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Importers: If you can't answer these 12 questions on forced labor, you're in trouble! Did you know that import cargo that has been made with forced labor can be seized by CBP? An estimated 40.3 million people were living in modern slavery at any moment in time in 2016. This amounts to 5.4 victims of modern slavery for every thousand people in the world. Seventy three per cent of the victims of forced labor were female, and one in four victims were children. Forced labor accounted for 24.9 million people, while 15.4 million were in forced marriage.
Basic question: Have you taken reliable measures to ensure imported goods are not produced wholly or in part with convict labor, forced labor, and/or indentured labor (including forced or indentured child labor)? Click the following link (http://diaztradelaw.com/importers-cant-answer-12-questions-forced-labor-youre-trouble/ ) to find out what you can do to ensure imported goods are not produced by forced labor.
Article written and published by Jennifer Diaz of Diaz Trade Law.
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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