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Dear Valued Client,
We wanted to take an opportunity to clarify that IEEPA Drug/border tariffs (20% effective March 4, 2025 for China), and (25% effective March 4 for Canada and Mexico) are still in effect. IEEPA Drug/border tariffs are distinctly different than the new IEEPA Reciprocal tariffs announced yesterday.
China
- IEEPA Reciprocal tariffs from China (34%) apply effective April 9.
- If section 232, steel, aluminum, derivatives, autmobiles, and auto parts is applicable, then section 232 (25%) tariff supersedes the IEEPA Reciprocal tariffs at 34%.
- Section 301 for China still applies .
- IEEPA Drug/border tariffs from China (20%) still applies.
Canada/Mexico
- Goods from Canada and Mexico are exempt from the IEEPA Drug/border tariffs if qualifying for USCMA.
- If goods are not qualifying for USMCA, then IEEPA Drug/border tariffs apply (25%).
- If the IEEPA Drug/border tariff is terminated or suspended, USMCA qualifying goods will be exempt from IEEPA Reciprocal tariffs and non-USMCA goods will be subject to a 12% IEEPA reciprocal tariff.
- No dates have been provided at this time.
Additional updates will follow once they are available.
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set forth in subsection (a) of this section shall apply retroactively to products of Japan entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on August 7, 2025.”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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