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On April 1st, the Court of International Trade issued an opinion stating that the USTR acted within its rights when implementing lists 3 and 4A of the Section 301 Tariffs. The plaintiffs in the case suggested that lists 3 and 4A violated the Trade Act and should be removed because these tariff lists were in retaliation to new Chinese tariffs on US goods, and not based in the original USTR Section 301 report.
They also suggested that the lists were unlawful because USTR did not start a new Section 301 investigation before implementation. The CIT found that the new lists were not in violation of the 1974 Trade act as alleged, but they found that the USTR did not follow the Administrative Procedure Act because they did not properly respond to the public comments on lists 3 and 4A. The case has been remanded to the Office of the USTR, allowing an opportunity for them to explain the reasoning behind the implementation of these lists. The USTR has been given until June 30th to provide this information.
In an Executive Order published on March 24, 2025, the administration has announced 25% tariffs on countries that import oil from Venezuela. The order states that “On or after April 2, 2025, a tariff of 25 percent may be imposed on all goods imported into the United States from any country that imports Venezuelan oil...” These duties will be supplemental to duties already imposed such as IEEPA, Section 232, Section 301 China tariffs, etc.
Additionally the President signed an executive order on March 26 applying Section 232 duties to automobiles, light trucks and auto parts (such as transmissions/powertrain parts, engines and engine parts etc.). The rate of duty will be 25% and this will go into effect starting April 3. It will not apply to USMCA parts until a process has been established to account for the non-US content of auto parts. If additional parts are to be tariffed, there will be a Federal Register notice as soon as practicable after the Commerce Secretary’s decision, and the tariffs will be collected one day after that notice.
Finally in response to a question yesterday, the President indicated that Lumber Tariffs may come starting on April 2.
Tariffs on Imports
Note this information is subject to change
Canada
• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• 10% IEEPA tariff on potash not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• 10% IEEPA tariff on energy not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• IEEPA tariffs became effective March 4, 2025.
• March 7, 2025 the carve out for USMCA became effective.
• USMCA qualified goods can be entered without the additional IEEPA rate.
• There’s no mechanism to recover duties paid from March 4 through March 6 on USMCA goods.
• If eligible for USMCA based on USMCA rules of origin, then IEEPA tariff will not apply.
Mexico
• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.
• IEEPA tariffs became effective March 4, 2025.
• March 7, 2025 the carve out for USMCA became effective.
• USMCA qualified goods can be entered without the additional IEEPA rate.
• There’s no mechanism to recover duties paid from March 4 through March 6 on USMCA goods.
• If eligible for USMCA based on USMCA rules of origin, then IEEPA tariff will not apply.
China
• IEEPA 20% tariff on all imports.
• Was initially 10% but was increased to 20% on March 4, 2025.
• Started on February 4, 2025.
• Goods on final leg destined to the US prior to February 1 and arriving before March 7, 2025 were eligible for an exemption on the IEEPA tariff.
• Existing Section 301 tariffs still in affect on top of IEEPA tariffs.
• Tariffs stack including IEEPA, 301 and 232 tariffs.
• Existing Section 301 exclusions are still in effect until their expiry date.
Section 232: Steel & Aluminum Tariffs
• All non-US steel and aluminum tariffs are 25% regardless of origin
• 25% tariffs expanded to include derivative products.
• No more exclusion process
• No Drawback allowed
• End of quota agreements with affected countries
• FTZ admissions must be in Privileged Foreign Status
• Listing of affected HTS codes and their corresponding chapter 99 program tariff can be found at the link below.
International Emergency Economic Powers Act (IEEPA)
• Grants the U.S. President authority to regulate commerce in response to national emergencies.
• Used to impose economic sanctions, restrict trade, or freeze assets of individuals, companies, or governments.
• Aims to protect U.S. national security and foreign policy interests.
• No drawback allowed
JAS Forwarding (USA) Inc. Compliance Team is pleased to announce that we will be hosting a webinar on all things tariffs on March 25, 2025, at 3PM Eastern time.
On the agenda, we will cover Canada tariffs, Mexico tariffs, China tariffs, Steel & Aluminum, reciprocal tariffs and much more.
Our own Laurie Arnold and Scott Cassell will discuss tariffs and answer questions. Check out our webinar flyer and the link to the registration page below.
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