Rail locomotives are not among the primary product categories targeted by Section 232 steel and aluminum tariffs as finished goods, though steel and aluminum components within them may be affected. Section 301 tariffs apply to goods of Chinese origin across a broad range of HTS chapters; importers sourcing battery-electric locomotives from China should assess Section 301 exposure. For locomotives from Germany, Spain, or Italy — the current leading suppliers — Section 301 does not apply, though standard MFN duties remain.

A battery-electric locomotive under 860120 uses stored electrical energy in onboard accumulators as its sole or primary motive power source. A diesel-electric locomotive under 860210 uses a diesel engine to generate electricity that drives electric traction motors — the diesel engine is the primary energy source. The presence or absence of an internal combustion engine as the prime mover is the key classification distinction.