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

MPF INCREASES

Customs and Border Protection has announced an increase to the Merchandise Processing Fee assessed on imported goods. The increase is effective on October 1, 2025.

CSMS message 65741993 gives the details of the adjustments. For standard entry types, MPF is assessed at 0.3464% ad valorem with minimums and maximums. The minimum will be adjusted from the current $32.71 to $33.58. The maximum will be adjusted from $634.62 to $651.50.

Click below to read more:

EU DEAL

The President has announced a trade deal with the European Union.

Some of the terms of the deal are that the EU will purchase $750 billion worth of US energy, invest 600 billion in the US, and buy more US military equipment.

Additionally, the EU will lower the tariff on US origin goods to 0% and the US will impose 15% instead of the original 30% that was expected.

Steel and aluminum will remain at 50% for EU origin products under Section 232.

TRADE DEALS

In a White House Fact Sheet, the Indonesia deal is outlined. Under this deal with Indonesia, the reciprocal tariff will be 19%. Other key terms include eliminating tariff barriers, breaking down non-tariff barriers for US industrial exports, US agricultural exports, and more. Additional details are in the fact sheet linked below.

In a Truth Social Post, the President has indicated that a deal has been made with Japan. According to the post, the deal includes Japan investing in the US, Japan opening their country to trade including cars and trucks, rice and other ag products etc. The reciprocal rate under this deal will be 15%. The full Truth Social post is linked below.

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