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The Office of the U.S. Trade Representative has issued another list of product exclusions on March 25th from Section 301 tariffs on goods from China. The product exclusions apply retroactively to July 6, 2018 and will remain in effect until one year from the date of the notice in the Federal Register. The first list of exclusions was issued on December 28, 2018 and will also remain in effect until one year from the date of the notice in the Federal Register.
The US Department of Homeland Security (DHS) implemented its Air Cargo Advanced Screening (ACAS) requirements for cargo entering the country following the completion of a pilot program. In the final ruling, DHS required air cargo data be submitted to Customs and Border Protection (CBP) before the aircraft is loaded, differing from previous requirements that the information be provided four hours before arrival. Previously a voluntary process (in which many airlines already participated), the program is now mandatory for airlines flying inbound to the United States. This is a necessary measure as the Department of Homeland Security (DHS) continues to raise the bar on aviation security worldwide.
The U.S. Mexico Canada Trade Agreement (USMCA) could require that changes to existing law are necessary to bring the U.S. into compliance with several obligations under the new trade agreement. Legislation to implement the USMCA could be introduced and considered by Congress within the next few months.
An announcement was made by the USTR that India (the biggest recipient of the Generalized System of Preferences) will be terminated from the program after the mandatory 60-day waiting period. Additionally, Turkey (which is the fifth-largest beneficiary of the program) is being terminated because its economy has developed sufficiently that it should no longer benefit from preferential market access.
In December, President Trump decided to postpone the additional China Section 301 tariff increase until March 2, 2019. The tariffs, which cover $200 billion in Chinese imports, were set to increase from 10% duty to 25% duty. It was announced on February 24th that the scheduled increase has now been delayed until further notice.
An announcement was issued by Customs and Border Protection that several reports regarding entries processed that are subject to the 201, 232, or 301 duties are now available. The reports are available for importers and customs brokers that have an active ACE account. To see a list of the available reports, please see the link for the CSMS message issued by CBP.
On December 28th in a Federal Register publication, USTR announced that determinations have been made to grant certain exclusion request. Shortly after the announcement, the federal government shutdown began, resulting in delays that impacted U.S. import and exports. The government has now reopened with funding through the end of February; however, instructions on how to process these exclusions and any refunds have not been provided by CBP. We will provide further information on the exclusions as it becomes available.
A statement was released from the White House regarding discussions that have taken place between high-ranking officials from the U.S. and China. Over two days, intense and productive negotiations over the economic relationship between the two countries were discussed and a wide range of issues were covered. The statement confirmed that the U.S. will be moving forward with the increase from 10% to 25% in additional tariffs on $200 billion worth of goods from China effective March 1.
In July 2018, the USTR (U.S. Trade Representative) imposed additional duties on goods from China with an annual trade value of approximately $34 billion as part of the action in the Section 301 investigations. The USTR also initiated an exclusion process in July 2018 and stakeholders have proceeded to submit requests for the exclusion of specific products. On December 28th in a Federal Register publication, USTR announced that determinations have been made to grant certain exclusion request. They will also continue to issue decisions on pending requests on a periodic basis.
An announcement was made in early December that the additional Section 301 duties scheduled to increase on January 1, 2019 from 10% to 25% would not increase on January 1. The USTR has announced the new effective date for the rate increase. The duty rate for goods from China will increase to 25% effective March 2, 2019.
President Trump stated on Dec. 2 that he intends to formally withdraw the U.S. from NAFTA “shortly” after signing a replacement deal with partners Canada and Mexico. However, it is unclear what the impact of such a move would be. Trump advised that submitting a formal withdrawal notice, (which could end U.S. participation in NAFTA six months later) would give Congress the option of approving the U.S.-Mexico-Canada Agreement signed Nov. 30 or reverting to pre-NAFTA trade relations.
The Environmental Protection Agency (EPA) has published an update regarding the standards for regulated composite wood products. Some of these products include hardwood plywood, particleboard, medium-density fiberboard, furniture, cabinets, picture frames, toys, and many other goods. These requirements apply to regulated products imported into the United States.
The Office of the U.S. Trade Representative (USTR) previously announced a process to obtain product exclusions from the additional tariffs in effect on certain products imported from China under the U.S. response to China’s unfair trade practices. The USTR recently announced that it is still in the process of posting exclusion requests due to the high volume of submissions. As of the date of this report, 815 exclusion requests have been denied and none have been granted.
On November 20th, U.S. Customs and Border Protection officers at the border crossing of Nogales are credited for saving the life of a U.S. infant. Officers at the Dennis DeConcini Crossing assisted a 41-year-old woman who was attempting to re-enter the U.S. from Mexico. As the Arizona woman crossed through a SENTRI lane, she was calling for agents to help with her two-month-old son who was not breathing and possibly choking. Agents quickly closed the lane and began to assist with the baby. The CBP officer quickly began to perform infant CPR. Once the baby regained consciousness and began to breathe on his own, he was handed back to his mother. The woman drove the baby on her own to the local hospital without further incident. What a happy ending for all and a special thank you to our CBP Heroes that control our borders!
The U.S. Mexico-Canadian Agreement (USMCA) is scheduled to be signed on November 30th at the G20 summit in Buenos Aries, Argentina. Before reaching the signing ceremony, the new USMCA deal must be ratified by the legislatures of the three countries. With such a short window of time before the scheduled signing ceremony, many obstacles remain in the way. However, it has been confirmed that all three countries will sign the agreement. The USMCA will replace the North American Free Trade Agreement (NAFTA).
In September, U.S. Customs and Border Protection announced that the Miscellaneous Tariff Bill Act is effective for over 1600 products entered or withdrawn from warehouse for consumption on or after Oct. 13 and will remain in effect through Dec. 31, 2020. Additionally, according to CBP approximately half of these items are subject to the China 301 additional tariff. CBP states that while such products can benefit from the Miscellaneous Trade Bill, they remain subject to the 25% duty imposed from the Section 301 additional tariff requirement.
The Office of the U.S. Trade Representative announced that it will hold a hearing Nov. 29 in its reviews of whether various countries are meeting the eligibility criteria of the Generalized System of Preferences. USTR is currently evaluating whether:
Interested parties can submit comments, pre-hearing briefs, and requests to appear at the hearing to the USTR until 12:00 a.m. on Nov. 13, 2018.
On October 16, the Trump administration formally notified Congress that it intends to negotiate trade agreements with Japan, the European Union, and the United Kingdom. The Office of the U.S. Trade Representative will next consult with Congress and gather public input on the direction, focus, and content of these agreements as part of a process set forth under the Trade Promotion Authority law (TPA) to ensure that any final agreements receive expedited consideration by lawmakers. Negotiations will begin no earlier than Jan. 14, 2019, with the EU and Japan, and the United Kingdom after March 29, 2019.
The U.S., Canada, and Mexico announced Sept. 28 an agreement to modernize the 25-year-old North American Free Trade Agreement. The agreement is now called, "The U.S.-Mexico-Canada Agreement (USMCA)" and is expected to be signed by Dec. 1 which could bring it up for congressional consideration in early 2019.
The White House announced that the Miscellaneous Tariff Bill became law on September 13th. The tariff rate reductions on nearly 1,700 items will take effect 30 days after the bill was signed. The reductions will last through the end of 2020. The International Trade Commission developed the list, and most of the items are intermediate goods, but some are consumer goods that are not produced in the U.S.
On August 1, an announcement was published regarding the adjustment of certain customs fees collected by U.S. Customs and Border Protection including its Merchandise Processing Fee. The adjusted amounts and their corresponding limitations set forth in the notice for Fiscal Year 2019 are effective as of October 1, 2018.
The USTR released the final list for the second tranche of Section 301 tariffs. This is the remaining tariffs from the list that was released on April 5th. These products will be subject to the additional duty rate of 25% from China. Please note that this is not to be confused with the list that contains approximately 6031 tariffs and is being reviewed in the announcement on August 1st. That is a completely separate list and is still in the review process for consideration of increasing the tariff to 25% instead of the initial announcement of 10%. CBP begin collection of an additional 25% duty on these goods effective August 23!
The Trump administration is reviewing Turkey's duty-free trade access to US markets under the Generalized System of Preferences after Turkey imposed retaliatory tariffs on $1.78 billion of US goods in response to American steel and aluminum tariffs. The review could affect $1.66 billion worth of Turkish imports into the United States that benefited from the GSP program last year, including motor vehicles and parts, jewelry, precious metals and stone products. The Office of the US Trade Representative said the review is being conducted due to concerns about Turkey's compliance with the program after it targeted only US goods and not those of other countries.
At a time when trade news is in the headlines almost daily, U.S. Customs and Border Protection’s Trade Symposium, held in Atlanta, on August 14-15, drew a record number of attendees from near and far. More than 1,100 members of the trade community flocked to the event. The two-day event at the Atlanta Marriott Marquis opened with a conversation with CBP Commissioner Kevin McAleenan and Elizabeth Merritt (Managing Director of Cargo Services for Airlines for America). The commissioner spoke on a wide range of subjects including the new trade remedies. JAS Forwarding had two team members in attendance, Laurie Arnold and Leah Ellis.
When U.S. Customs and Border Protection (CBP) officers seized 48 counterfeit Cartier Love Bracelets on Monday at the Port of Philadelphia, they proved that true love isn't as cheap as some may hope.
CBP officers selected a shipment manifested as bracelets from Hong Kong. When the shipment was inspected for possible counterfeit merchandise, the officers found 31 Cartier Rose and Yellow Gold Bracelets and 17 Cartier White Gold Bracelets, all diamond paved. Due to the poor packaging and quality of the items, CBP officers detained the shipment for further evaluation.
In May, JAS Forwarding (USA) Inc. Compliance team met at the USA Corporate Headquarters in Atlanta, GA. During the meetings, the team worked to align on all of the trade changes and learn from each other to continue to provide positive impacts to our clients.
From Left to Right: Ted Myron, Xenia Vazquez, Leah Ellis, Calvin Oh, Margaret Christian, Casey Hughes, Laurie Arnold, Scott Cassell, and Yvette Sosa
The Court of International Trade has determined that IEEPA does not give the President authority to impose reciprocal or drug/border tariffs.
The Adminstration immediately appealed and requested a stay in the Court of Appeals Federal Circuit which has ben approved. This means that IEEPA tariffs will remain in effect while this is being reviewed in the appellate process.
Click below to read more:
The USTR has announced that they will extend Section 301 exclusions for 164 items plus 14 exclusions covering solar manufacturing equipment. These items were extended on May 30, 2024, and September 18, 2025 respectively and were set to expire on May 31, 2025. The new expiration date is August 31, 2025.
On June 3, 2025, the President signed a proclamation, “Adjusting Imports of Aluminum and Steel into the United States.” This proclamation addresses previous statements on increasing steel and aluminum duties from 25% to 50%.
Per the proclamation, all countries except for U.K. will now be subject to 50% for 232 tariffs on steel/aluminum and derivatives. Steel/aluminum and derivative imports from the U.K. will remain at 25% at least through July 9. The Commerce Secretary may adjust the rate at that time if needed.
This is effective for consumption entries as of 12:01am Eastern time June 4, 2025, and there are no in-transit exemptions, and no drawback is allowed on these duties.
With regards to steel/aluminum and derivative items,duties will be applied as follows:
Check out the links below:
The President has posted on Truth Social that tariffs on steel and aluminum will be raised from the current 25% to 50%. This change is expected to be effective on June 4.
The President stated that this increase will help continue to bring steel and aluminum production back to the US.
Check out the Truth Social post below:
Update
As previously advised in our advisory below, CIT has determined that IEEPA does not give the President authority to impose reciprocal or drug/border tariffs.
For clarity note that the CIT directed the U.S. Government to enforce a permanent injunction against the IEEPA tariffs within 10 calendar days of its decision, setting a deadline of June 7, 2025. In response, the government promptly filed an appeal with the US Court of Appeals in the Federal Circuit and submitted a motion requesting a stay of judgment’s enforcement during the appeal process. If CIT grants the stay, the IEEPA tariffs will likely remain in place until a final ruling is issued. In other words, nothing changes at this time until additional instructions have been provided.
Until JAS receives further information/instructions from CBP, we are required to continue to apply all existing tariffs.
Additionally, it remains uncertain whether importers will be allowed to file claims for refunds on IEEPA tariffs they have already paid.
Note this is a fluid situation that we will continue to monitor.
Previously advised:
The Court of International Trade has determined that IEEPA does not give the President authority to impose reciprocal tariffs or drug/border tariffs. The court has ruled that the IEEPA tariffs exceed the authority granted to the President.
Per the judgement issued on May 28, 2025, Executive order 14193 (Canada Drug/Border), Executive order 14194 (Mexico Drug/Border), Executive order 14195 (China Drug/Border), and Executive order 14257 (Reciprocal Tariffs), all modifications and amendments are declared invalid as contrary to law.
The administration has the option to appeal, and it is expected that they will file an appeal. It is also very likely the administration will request a stay pending a decision on the appeal, meaning that the tariffs are probably going to stay for a while longer.
Check out the links below for more information.
The Administration has announced a 90-day pause on the recently escalating tariffs with China. During the pause, the US will reduce the 125% reciprocal tariff rate down to 10% which is currently applicable to all other countries. The 20% IEEPA drug/border tariff will remain during the pause.
Part of the agreement includes China removing their retaliatory tariffs and restrictions taken since April 2.
These actions are expected to be in effect by May 14, 2025, and will last for 90 days. The US and China will work to continue trade talks to address issues.
In summary, tariffs on imported Chinese goods will be applied as follows:
- Most Favored Nation rate (MFN)
- Section 301 duty rate (7.5%-100% depending on HTS)
- IEEPA Drug/Border (20%)
- IEEPA Reciprocal (at 10%), OR Section 232 (25% steel/aluminum/autos/auto parts/derivatives) – whichever is applicable by law
Check out the White House announcement, joint statement and fact sheet at the links below.
CBP has announced in CSMS 64981848 that they will be presenting a monthly series of four ACE Reports informational webinars starting on May 21. Below are the schedule and topics for the webinars:
1. Topic: Schedule and Email Recurring Reports
Webinar Date/Time: Wednesday, May 21, 2025, 1:00 p.m. ET
Virtual Office Hours Date/Time: Thursday, May 22, 2025, 1:00 p.m. ET
2. Topic: Modifying Reports
Webinar Date/Time: Tuesday, June 17, 2025, 1:00 p.m. ET
Virtual Office Hours Date/Time: Wednesday, June 18, 2025, 1:00 p.m. ET
3. Topic: Adding Dynamic Dates
Webinar Date/Time: Wednesday, July 30, 2025, 1:00 p.m. ET
Virtual Office Hours Date/Time: Thursday, July 31, 2025, 1:00 p.m. ET
4. Topic: Webinar Topic Coming Soon!
Webinar Date/Time: Wednesday, August 13, 2025, 1:00 p.m. ET
Virtual Office Hours Date/Time: Thursday, August 14, 2025, 1:00 p.m. ET
Information on how to join the webinars will be provided in an upcoming CSMS message. Check out the CSMS message link below for more details.
The President and the UK Prime Minister announced a trade deal, providing American companies access to the UK markets.
The trade deal will expand US market access in the UK, creating a $5 billion opportunity for new exports for US farmers, ranchers, and producers.
Additionally, the deal will create preferential access to UK aerospace components, and 10% reciprocal tariff rate on the first 100,000 UK origin vehicles per year (with the rate increasing to 25% after that threshold).
The White House Fact Sheet also states that “The United States…will negotiate an alternative arrangement to the Section 232 tariffs on steel and aluminum.”
No dates have been provided on when these actions will take effect. Click below to check out the White House Fact Sheet:
JAS Forwarding (USA) Inc. Compliance Project Manager, Scott Cassell in partnership with Sheryl Roberts, Director of Ocean Services, presented at a client event at our JAS ATL Branch. Ocean trends were discussed along with all the tariffs in the news.
Pictured Left to Right: Lars Huebecker, Tabitha Ackermann, Scott Cassell, Sheryl Roberts, and Cameron Hall
Laurie Arnold and Leah Ellis from the JAS Forwarding (USA) Inc. Compliance team attended the annual NCBFAA (National Customs Brokers and Forwarders Association of America) conference in April. Laurie Arnold, our VP of Compliance is also the Secretary of the NCBFAA. Leah is the NCBFAA Legislative Committee Chair. Our Compliance team attends numerous events during the year to stay on top of current events and issues!
Leah is on the left looking at the camera and Laurie on the right looking at the camera!
With rising tariffs, importers of record should proactively coordinate with their financial institutions to ensure that Customs and Border Protection (CBP) can successfully debit the appropriate duty amounts from their bank accounts.
Your bank may need to adjust the Debit Cap or remove a Debit Blocker associated with CBP debits. This action requires providing your bank with the CBP Company ID, which was originally issued in your ACH Debit Acceptance letter.
To avoid failed transactions, it is critical to:
• Review ACH debit reports to monitor the amounts CBP is drawing from your account.
• Confirm sufficient funds are available in your account to cover upcoming debits.
• Work with your bank to raise your debit cap if the increased tariffs result in higher duty payments.
Failure to ensure adequate authorization or funding could lead to debit rejections, which may trigger the issuance of a debit voucher and possible removal from the ACH Debit program, along with potential liquidated damages.
If you're moving to your own ACH Debit Pay Types 3, 7, or 8, here are additional steps to take:
• Notify your bank that CBP is authorized to debit your account.
• Provide the CBP Company ID to your financial institution.
• Set an adequate dollar limit on your ACH authorization to cover all expected Duties, Taxes, and Fees.
• Establish a daily transaction limit with your bank that accommodates the number of charges CBP may process (especially important for Periodic Monthly Statement (PMS) participants, who may incur multiple transactions in a single billing cycle).
CBP has stated in CSMS message 64916414 that they will publish refund procedures and any necessary updates to the Harmonized Tariff Schedule of the United States (HTSUS) in a Federal Register Notice no later than May 16, 2025. The message goes on to say that “Filers should refrain from requesting refunds until refund procedures are announced in the Federal Register Notice.”
This is related to the Executive Order, “Addressing Certain Tariffs on Imported Articles,” signed on April 29 which gives guidance on the application of tariffs imposed by previous presidential actions.
To read more details click below:
Click below to download a copy of the JAS Forwarding (USA) Inc. CTPAT Certificate
The President issued a Proclamation on April 29, 2025. The Proclamation states in part “To more effectively eliminate the threat to impair national security posted by imports of automobiles and automobile parts,...it is necessary to modify the system imposed in Proclamation 10908 by reducing the duties assessed on automobile parts for 15% of the value of an automobile assembled in the United States for 1 year and equivalent to 10% of that value for an additional year...” The Proclamation continues and states that “For automobiles assembled in the United States, automobile manufacturers shall be eligible to receive an import adjustment offset amount applicable to section 232 duties on automobiles...”
The Proclamation also defines the schedule for the import adjustment offset. “The automobile manufacturer may apply for an import adjustment offset amount equal to 3.75% of the aggregate MSRP value of all automobiles assembled in the US from April 3, 2025, through April 30, 2025.” It goes on to say, “The automobile manufacturer may apply for an import adjustment offset amount equal to 2.5% of the aggregate MSRP value of all automobiles assembled in the United States from May 1, 2026, through April 30, 2027.”
The Proclamation states that a process will be established for manufacturers to seek an import adjustment offset amount.
The President also issued an Executive Order on April 29, 2025. This order exempts good subject to 232 automobile and auto parts tariffs from section 232 steel/aluminum tariffs, and IEEPA drug/border tariffs for goods from Canada and Mexico.
The executive order also states “This order shall apply retroactively to all entries of merchandise subject to any applicable tariffs... (as noted above)...and made on or after March 4, 2025. Any refunds will be processed pursuant to applicable laws and U.S. Customs and Border Protection’s standard procedures for such refunds.
JAS Forwarding (USA) Inc. will provide more details on the refunds procedures once the guidance has been provided by CBP.
The President issued an Executive Order on April 9, 2025 aimed at “Restoring America’s Maritime Dominance.” The order covers numerous topics including a Maritime Action Plan, Ensuring Security and Resilience, PRC’s unfair actions, and other topics.
One key topic addresses the enforcement/collection of HMF (Harbor Maintenance Fees) and other charges. Historically, HMF was payable on all entries of goods by ocean mode of transport at US ports (including inland ports where cargo imported at a sea port and moved in bond inland). Cargo routed through Canada and Mexico and entered by land borders were not assessed the HMF fees. The executive order directs the Secretary of Homeland Security to take steps to collect HMF and any other fees etc. PLUS a 10% service fee for cargo first arriving in Canada or Mexico by vessel.
Another key issue addressed is the “Targeted and Phased Action to Reverse Chinese Dominance and to Restore American Shipbuilding.” These actions will occur in two phases. For the first 180 days, applicable fees will be set to zero. After 180 days:
• Fees on vessel owners and operators of China based on net tonnage per U.S. voyage, increasing incrementally over the following years - the fee would start at $50/NT in 180 days and increases by $30/NT per year over the next three years;
• Fees on operators of Chinese-built ships based on net tonnage or containers, increasing incrementally over the following years - the fee would start at $18/NT or $120 per container in 180 days, and would increase by $5/NT per year, or the same proportional yearly amount per container (e.g., in year 2, to $154 per container), over the next three years; and
• To incentivize U.S.-built car carrier vessels, fees on foreign-built car carrier vessels based on their capacity - the fee would start at $150 per Car Equivalent Unit (CEU) capacity of the entering non-U.S. built vessel in 180 days.
To read all related documents, check out the links below.
The President issued a memorandum on April 11, 2025 providing clarification of exceptions under Executive Order 14257 of April 2, 2025. In this EO, the President stated that certain goods are not subject to the ad valorem rates of duty under that order. Some of the excepted products are chips, computers, and smartphones.
The memorandum of April 11, 2025 notes that products classified in the following headings and subheadings of the HTSUS are included:
8471, 8473.30, 8486, 8517.13.00, 8517.62.00, 8523.51.00, 8524, 8528.52.00, 8541.10.00, 8541.21.00, 8541.29.00, 8541.30.00, 8541.49.10, 8541.49.70, 8541.49.80, 8541.49.95, 8541.51.00, 8541.59.00, 8541.90.00, and 8542.
Any duties collected at or after 12:01 a.m. eastern daylight time on April 5, 2025 are eligible for refunds in accordance with US CBP procedures. JAS Forwarding (USA) Inc. is reviewing past entries to see if any updates can be made and our branches will reach out to confirm approval to process.
The President has posted on Truth Social that as a result of China’s actions, he is increasing the tariff rate charged to China by the United States to 125%, effective immediately.
Additionally, the President has authorized a 90 day PAUSE on higher country rate reciprocal tariffs (Excluding China) because of more than 75 affected countries reaching out to the US to negotiate a solution.
During this time, the 10% reciprocal tariff that went into effect on April 5, 2025 on all countries will continue.
These changes are effective immediately per the posting. This has not been formally announced and we are awaiting the official notice.
The White House Press Secretary announced today April 8, 2025 that the President is set to impose an additional 50% on Chinese imports. The additional 50% is set to take effect at 12:01 a.m. EDT on April 9, 2025.
The official written notice from the White House has not yet been released so it is unclear under which program (IEEPA or others) this additional 50% will be implemented under.
Update- 4/9/2025- The President issued and executive order on April 8, 2025, "Amendment To Reciprocal Tariffs and Updated Duties as Applied to Low-Value Imports From the People's Republic of China." The order updates the reciprocal rate of duty for goods of China to 84% replacing the previous rate of 34% (for reciprocal tariffs).
IEEPA
Drug/Border Tariffs
Reciprocal Tariffs
China has issued Retaliatory Tariffs of 34% on top of existing tariffs and other measures. The President has posted on Truth Social that if China does not withdraw it’s 34% increase by April 8, 2025, the US will impose additional tariffs on China of 50% effective April 9.
Note that Annex I of the reciprocal tariffs has been updated with some countries having revised rates. Annex I has been updated and Annex III has been added on our link.
Note that 10% reciprocal tariff applies as of April 5 for goods from all countries and starting on April 9, countries with specific rates will be subject to their specific rate.
CSMS 64649265 issued April 5 addressing reciprocal tariffs. The CSMS message states “To prevent importers from abusing the exceptions for goods that were in transit before April 5, 2025 when it is no longer realistic due to the passage of time, CBP will permit heading 9903.01.28 to be declared only for goods that are entered for consumption or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on May 27, 2025.”
Dear Valued Client,
JAS Forwarding (USA) Inc. Compliance Team has put together some specific examples to help illustrate our current interpretation of the tariffs.
-Example item 1 costs $100 and is considered an aluminum derivative. The non-US aluminum
content represents 25% (or $25) of the value of the item. The regular rate of duty for this
item is 2.5%. If from China section 301 duty of 25% would apply.
-Example item 2 costs $100 and is not a derivative or any product subject to section 232. The
regular rate of duty for this item is 2.5%. If from China section 301 of 25% would apply.
IEEPA Reciprocal examples for countries listed in Annex 1
- Example 1 from China
o Regular rate of duty 2.5% applies= $2.50
o IEEPA Drug/Border duty of 20% applies = $20.00
o Section 301 of 25% applies = $25.00
o Section 232 derivative applies at 25% on non-US content
Non US content is $25 x .25 = $6.25
o IEEPA Reciprocal tariff rate from China is 34%, but because the item is a Section 232 derivative, this 34% reciprocal tariff does not apply.
o Total duty in this example = $53.75
- Example 2 from China
o Regular rate of duty 2.5% applied = $2.50
o IEEPA Drug/Border duty of 20% applies = $20.00
o Section 301 of 25% applies = $25.00
o IEEPA Reciprocal tariff from China at 34% applies = $34.00
o Total duty in this example = $81.50
- Example 1 from Japan
o Regular rate of duty 2.5% applied = $2.50
o Section 232 derivative applies at 25% on non-US content
Non US content is $25 x .25 = $6.25
o IEEPA Reciprocal tariff rate from Japan is 24%, but because the item is a Section 232 derivative, this 24% reiprocal tariff does not apply.
o Total duty in this example = $8.75
- Example 2 from Japan
o Regular rate of duty 2.5% applied = $2.50
o IEEPA reciprocal tariff from Japan at 24% applied = $24.00
o Total duty in this example = $26.50
IEEPA Reciprocal examples for countries not listed in Annex 1
- Example 1 from any country not listed in Annex 1 (except Canada and Mexico)
o Regular rate of duty 2.5% applied = $2.50
o Section 232 derivative applies at 25% on non-US content
Non US content is $25 x .25 = $6.25
o IEEPA reciprocal tariff for countries not listed in Annex 1 (except Canada and Mexico) is 10%, but because the item is a Section 232 derivative, this 10% reciprocal tariff does not apply.
o Total duty in this example = $8.75
- Example 2 from any country not listed in Annex 1 (except Canada and Mexico)
o Regular rate of duty 2.5% applied = $2.50
o IEEPA reciprocal tariff for countries not listed in Annex 1 (except Canada and Mexico) at 10% applied = $10.00
o Total duty in this example = $12.50
IEEPA examples for Canada and Mexico
- Example 1 from either Canada or Mexico USMCA Qualifying
o Special rate of duty FREE = $0.00
o IEEPA Drug/Border Tariff of 25% does not apply because the item is USMCA qualifying = $0.00
o Section 232 derivative applies at 25% on non-US content
Non US content is $25 x .25 = $6.25
o Total duty in this example = $6.25
- Example 1 from either Canada or Mexico not USMCA Qualifying
o Regular rate of duty 2.5% applied = $2.50
o IEEPA Drug/Border tariff of 25% applied = $25.00
o Section 232 derivative applies at 25% on non-US content
Non US content is $25 x .25 = $6.25
o Total duty in this example = $33.75
- Example 2 from either Canada or Mexico USMCA Qualifying
o Special rate of duty FREE = $0.00
o IEEPA Drug/Border Tariff of 25% does not apply because the item is USMCA qualifying = $0.00
o Total duty in this example = $0.00
- Example 2 from either Canada or Mexico not USMCA Qualifying
o Regular rate of duty 2.5% applied = $2.50
o IEEPA Drug/Border tariff of 25% applied = $25.00
o Total duty in this example = $27.50
For April, we are highlighting Christopher Gottlob, CHB Supervisor in our Detroit, MI branch. Christohper has a bachelor’s degree in supply chain management. Christopher started working at JAS in 2017 as an intern. In 2019, he moved into a brokerage position and found that he enjoyed doing customs entries more than moving freight. Christopher took and passed the Licensed Customs Broker exam in 2020 during Covid, which gave him plenty of time for studying. In 2022, Christopher became the CHB Supervisor in Detroit. Christopher has been able to follow the HTS GRIs and cross reference with CBP rulings to help clients find more appropriate HTS codes and in some cases, that has led to lower duties, saving his client on duties!
Christopher is married to his wife Megan, and they have a 2 year old daughter and are expecting their second in July. Christopher and his family have 2 cats, and a dog. He loves to go Detroit Lions games as a season ticket holder, golfing and enjoying his cabin in north Michigan with family and friends.
Christopher is another great example that People Make the Difference!
JAS Forwarding (USA) Inc. Compliance Project Manager, Scott Cassell in partnership with Sheryl Roberts, Director of Ocean Services, and Vivian Brunialti, Trade-Lane Director, presented at a client event in Miami, FL on March 27. Ocean trends from Asia to the US and LATAM were discussed along with all the tariffs in the news.
Pictured left to right, Scott Cassell, Vivian Brunialti, and Sheryl Roberts
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