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The President issued an Executive Order on April 9, 2025 aimed at “Restoring America’s Maritime Dominance.” The order covers numerous topics including a Maritime Action Plan, Ensuring Security and Resilience, PRC’s unfair actions, and other topics.
One key topic addresses the enforcement/collection of HMF (Harbor Maintenance Fees) and other charges. Historically, HMF was payable on all entries of goods by ocean mode of transport at US ports (including inland ports where cargo imported at a sea port and moved in bond inland). Cargo routed through Canada and Mexico and entered by land borders were not assessed the HMF fees. The executive order directs the Secretary of Homeland Security to take steps to collect HMF and any other fees etc. PLUS a 10% service fee for cargo first arriving in Canada or Mexico by vessel.
Another key issue addressed is the “Targeted and Phased Action to Reverse Chinese Dominance and to Restore American Shipbuilding.” These actions will occur in two phases. For the first 180 days, applicable fees will be set to zero. After 180 days:
• Fees on vessel owners and operators of China based on net tonnage per U.S. voyage, increasing incrementally over the following years - the fee would start at $50/NT in 180 days and increases by $30/NT per year over the next three years;
• Fees on operators of Chinese-built ships based on net tonnage or containers, increasing incrementally over the following years - the fee would start at $18/NT or $120 per container in 180 days, and would increase by $5/NT per year, or the same proportional yearly amount per container (e.g., in year 2, to $154 per container), over the next three years; and
• To incentivize U.S.-built car carrier vessels, fees on foreign-built car carrier vessels based on their capacity - the fee would start at $150 per Car Equivalent Unit (CEU) capacity of the entering non-U.S. built vessel in 180 days.
To read all related documents, check out the links below.
The President issued a memorandum on April 11, 2025 providing clarification of exceptions under Executive Order 14257 of April 2, 2025. In this EO, the President stated that certain goods are not subject to the ad valorem rates of duty under that order. Some of the excepted products are chips, computers, and smartphones.
The memorandum of April 11, 2025 notes that products classified in the following headings and subheadings of the HTSUS are included:
8471, 8473.30, 8486, 8517.13.00, 8517.62.00, 8523.51.00, 8524, 8528.52.00, 8541.10.00, 8541.21.00, 8541.29.00, 8541.30.00, 8541.49.10, 8541.49.70, 8541.49.80, 8541.49.95, 8541.51.00, 8541.59.00, 8541.90.00, and 8542.
Any duties collected at or after 12:01 a.m. eastern daylight time on April 5, 2025 are eligible for refunds in accordance with US CBP procedures. JAS Forwarding (USA) Inc. is reviewing past entries to see if any updates can be made and our branches will reach out to confirm approval to process.
The President has posted on Truth Social that as a result of China’s actions, he is increasing the tariff rate charged to China by the United States to 125%, effective immediately.
Additionally, the President has authorized a 90 day PAUSE on higher country rate reciprocal tariffs (Excluding China) because of more than 75 affected countries reaching out to the US to negotiate a solution.
During this time, the 10% reciprocal tariff that went into effect on April 5, 2025 on all countries will continue.
These changes are effective immediately per the posting. This has not been formally announced and we are awaiting the official notice.
The White House Press Secretary announced today April 8, 2025 that the President is set to impose an additional 50% on Chinese imports. The additional 50% is set to take effect at 12:01 a.m. EDT on April 9, 2025.
The official written notice from the White House has not yet been released so it is unclear under which program (IEEPA or others) this additional 50% will be implemented under.
Update- 4/9/2025- The President issued and executive order on April 8, 2025, "Amendment To Reciprocal Tariffs and Updated Duties as Applied to Low-Value Imports From the People's Republic of China." The order updates the reciprocal rate of duty for goods of China to 84% replacing the previous rate of 34% (for reciprocal tariffs).
IEEPA
Drug/Border Tariffs
Reciprocal Tariffs
Section 232 Product Listings
China has issued Retaliatory Tariffs of 34% on top of existing tariffs and other measures. The President has posted on Truth Social that if China does not withdraw it’s 34% increase by April 8, 2025, the US will impose additional tariffs on China of 50% effective April 9.
Note that Annex I of the reciprocal tariffs has been updated with some countries having revised rates. Annex I has been updated and Annex III has been added on our link.
Note that 10% reciprocal tariff applies as of April 5 for goods from all countries and starting on April 9, countries with specific rates will be subject to their specific rate.
CSMS 64649265 issued April 5 addressing reciprocal tariffs. The CSMS message states “To prevent importers from abusing the exceptions for goods that were in transit before April 5, 2025 when it is no longer realistic due to the passage of time, CBP will permit heading 9903.01.28 to be declared only for goods that are entered for consumption or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on May 27, 2025.”
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
For April, we are highlighting Christopher Gottlob, CHB Supervisor in our Detroit, MI branch. Christohper has a bachelor’s degree in supply chain management. Christopher started working at JAS in 2017 as an intern. In 2019, he moved into a brokerage position and found that he enjoyed doing customs entries more than moving freight. Christopher took and passed the Licensed Customs Broker exam in 2020 during Covid, which gave him plenty of time for studying. In 2022, Christopher became the CHB Supervisor in Detroit. Christopher has been able to follow the HTS GRIs and cross reference with CBP rulings to help clients find more appropriate HTS codes and in some cases, that has led to lower duties, saving his client on duties!
Christopher is married to his wife Megan, and they have a 2 year old daughter and are expecting their second in July. Christopher and his family have 2 cats, and a dog. He loves to go Detroit Lions games as a season ticket holder, golfing and enjoying his cabin in north Michigan with family and friends.
Christopher is another great example that People Make the Difference!
JAS Forwarding (USA) Inc. Compliance Project Manager, Scott Cassell in partnership with Sheryl Roberts, Director of Ocean Services, and Vivian Brunialti, Trade-Lane Director, presented at a client event in Miami, FL on March 27. Ocean trends from Asia to the US and LATAM were discussed along with all the tariffs in the news.
Pictured left to right, Scott Cassell, Vivian Brunialti, and Sheryl Roberts
A California based importer have agreed to resolve allegations that they violated the False Claims Act. The importer evaded customs duties on imports from PRC. The importer faces paying $8.1 Million to settle the violations.
Click below to read more.
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.
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.
Section 321/de minimis goods from China/Hong Kong will be elmininated. All goods of China/Hong Kong which are shipped by any method other than the international postal network are ineligible for de minimus as of 12:01 am EDT May 5, 2025. Entries must be made using formal or informal entry.
Goods shipping via international postal methods from China/Hong Kong will be subject to duty rates equal to either:
- 30% of the value as of May 2, 2025; or
- $25 per item (from May 2- May 31, 2025); or
- $50 per item from June 2, 2025.
- These duties will be in lieu of most favored nation rates, IEEPA drug tariffs, and 301 tariffs.
Packages from Macau remain eligible for de minimis but there may be a recommendation to extend the prohibition to Macau within 90 days.
All other countries are exempt from this de minimis change until Commerce has established a system to collect the tariffs.
Additional updates will follow once they are available.
The President has announced broad reciprocal tariffs. The reciprocal tariffs will vary by country. The tariffs reciprocal tariffs will depend on existing tariffs for US goods exported to those countries.
The President shared a chart showing various rates applied to US goods to countries and the reciprocal tariff that will be applied to goods from those countries. Examples included China with overall tariff percentage of 67% on US goods, which the US will be applying a reciprocal tariff of 34%. Other examples include Japan charging 46% on US goods and the US now applying a 24% reciprocal tariff. JAS will post the full list once it is officially published.
Other deveopments today include a list of specific HTS codes for automobiles subject to the 25% tariff effective April 3. Auto parts will be implemented on May 3.
Finally, aluminum containers under 7612.90.10 and beer under 2203.00.00 have been added to the aluminum derivatives list.
Additional updates will follow once they are available.
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