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

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For April, we are highlighting Christopher Gottlob, CHB Supervisor in our Detroit, MI branch.  Christohper has 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!

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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