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Atlanta GA, 30328
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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
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.
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