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Are You at Risk? Have you ever thought or even said any of these statements?
“Just use this harmonized tariff code, it’s the one we have always used.”
“Send it to another port and use the same HTS and maybe that port won’t catch it…”
”We’ve never had to enter this item as ADD/CVD before so it doesn’t apply.”
“Compliance manual? Why do we need that?”
“Ultimate Consignee type? Other/unknown seems like a good choice.”
“Routed export transaction, who cares.”
“Oh just mark it as EAR99 and send it no license required, it can’t be harmful.”
If you have thought or said any of these statements, you may be putting yourself at a compliance risk! JAS Compliance may be able to help you!!! We offer a variety of value-add services.
Please contact your JAS representative today for more information!
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for these additional steel and aluminum derivatives are effective for…products that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on August 18, 2025.
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The President has issued an executive order “Further Modifying Reciprocal Tariff Rates to Reflect Ongoing Discussions with the People’s Republic of China” on August 11, 2025. This executive action falls under the International Emergency Economic Powers Act (IEEPA).
The United States has been in discussions with the PRC, and the rate has been 10% while discussions on details of a China deal have been continuing. The 10% was scheduled to expire on August 12, 2025, at 12:01 am EDT.
The Executive order notes that “The United States continues to have discussions with the PRC to address the lack of trade reciprocity in our economic relationship and our resulting national and economic concerns.” It goes on to say, “Through these discussions, the PRC continues to take significant steps toward remedying non-reciprocal trade arrangements and addressing the concerns of the United States relating to economic and national security matters.”
Because of these efforts, the President has continued the suspension of the duties until November 10, 2025 at 12:01 am.
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The President has issued an executive order “Addressing Threats to the United States by the Government of the Russian Federation” on August 6, 2025. This executive action falls under the International Emergency Economic Powers Act (IEEPA).
This order addresses findings that the Government of India is currently directly or indirectly importing Russian oil. As a result, articles of India imported into the United States shall be subject to an additional ad valorem rate of duty of 25%. This will take affect on August 27 and will be in addition to the 25% reciprocal tariff that takes effect for India on August 7.
Goods that were loaded onto a vessel at the port of loading and in transit on the final mode of transit prior to entry into the United States before 12:01 am EDT on August 27, and are entered for consumption, or withdrawn from warehouse for consumption before 12:01 am EDT on September 17, 2025, the tariff will not apply.
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