JAS USA COMPLIANCE

News & Insights from JAS Worldwide Compliance

JAS Forwarding (USA), Inc.

6165 Barfield Road
Atlanta GA, 30328
United States
Tel: +1 (770)688-1206
Fax: +1 (770)688-1229

RECIPROCAL TARIFF UPDATES APRIL 3, 2025

April 3, 2025

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.  

Executive OrderAnnex IAnnex IICLIENT ADVISORY- RECIPROCAL TARIFF UPDATES 4-3-2025IEEPA RECIPROCAL ANNEXES 1 - 3 4-7-2025
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Latest News

RECIP UPDATES JULY 2025

Dear Valued Client,

On July 7, the administration has notified several different countries including Japan and South Korea of their new reciprocal tariffs that are expected to be applicable as of August 1. These letters are related to the reciprocal tariffs from the April 2 Executive Order 14257 that were paused starting on April 9.  

Additionally, the President has signed an executive order extending the 10% reciprocal tariff to continue until at least August 1.

Click below to reach the White House Fact sheet and Executive Order:

VIETNAM DEAL

Dear Valued Client,

The President has posted on Truth Social that a deal has been made with Vietnam. The preliminary details indicate that Vietnam will be subject to 20% tariff on goods sent directly to the US and 40% on goods transshipping. The President’s post indicates that Vietnam will open their markets to the United States.

Currently this has only been posted on social media. It is not an official announcement.

Additional updates will follow once they are available.

IEEPA UPDATES JULY 2025

On June 4, the Court of International Trade determined that IEEPA does not give the President authority to impose reciprocal or drug/border tariffs. The administration immediately filed an appeal and requested a stay.

On June 10, the Court of Appeals Federal Circuit (CAFC) issued the stay which means that for the time being, the IEEPA tariffs will remain while the courts litigate on this matter.

Oral arguments are scheduled for July 31 and a final decision from CAFC is not expected until at least August.  

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