in auto parts manufacturing jobs, according to an analysis of the latest Bureau of Labor Statistics jobs report in .
International Energy Agency shows global EV sales rose 35% in Q2 2026 from the prior quarter, supported by stronger demand in markets including Australia, Brazil, India, Korea, and Vietnam. With gasoline prices remaining elevated, the IEA expects EVs to account for 29% of global new-car sales in 2026, up from 25% last year. The report also highlights ��󾱲Բ�’s accelerating role in global EV supply, with Chinese EV exports up 120% in the first half of 2026 compared to the same period last year.

TRADE/TARIFFS

�鶹ֱ�� & Lardner LLP partner Gregory Husisian shared insights with��and the��on the recent surge in tariff refund litigation, ongoing uncertainty surrounding timelines, and how companies are navigating the financial impact of tariff repayments.
President Trump paused to impose 50% tariffs on certain Canadian imports ahead of the August 19 deadline, citing progress toward a trade deal that could on Canadian automobiles, steel, and aluminum.
During recent U.S.-Mexico-Canada Agreement (USMCA) negotiations, the Mexican government proposed applying tariffs only to the value of vehicle components produced outside North America, according to unnamed sources in . This is reported to be a counterproposal to the Trump administration’s goal to require in vehicles.
The U.S. Court of International Trade a Michigan-based automotive parts distributor, upholding the Trump administration’s elimination of the “de minimis” tariff exemption for low-value imports. The decision found that the International Emergency Economic Powers Act (IEEPA) authorized President Trump to revoke the duty-free exemption, even though the Supreme Court has ruled the act does not authorize the president to impose tariffs.
U.S. Customs and Border Protection will implement enhanced enforcement procedures to verify the accuracy of importer of record information submitted on CBP Form 5106. According to ��’s , importers of record and customs brokers must ensure that Form 5106 information is complete and accurate by September 18, 2026, or risk potential penalties and disruption of importing activity.
The Trump administration is developing an AI-enabled “Detective Border” tool to improve ��’s ability to distinguish legitimate nearshoring and foreign investment from illegal pass-through trade, according to a focused on tariff evasion via transshipment. The administration has identified more than 40 trading partners – including Mexico, Canada, the European Union, India, Japan, and South Korea – ��as having elevated illegal transshipment risk.
The Trump administration granted the Commerce Department��to ban exports of recoverable critical minerals under the Defense Production Act. The Commerce Department subsequently that would require 100% of U.S. sales of black mass and scrap tungsten to be allocated to U.S. persons as of August 27, 2026, “unless an adjustment or exception is obtained in advance.” The agency defines “black mass” as shredded lithium-ion battery scrap that contains cathode material (such as lithium, cobalt, nickel and manganese), anode material (graphite and silicon), or other residual battery cell materials.

OEMs/SUPPLIERS

Ford to move production of certain Lincoln models from China to the U.S. beginning in 2030.
Stellantis that the next-generation Jeep Cherokee SUV will be built on the automaker’s new STLA One platform at its Belvidere, Illinois, assembly plant.
Honda has outsourced development of a new, multi-powertrain vehicle platform for undisclosed markets to India-headquartered Tata Technologies Ltd.
Geely’s External Collaboration Research Institute offers turnkey vehicle development, technology licensing, and engineering services to customers that include major . Launched in 2021, it currently has in progress with a��dozen clients.
Nexteer Automotive a new High Mount Direct Drive Steer-by-Wire Hand-Wheel Actuator (HMDD) intended to give automakers greater cockpit design freedom for software-defined vehicles.
Daimler Truck North America plans to establish a new U.S. manufacturing facility that will begin production in 2029. DTNA is evaluating multiple sites, and it expects construction to start later this year.
GM ��350 employees at two Lansing plants��as a part of a previously announced $1.25 billion investment for Cadillac sedan production.

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

The relatively short support cycles of smartphones and computers have raised questions about how software-dependent vehicles will age, according to a report by . Sam Fiorani, senior vice president of vehicle forecasting for AutoForecastSolutions, stated, “We honestly don’t know how long these vehicles will last. We’re already seeing problems with hardware not being able to deal with new software.”
provided an update on the projected market growth of over-the-air (OTA) updates.
provided an overview of automakers’ strategies to deploy artificial intelligence assistants in vehicles. Most recently, Ford announced it is its in-vehicle AI-powered assistant to eight million more eligible vehicles, following an initial launch that started earlier this year.
Tokyo-headquartered autonomous-driving software developer Turing to establish a U.S. office within the next year that will initially focus on research and development.

MARKET TRENDS AND REGULATORY

Automakers have over 20 million vehicles due to faulty backup cameras since the U.S. mandated the safety system eight years ago. JD Power indicates that the camera systems have been among the top 10 most-problematic vehicle features every year since 2022. Most recently, Stellantis announced it nearly a million vehicles – mostly Chrysler, Dodge and Jeep models in the U.S. – due to potentially faulty rearview cameras.
A federal judge warned that allowing the U.S. Environmental Protection Agency to submit California emissions waivers for congressional review more than a decade after they were granted could have far-reaching consequences for oversight of agency rulemaking, reported.
The California Energy Commission new rules that will phase out the sale of replacement tires that do not meet certain energy efficiency standards beginning in 2029.
Mexican production of heavy-duty commercial vehicles by more than 50% year-over-year in July, with truck and bus exports rising 67% YOY.

HYBRID AND ELECTRIC VEHICLES

Tesla exhausted its share of California’s MyFirstEV rebate program within five days. The offers $3,500 rebates to first-time buyers of new EVs, and it is funded equally by the state and automakers.
LG Energy Solution provided an on plans to produce batteries for energy storage systems and EVs at a Lansing, Michigan factory that was once intended to be a joint venture with GM.
Samsung SDI �Ҳ�’s 49.99% stake in��a planned $3.5 billion EV battery joint venture plant in Indiana. �Ҳ�’s decision to sell its stake in the SynergyCells battery plant��follows similar actions by Ford and Stellantis to dissolve battery JVs in North America in response to market conditions.
Ford its upcoming electric pickup, Fathom, will have a starting price of less than $30,000 and it will be available for preorders in early 2027. This will represent the first vehicle to be built using ��ǰ��’s “Universal Electric Vehicle” platform.
Specialty EV upfitter Grounded it closed a $5 million seed round��and opened a new 50,000-square-foot manufacturing facility in Detroit.
Boston-headquartered Cabot Corp. to establish a $50 million battery materials plant in Wayne County, Michigan.��
Customer satisfaction with DC fast chargers rose 12 points to 666 (on a 1,000-point scale), while satisfaction with public Level 2 chargers declined 12 points to 595 from the same period a year ago, according to the . The study also notes that “satisfaction is highest among DC fast chargers located at hotels (692), gas stations/convenience stores (689) and restaurants (688), while chargers located at dealerships (570) and stand-alone parking lots/garages (606) are among the least satisfying experiences for owners.”

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Claims Brought by Franchisor of Co-Working Concept Survive (Mostly): Key Takeaways from RGN-USF v. Megatron Workspaces

Taylor Rourke — Mon, 17 Aug 2026 16:12:58 +0000

In RGN-USF, LLC v. Megatron Workspaces of Michigan, LLC, No. 2:25-cv-10967 (E.D. Mich. May 29, 2026), a federal court’s ruling on a motion to dismiss largely sided with the Regus brand franchisor in a dispute over terminated co-working space franchises in Southeast Michigan.

What happened. RGN-USF (the U.S. sublicensor of the Regus brand) entered a multi-unit development agreement and four separate franchise agreements with entities controlled by a individual named John Schmidt to open and operate Regus co-working offices in the Detroit area. When the franchisees allegedly failed to meet various obligations — including obtaining operating certificates, remitting fees, and engaging in competitive conduct — RGN sent default notices in October 2024 and terminated the agreements in November 2024. The defendants continued using the Regus brand. RGN then sued for breach of contract, trademark infringement, specific performance, and unjust enrichment.

Motion to Dismiss. The former franchisee defendants moved to dismiss on five grounds. The Court rejected four of them and granted only one:

Mediation condition precedent: The Court found that the development agreement’s mediation requirement was a precondition to arbitration, to not filing suit in federal court. Because neither party was seeking arbitration, there was no obligation to mediate.
Notice: The Court held the complaint gave each defendant fair notice of the claims against it, despite incorporating prior allegations into each count.
Improper termination: This was the heart of the dispute — and where Michigan franchise law plays a central role. Under Mich. Comp. Laws § 445.1527(c), a franchisor cannot terminate a franchise before its term expires without “good cause.” The statute defines good cause to include a franchisee’s failure to comply with any lawful provision of the franchise agreement, provided the franchisor gives written notice and a “reasonable opportunity” to cure — which “in no event need be more than 30 days.” In other words, the statute sets a ceiling, not a floor: franchisors must give at least some reasonable cure period, but 30 days is always enough.

The Court found that each franchise agreement provided independent grounds for termination — some allowing immediate termination (such as competitive conduct or dishonest behavior), others requiring only 7 days’ cure period (payment defaults) or 60 days (failure to obtain an operating certificate). RGN provided at least 30 days to cure in every instance, which satisfied § 445.1527(c). The defendants’ argument that they deserved 60 days to cure failed because it conflated all four franchisees into one and ignored the multiple, severable termination grounds — each of which independently justified termination on a shorter timeline.

Trademark infringement: Because the Court found that termination was adequately pled, the defendants’ defense that they were still franchisees collapsed.
Unjust enrichment (dismissed): The Court dismissed this claim because both sides acknowledged the existence of the underlying contracts, which forecloses equitable relief under Michigan law.

Bottom line. This case reinforces that franchisors who carefully document multiple, independent grounds for termination and provide notice exceeding statutory minimums put themselves in a strong position to prosecute enforcement actions — even at the earliest stages of litigation.

Want more? Explore our new LearningLab: On-Demand Hub and get insights anytime on topics that impact your business. Take a look:

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�鶹ֱ�� Automotive Update

Holly Kane — Wed, 05 Aug 2026 18:16:34 +0000

Key Legal Insights from �鶹ֱ��’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

AUTOMOTIVE KEY DEVELOPMENTS

Mobility Global, formerly S&P Global Mobility, 2026 U.S. auto sales will reach 15.82 million units, representing a decline of approximately 3% year-over-year from 2025. The analysis also predicts new light-vehicle sales in July “will maintain pace with the previous three months,”noting that “the market is settling rather than growing.”
provided preliminary estimates for July 2026 new light-vehicle sales.
Ford followed in 2026 full-year guidance, amid expectations for continued sales of higher-priced pickups and SUVs. ��ǰ��’s fell nearly 10% YOY amid recovery from a supplier fire, while EV-related charges drove a $1.3 billion net loss.
Toyota its annual earnings guidance after reporting a 76% YOY increase in net profit for the three months ended June 30, 2026.

Stellantis second-quarter 2026 earnings that missed analyst projections, despite posting a profit in North America for the second consecutive quarter. The automaker maintained its 2026 financial guidance.
Nissan a quarterly net profit of ¥3.8 billion (US$24M) for the three months ended June 30, 2026. The automaker maintained its annual earnings guidance for the fiscal year ending March 2027.
Chinese brands accounted for 17% of new vehicle sales in Mexico during the first half of 2026, up from 14% a year earlier, according to data from the Mexican Association of Automobile Distributors cited by . Sales rose to 137,525 in H1 2026 compared to 107,712 during the same period last year.

TRADE/TARIFFS

�鶹ֱ�� & Lardner partner Gregory Husisian garnered media coverage across multiple sources for his analysis of the Trump administration’s announcement of a 50% tariff on Canadian imports.
The U.S. Department of Commerce will request public comments regarding a proposal to include an additional 14 types of derivative products in its Section 232 tariffs on steel, aluminum and copper, according to a that is scheduled to post on August 6, 2026.
According to a from the��U.S. Department of Commerce, eligible domestic manufacturers of engines for automobiles and medium- and heavy-duty vehicles (MHDVs) can apply to receive tariff offsets for sectoral duties on imported parts starting July 29, 2026. This follows that established offsets for domestic automobile and MHDV manufacturers for certain imported parts.
Truck bed covers produced by certain Chinese manufacturers may be subject to triple-digit tariffs due to a in the Commerce Department’s countervailing duty (CVD) investigation. The Commerce Department expects to make its final CVD determination “on or around October 13, 2026.” The agency is also conducting antidumping duty investigations of truck bed covers from China.
In a July 28 to its “covered list,” the Federal Communications Commission banned imports of “advanced robotic devices” – defined as mobile robots, such as humanoids and quadrupeds – as well as connected power inverters, citing concerns for national security.

OEMs/SUPPLIERS

Chinese tooling and casting manufacturer��Huatai Mould $30 million to establish a new plant in Aguascalientes, Mexico. This will be the company’s first manufacturing facility in the Americas.
During a recent employee town hall, Ford CEO Jim Farley that Chinese automakers could enter the U.S. market within five to ten years, despite tariffs and trade barriers currently blocking them.
BMW to eliminate up to 8,000 white-collar jobs in Germany by the end of 2027 through a voluntary severance program, due in part to sales losses to Chinese competitors. This follows �մǱ��ɲ��’s that it may cut up to 100,000 jobs across its brands by 2030.
reported on the opportunities and challenges Ford and GM face as they pursue expansion in defense and grid-scale battery storage markets.

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

Certain AI-powered systems are to accelerate aging in automotive sensors and other electronic components, leading to vehicle security and operational risks. Unlike traditional automotive electronics which operate intermittently, AI is “always on,” contributing to the “gradual decline of hardware within automotive systems.” ��
Zoox from the National Highway Traffic Safety Administration to deploy up to 2,500 commercial robotaxis annually over the next two years. Amazon-owned Zoox has been offering free rides in parts of Las Vegas and San Francisco in a purpose-built autonomous vehicle that does not have pedals or a steering wheel.
Paccar’s CEO said the parent company of Kenworth and Peterbilt to remove human drivers from the autonomous trucks it is developing with partners.

MARKET TRENDS AND REGULATORY

Concerns are rising over diesel supplies and prices amid instability in the Middle East and the approach of the high-demand autumn season, according to a report in . The nationwide was $5.36 as of August 3, compared with $3.73 one year ago.
AI-powered recommendation algorithms are expected to in how consumers choose their next vehicle.

HYBRID AND ELECTRIC VEHICLES

According to from the California New Car Dealers Association, hybrid EVs reached a record 22.1% market share in the state, with 191,000 registrations in the first half of 2026. Battery EVs achieved a 15.9% market share, with slightly over 137,000 units sold in H1 2026. Total new vehicle sales in California declined 7.7% YOY, with 864,848 new light vehicles registered in the first six months of 2026 compared with 936,543 during the same period in 2025.
provided an update on the recent actions of big-box retailers in building out EV charging infrastructure across the U.S.
Rivian its full-year 2026 sales guidance to between 65,000 and 70,000 EVs.

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�鶹ֱ�� Automotive Update

Holly Kane — Wed, 29 Jul 2026 16:07:56 +0000

Key Legal Insights from �鶹ֱ��’s Automotive Team

Analysis by Julie Dautermann, Competitive Intelligence Analyst

AUTOMOTIVE KEY DEVELOPMENTS

The most recent article in �鶹ֱ�� & Lardner’s 2026 AI in Manufacturing & Supply Chain Series is AI Bills of Materials (AI-BOMs) and Model Provenance: Contracting for Cybersecurity in AI-Enabled Manufacturing Supply Chains. Subscribe to get updates about new articles in this series.
U.S. new light-vehicle sales in July 2026 are projected to reach a SAAR of 16.9 million units, representing an increase of 1.4% year-over-year, according to a from JD Power and GlobalData.
released its 2026 list of the top 100 global parts suppliers.
The U.S. Senate Commerce Committee to send the Connected Vehicle Security Act of 2026 () to the full Senate for consideration. Expanding on Commerce Department that restrict the sales of connected vehicles with software or hardware linked to China, the Senate proposal would prohibit the U.S. sale of connected vehicles by companies that are more than 15% owned by Chinese entities, such as . A remains under consideration in the House.

On July 24, 2026, the National Highway Traffic Safety Administration (NHTSA) issued a granting a petition to begin the rulemaking process for potential new car door safety requirements. If finalized, the requirements would mandate a “robust and obvious door egress system in all motor vehicles.”
Stellantis a supplier reward program that shares certain cost savings.

TRADE/TARIFFS

�鶹ֱ�� & Lardner provided updates for multinationals regarding the escalation of customs and tariff enforcement by the Department of Justice and the ramifications of President Trump’s Executive Order strengthening Customs enforcement.
�鶹ֱ�� & Lardner provided overviews of compliance best practices for tariff mitigation, and dubious tariff-saving “opportunities” for importers to avoid.
�鶹ֱ�� & Lardner assessed the key implications of the U.S. Customs and Border Protection’s .
On July 23, 2026, the Trump administration implemented tariffs of 10% to 12.5% under Section 301 of the Trade Act of 1974 on – including Canada, China, the European Union, and Mexico – for their “failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.” This follows the on July 24, 2026 of temporary global 10% tariffs imposed by President Trump under Section 122 of the Trade Act of 1974 after the U.S. Supreme Court invalidated IEEPA-based tariffs. Two small businesses filed a lawsuit with the Court of International Trade to challenge the legality of the forced labor tariffs.
President Trump utilized Section 338 of the 1930 Tariff Act to impose 50% tariffs on certain Canadian imports effective August 19, 2026, citing Canada’s discriminatory treatment of and other U.S. goods. The July 20 proclamation stated that counter-tariffs by Canada reduced U.S. auto exports to the nation by 22%, worth $5.6 billion, from April 2025 to March 2026. Prime Minister Mark Carney the need to accelerate trade negotiations with the U.S., while noting that Canada may pursue retaliatory levies if President Trump’s new tariffs are imposed in August.
During last week’s bilateral negotiations in Mexico City on the United States-Mexico-Canada Agreement (USMCA), the U.S. urged Mexico to consider imposing national security-related duties on certain Chinese-made goods, including steel and aluminum, according to unnamed sources cited by . U.S. Trade Representative (USTR) Jamieson Greer a fourth bilateral negotiating round with Mexico is planned for September 2026 in Washington, D.C.
USTR Jamieson Greer that he hopes to provide USMCA “options” by the end of 2026 to President Trump, while noting that certain issues such as rules of origin may take longer to resolve. Some of the USTR’s other priorities reducing the U.S. trade deficit with Mexico and measures to “incentivize supply chains to relocate” to the U.S.
reports that �ѱ�澱��’s expanding fleet of Chinese-made heavy trucks is heightening U.S. trade officials’ concerns about the impact on North American supply chains, and this topic could be addressed during bilateral USMCA-related negotiations. Nearly two dozen Chinese truck companies are estimated to be operating in Mexico.
, U.S. Customs and Border Protection will require importers of certain copper articles from non-U.S. countries of origin to report the primary country of smelt and cast. This guidance also states, “If the primary or secondary countries of smelt or cast are unknown, importers may report ‘OTH,’ or other.”
President Trump an incentive program under which companies that build, expand, or refurbish plants in the U.S. to produce primary aluminum would receive a reduced tariff rate for the metal they ship into the country from abroad. Companies with approved plans must commit to beginning construction by January 20, 2029, and submit reports to the Department of Commerce to “ensure compliance with domestic manufacturing requirements.”
The outcome of Section 301 manufacturing overcapacity investigations could have a significant impact on tariff rate increases, according to from S&P Global Market Intelligence. In a July 16 interview, USTR Jamieson Greer the administration’s Section 301 investigations into – including China, the EU, Korea, Vietnam, Taiwan, and Mexico – over manufacturing overcapacity are expected to conclude in the coming weeks. Greer did not provide a specific deadline.
The Trump administration is launching a new Section 301 investigation to apply additional tariffs to goods from the EU in response to the bloc’s fines on U.S. tech firms.

OEMs/SUPPLIERS

GM its 2026 full-year guidance for earnings before interest and taxes (EBIT) to as much as $16 billion, from a previous maximum of $15.5 billion, lower tariff costs and stronger margins on large vehicles. The automaker lowered net income to a maximum of $9.8 billion, from a previous target of $11.4 billion, due to EV-related charges.
Honda is plans to establish an eighth assembly plant in the U.S. The automaker’s key are in Ohio, Indiana and Alabama.
Ford was a Defense Department contract to develop three truck prototypes based on the F-Series super-duty pickups.
Daimler Truck a $40 million engineering hub in Portland, OR that will support the development of new generations of commercial trucks.
GM of a Magna plant in the proximity of its Orion Assembly factory in Oakland County, Michigan.
Honda its GAC Group joint venture in China through 2038, underscoring its commitment to compete with Chinese brands despite sales falling more than 50% from a 2020 peak of over 1.6 million units.
Unifor members a new three-year contract with Ford in Canada, securing 3% annual wage increases and a planned $500M investment in the Essex Engine Plant in Windsor, Ontario. Unifor to begin contract negotiations with GM on August 10, 2026.

AUTONOMOUS TECHNOLOGIES AND VEHICLE SOFTWARE

NHTSA plans to establish new safety standards for the operation of autonomous vehicles on U.S. roads before President Trump’s current term ends, according to in a recent interview. NHTSA intends to seek public comment from industry stakeholders to identify “behavioral competencies” for��AVs, with tests to measure performance.
Aurora Innovation plans to deploy its second generation Class 8 autonomous truck across its commercial network, which includes 10 throughout portions of Texas and Arizona.
China issuing robotaxi permits following a suspension in April 2026 due to a system outage that impacted over 100 self-driving vehicles in Wuhan.

MARKET TRENDS AND REGULATORY

Penske Automotive Group, Inc. (NYSE: PAG) it received and will review an unsolicited, preliminary and non-binding��take private proposal from Penske Corporation and Mitsui & Co., Ltd.
Automotive dealership M&A could , due to high franchise values for in-demand brands, as well as dealers motivated to sell because of market risks that include higher gas prices and vehicle affordability.
A Department of Justice investigation of UAW President Shawn Fain over could lead to an extension of federal oversight into the union beyond the January 2027 expiration date.

HYBRID AND ELECTRIC VEHICLES

Honda its only EV model in the U.S., the Prologue SUV, after the 2026 model year.
Foxconn plans to launch its Model C electric crossover in the U.S. market in partnership with an unnamed automaker.
Apple Maps will be integrated in ��ǰ��’s Universal Electric Vehicle platform .
Ford and ��󾱲Բ�’s Geely Automobile Holdings to co-develop and produce electrified models from both brands at ��ǰ��’s plant in Valencia, Spain.

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