6165 Barfield Road
Atlanta GA, 30328
United States
Tel: +1 (770)688-1206
Fax: +1 (770)688-1229
In March 2019, JAS Forwarding Miami Branch was very pleased to have MSA Security on site for a live demo of their canine screening process. The 3PK9 Security Program allows airlines and freight forwarders to utilize private sector canine teams as a primary screening method. Essentially, reducing time and cost compared to other screening procedures.
On March 27th, JAS USA Compliance conducted or first FREE webinar open to current and potential JAS Import Clients. During this session, we discussed Section 232 & 301 tariffs and how it affects customs bonds, tariff exclusions and more! Please find the link below to review all of the questions and answers that were discussed in the webinar session. More webinars to come throughout the year!
Recently, our very own Compliance Officer Laurie Arnold was “flying” high, as her and Compliance Specialist Scott Cassell did an onsite audit for a company with airplanes.
Did you know that JAS Corporate Compliance offers internal auditing and other value added services?
We offer the following services for clients that include but not limited to:
For more information on any of these services, please contact your local JAS Representative today!
As of Monday March 20, 2018 JAS Forwarding (USA) is now assisting CBP and TSA on its initiative to provide enhanced security for air cargo coming into the United States. The Air Cargo Advanced Screening (ACAS) initiative was created by U.S. Customs and Border Protection (CBP) to gather data concerning the parties and commodities involved in air cargo prior to its loading on an aircraft at a foreign port. The initiative is currently in the pilot phase allowing CBP to collaborate with the air cargo industry to determine the most effective means of achieving the desired regulatory results without affecting the speed of air cargo operations.
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
A California based importer have agreed to resolve allegations that they violated the False Claims Act. The importer evaded customs duties on imports from PRC. The importer faces paying $8.1 Million to settle the violations.
Click below to read more.
Dear Valued Client,
We wanted to take an opportunity to clarify that IEEPA Drug/border tariffs (20% effective March 4, 2025 for China), and (25% effective March 4 for Canada and Mexico) are still in effect. IEEPA Drug/border tariffs are distinctly different than the new IEEPA Reciprocal tariffs announced yesterday.
China
- IEEPA Reciprocal tariffs from China (34%) apply effective April 9.
- If section 232, steel, aluminum, derivatives, autmobiles, and auto parts is applicable, then section 232 (25%) tariff supersedes the IEEPA Reciprocal tariffs at 34%.
- Section 301 for China still applies .
- IEEPA Drug/border tariffs from China (20%) still applies.
Canada/Mexico
- Goods from Canada and Mexico are exempt from the IEEPA Drug/border tariffs if qualifying for USCMA.
- If goods are not qualifying for USMCA, then IEEPA Drug/border tariffs apply (25%).
- If the IEEPA Drug/border tariff is terminated or suspended, USMCA qualifying goods will be exempt from IEEPA Reciprocal tariffs and non-USMCA goods will be subject to a 12% IEEPA reciprocal tariff.
- No dates have been provided at this time.
Additional updates will follow once they are available.
All of the comments in this advisory are subject to change and based on our current interpretation. The President issued executive orders yesterday, April 2.
Section 321/de minimis goods from China/Hong Kong will be elmininated. All goods of China/Hong Kong which are shipped by any method other than the international postal network are ineligible for de minimus as of 12:01 am EDT May 5, 2025. Entries must be made using formal or informal entry.
Goods shipping via international postal methods from China/Hong Kong will be subject to duty rates equal to either:
- 30% of the value as of May 2, 2025; or
- $25 per item (from May 2- May 31, 2025); or
- $50 per item from June 2, 2025.
- These duties will be in lieu of most favored nation rates, IEEPA drug tariffs, and 301 tariffs.
Packages from Macau remain eligible for de minimis but there may be a recommendation to extend the prohibition to Macau within 90 days.
All other countries are exempt from this de minimis change until Commerce has established a system to collect the tariffs.
Additional updates will follow once they are available.
All of the comments in this advisory are subject to change and based on our current interpretation. The President issued executive orders yesterday, April 2. The orders utilize International Economic Emergency Power Act (IEEPA) authority to impose a universal 10% tariff on all countries except some specific countries with greater rates. Additionally, the list of products subject to section 232 tariffs on automobiles/auto parts has been released. The Department of Commerce also added two new products to the section 232 derivative aluminum articles.
IEEPA reciprocal tariffs of 10% ad valorem will be added for all countries. These will be effective at 12:01 am EDT April 5, 2025. Note that goods loaded onto a vessel at the port of lading in the final mode of transit prior to April 5, will not be subject to the IEEPA reciprocal tariffs.
IEEPA reciprocal tariffs with specifc rates (for countries listed in Annex I) will be effective at 12:01 am EDT on April 9, 2025. Note that goods loaded onto a vessel at the port of lading in the final mode of transit prior to April 9, will not be subject to the IEEPA reciprocal country specific rate.
There are published exceptions which define products that are excluded from the IEEPA reciprocal tariffs. Goods for personal use, donations, informational articles including publications, films and posters etc., under 50 USC 1702 are exempt.
Steel, aluminum, and derivatives, automobiles and auto parts under existing section 232 tariffs are exempt from the IEEPA reciprocal tariffs (note all existing tariffs still apply). Additionally, goods listed in Annex II (linked below) of the order are exempt, which includes items such as copper, pharmaceuticals, semiconductors, lumber, certain critical minerals, and energy/energy products. We believe these items are going to be addressed separately. The value of US content on any goods which have no less than 20% US value will be exempt from IEEPA reciprocal tariffs.
Section 232 for automobile and auto parts annex has been released. Section 232 for automobile tariffs are effective 12:01 am EDT April 3, 2025 with 25% tariffs applicable. Section 232 for auto parts tariffs are effective 12:01 am EDT May 3, 2025 with 25% tariffs applicable. The full list of applicable HTS codes are linked below.
Goods from Canada and Mexico that currently qualify for USMCA are exempt from the IEEPA border tariffs. However, upon termination/suspension of IEEPA border tariffs (25%), USMCA goods will be exempt from the IEEPA Reciprocal tariffs and non-USMCA goods will be subject to 12% IEEPA tariffs. No dates have been provided at this time.
Finally, the Department of Commerce has added two items to the Aluminum Derivatives list which include aluminum cans (7612) and aluminum cans containing beer (2203). These are effective 12:01 am EDT April 4, 2025 with 25% tariffs applicable.
Note that goods admitted to Foreign Trade Zones after 12:01 eastern on April 9 must be admitted in privileged foreign status. It is noted that goods that are eligible for admission to an FTZ under domestic status will be exempt from the tariffs.
Update 4-7-2025- IEEPA reciprocal tariffs are eligible for drawback. Unlike in previous IEEPA action, there is no express prohibition of claiming duty drawback on these tariffs.
The President has announced broad reciprocal tariffs. The reciprocal tariffs will vary by country. The tariffs reciprocal tariffs will depend on existing tariffs for US goods exported to those countries.
The President shared a chart showing various rates applied to US goods to countries and the reciprocal tariff that will be applied to goods from those countries. Examples included China with overall tariff percentage of 67% on US goods, which the US will be applying a reciprocal tariff of 34%. Other examples include Japan charging 46% on US goods and the US now applying a 24% reciprocal tariff. JAS will post the full list once it is officially published.
Other deveopments today include a list of specific HTS codes for automobiles subject to the 25% tariff effective April 3. Auto parts will be implemented on May 3.
Finally, aluminum containers under 7612.90.10 and beer under 2203.00.00 have been added to the aluminum derivatives list.
Additional updates will follow once they are available.
In an Executive Order published on March 24, 2025, the administration has announced 25% tariffs on countries that import oil from Venezuela. The order states that “On or after April 2, 2025, a tariff of 25 % may be imposed on all goods imported into the United States from any country that imports Venezuelan oil...” These duties will be supplemental to duties already imposed such as IEEPA, Section 232, Section 301 China tariffs, etc.
Additionally the President signed an executive order on March 26 applying Section 232 duties to automobiles, light trucks and auto parts (such as transmissions/powertrain parts, engines and engine parts etc.). The rate of duty will be 25% and this will go into effect starting April 3. It will not apply to USMCA parts until a process has been established to account for the non-US content of auto parts. If additional parts are to be tariffed, there will be a Federal Register notice as soon as practicable after the Commerce Secretary’s decision, and the tariffs will be collected one day after that notice.
Finally in response to a question yesterday, the President indicated that Lumber Tariffs may come starting on April 2.
Tariffs on Imports
Note this information is subject to change
Canada
• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• 10% IEEPA tariff on potash not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• 10% IEEPA tariff on energy not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• IEEPA tariffs became effective March 4, 2025.
• March 7, 2025 the carve out for USMCA became effective.
• USMCA qualified goods can be entered without the additional IEEPA rate.
• There’s no mechanism to recover duties paid from March 4 through March 6 on USMCA goods.
• If eligible for USMCA based on USMCA rules of origin, then IEEPA tariff will not apply.
Mexico
• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• IEEPA tariffs became effective March 4, 2025.
• March 7, 2025 the carve out for USMCA became effective.
• USMCA qualified goods can be entered without the additional IEEPA rate.
• There’s no mechanism to recover duties paid from March 4 through March 6 on USMCA goods.
• If eligible for USMCA based on USMCA rules of origin, then IEEPA tariff will not apply.
China
• IEEPA 20% tariff on all imports.
• Was initially 10% but was increased to 20% on March 4, 2025.
• Started on February 4, 2025.
• Goods on final leg destined to the US prior to February 1 and arriving before March 7, 2025 were eligible for an exemption on the IEEPA tariff.
• Existing Section 301 tariffs still in affect on top of IEEPA tariffs.
• Tariffs stack including IEEPA, 301 and 232 tariffs.
• Existing Section 301 exclusions are still in effect until their expiry date.
Section 232: Steel & Aluminum Tariffs
• All non-US steel and aluminum tariffs are 25% regardless of origin
• 25% tariffs expanded to include derivative products.
• No more exclusion process
• No Drawback allowed
• End of quota agreements with affected countries
• FTZ admissions must be in Privileged Foreign Status
• Listing of affected HTS codes and their corresponding chapter 99 program tariff can be found at the link below.
• Automobiles, aluminum containers and beer added to Section 232 25% tariffs
International Emergency Economic Powers Act (IEEPA)
• Grants the U.S. President authority to regulate commerce in response to national emergencies.
• Used to impose economic sanctions, restrict trade, or freeze assets of individuals, companies, or governments.
• Aims to protect U.S. national security and foreign policy interests.
• No drawback allowed
JAS Forwarding (USA) Inc. Compliance Team is pleased to announce that we will be hosting a webinar on all things tariffs on March 25, 2025, at 3PM Eastern time.
On the agenda, we will cover Canada tariffs, Mexico tariffs, China tariffs, Steel & Aluminum, reciprocal tariffs and much more.
Our own Laurie Arnold and Scott Cassell will discuss tariffs and answer questions. Check out our webinar flyer and the link to the registration page below.
Multiple media outlets are reporting that the President will increase tariffs on steel and aluminum from Canada from 25% to 50% in response to the electricity price increases announced by the Ontario government for electricity sold to the United States. The President noted on a Truth Social post that the increase is effective starting tomorrow, March 12, 2025.
Read our full advisory by clicking below.
Customs and Border Protection has issued two CSMS messages, 64348288 and 64348411 providing guidance on handling of steel and aluminum derivatives including derivatives outside of chapters 73 and 76. The additional 25% duty will be applicable starting on March 12, 2025, for ALL steel and aluminum derivatives.
To read our full advisory, click on the link below.
Check out the link below to see our drawback webinar from March 4.
The President has signed an amendment to the Executive Orders related to goods from Canada and Mexico. This amendment addresses duties on Canadian and Mexican goods that are eligible for duty free entry under USMCA.
To read the full advisory, check out the link below.
An update has been provided regarding the steel and aluminum derivatives that are subject to the 25% additional tariff. The additional tariffs for the derivatives listed in chapter 73 and 76 will go into effect on March 12, 2025.
To read the full advisory, check out the link below.
Multiple media outlets are reporting that the paused tariffs with Canada and Mexico will go into effect on March 4, 2025. It has also been stated that the 10% additional tariffs on goods from China implemented in early February may be increased to 20% effective on March 4, 2025.
To read our advisory, check out the file below.
As the Administration continues to announce numerous new tariffs on various imported goods, it is crucial for importers to review their continuous bond sufficiency. With increased tariff rates and new product categories subject to additional duties, the potential for higher liabilities has significantly risen.
To read the full advisory check out the link below:
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