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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. The orders utilize International Economic Emergency Power Act (IEEPA) authority to impose a universal 10% tariff on all countries except some specific countries with greater rates. Additionally, the list of products subject to section 232 tariffs on automobiles/auto parts has been released. The Department of Commerce also added two new products to the section 232 derivative aluminum articles.
IEEPA reciprocal tariffs of 10% ad valorem will be added for all countries. These will be effective at 12:01 am EDT April 5, 2025. Note that goods loaded onto a vessel at the port of lading in the final mode of transit prior to April 5, will not be subject to the IEEPA reciprocal tariffs.
IEEPA reciprocal tariffs with specifc rates (for countries listed in Annex I) will be effective at 12:01 am EDT on April 9, 2025. Note that goods loaded onto a vessel at the port of lading in the final mode of transit prior to April 9, will not be subject to the IEEPA reciprocal country specific rate.
There are published exceptions which define products that are excluded from the IEEPA reciprocal tariffs. Goods for personal use, donations, informational articles including publications, films and posters etc., under 50 USC 1702 are exempt.
Steel, aluminum, and derivatives, automobiles and auto parts under existing section 232 tariffs are exempt from the IEEPA reciprocal tariffs (note all existing tariffs still apply). Additionally, goods listed in Annex II (linked below) of the order are exempt, which includes items such as copper, pharmaceuticals, semiconductors, lumber, certain critical minerals, and energy/energy products. We believe these items are going to be addressed separately. The value of US content on any goods which have no less than 20% US value will be exempt from IEEPA reciprocal tariffs.
Section 232 for automobile and auto parts annex has been released. Section 232 for automobile tariffs are effective 12:01 am EDT April 3, 2025 with 25% tariffs applicable. Section 232 for auto parts tariffs are effective 12:01 am EDT May 3, 2025 with 25% tariffs applicable. The full list of applicable HTS codes are linked below.
Goods from Canada and Mexico that currently qualify for USMCA are exempt from the IEEPA border tariffs. However, upon termination/suspension of IEEPA border tariffs (25%), USMCA goods will be exempt from the IEEPA Reciprocal tariffs and non-USMCA goods will be subject to 12% IEEPA tariffs. No dates have been provided at this time.
Finally, the Department of Commerce has added two items to the Aluminum Derivatives list which include aluminum cans (7612) and aluminum cans containing beer (2203). These are effective 12:01 am EDT April 4, 2025 with 25% tariffs applicable.
Note that goods admitted to Foreign Trade Zones after 12:01 eastern on April 9 must be admitted in privileged foreign status. It is noted that goods that are eligible for admission to an FTZ under domestic status will be exempt from the tariffs.
Update 4-7-2025- IEEPA reciprocal tariffs are eligible for drawback. Unlike in previous IEEPA action, there is no express prohibition of claiming duty drawback on these tariffs.
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.
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