Beginning April 9, country-specific tariffs will be implemented under new subheadings ranging from 9903.01.43 through 9903.01.76, with countries grouped by their tariff rates.
Examples of country-specific tariffs include:
• 20% for the EU and Jordan (subheading 9903.01.50)
• 25% for South Korea (subheading 9903.01.54)
• 26% for India (subheading 9903.01.55)
• 32% for Taiwan, Indonesia, Angola, and Fiji (subheading 9903.01.61)
• 34% for China (including Hong Kong and Macau) (subheading 9903.01.63)
• Various other rates for Thailand, Bangladesh, Botswana, Liechtenstein, Serbia, and Vietnam.
Annex III also outlines exemptions to these tariffs under subheadings 9903.01.26 through 9903.01.34. These exemptions cover goods subject to IEEPA tariffs on Canada and Mexico (including USMCA exemptions), goods in transit, goods from Russia, Belarus, Cuba, and North Korea subject to the column 2 rate, donations and informational materials exempt by law, goods listed in Annex II of the executive order, goods subject to Section 232 tariffs on iron/steel, aluminum, autos/auto parts, and U.S. content exceeding 20%.
The 10% tariff under subheading 9903.01.25 will not be applied in addition to the country-specific tariffs taking effect on April 9.
Finally, the order details tariff treatment for Canada and Mexico should their IEEPA tariffs be removed, specifying subheadings and rates (generally 12%) for various categories of goods, including USMCA goods and energy/potash products, as well as duty-free treatment for certain parts and components. The annex allows Chapter 98 treatment for goods subject to these tariffs but does not mention drawback. Previous IEEPA orders have barred drawback.
Exceptions to Additional IEEPA Reciprocal Tariff
The additional duty will not apply to the following categories of goods:
• Goods exempted under IEEPA Reciprocal Tariff:
○ Goods that are for personal use.
○ Donations of food, clothing, and medicine intended to relieve human suffering.
○ Merely informational materials.
○ Donations of food, clothing, and medicine intended to relieve human suffering.
○ Merely informational materials.
• Products subject to existing 232 tariffs are exempt:
○ Steel and derivatives.
○ Aluminum and derivatives.
○ Autos/auto parts.
• Annex II provides a list of exempt commodities:
○ Copper.
○ Pharmaceuticals.
○ Semiconductors.
○ Lumber.
○ Certain critical minerals.
○ Energy and energy products.
• Products from countries subject to Column 2 duty rates are exempted:
○ Cuba.
○ North Korea.
○ Russia.
○ Belarus.
Drawback is available with respect to the additional duties imposed pursuant to the Executive Order.
US Customs Guidance on the utilization of Exemptions
To prevent importers from abusing the exception 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.
See Updated CBP Guidance here.
JSC will continue to monitor the situation and provide updates when available.
If you have any questions, please contact our Compliance Team or your JSC account supervisor.
