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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
The President has signed an executive order on September 5. This order provides an updated version of Annex II to Executive Order 14257.
New additions to Annex II are in 9 Chapters of the HTSUS. The chapters are 25, 26, 28, 29, 47, 71, 72, 75, and 85. The full list can be reviewed by clicking on the excecutive order link below.
Also, there were some items that were removed from Annex II and will now be subject to reciprocal tariffs. These HTS include 2818.30.00, 3824.99.93, 3907.29.00, 3907.30.00, 3907.61.00, 3907.69.00, 3907.99.50, and 3910.00.00. These will all now be subject to reciprocal tariffs.
These changes took effect at 12:01 a.m. Eastern on September 8.
Click below to read more:
The President has signed an executive order on September 4. This order sets the parameters for the United States-Japan agreement.
In general, items will be subject to a baseline 15% duty rate on most items which are of Japanese origin. The order also states that “The tariffs set forth in subsection (a) of this section shall apply retroactively to products of Japan entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on August 7, 2025.”
CBP has advised that Post Summary Corrections or Protests should not be filed until CBP has provided additional guidance through a CSMS message on how to process any corrections.
Click below to read more:
The US Department of Commerce has posted for public inspection a Federal Register Notice that will be published in the Federal Register on August 19, 2025. This notice states that “BIS (Bureau of Industry and Security) is adding 407 Harmonized Tariff Schedule of the United States codes to the list of products that will be considered as steel or aluminum derivative products.
Per the FRN, “The non-steel and non-aluminum content will remain subject to the reciprocal and other applicable tariffs.” It goes on to note “The complete list of HTSUS codes added to the Section 232 tariffs by today’s action is listed in the annexes to this notice.”
Finally, the notice indicates that “The duties set out in the annex for these additional steel and aluminum derivatives are effective for…products that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on August 18, 2025.
Click below to read more:
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