- Effective Dates: The reciprocal tariffs are being implemented in two phases: April 5, 2025, and April 9, 2025.
- Secondary HTSUS Classification: Importers are required to report a Chapter 99 secondary classification related to these reciprocal tariffs for all imported merchandise. This classification will either indicate the applicable reciprocal tariff or an exception to it.
- Initial 10% Duty (Effective April 5, 2025): Starting April 5, 2025, a 10% additional ad valorem duty applies to most imported goods under HTSUS secondary classification 9903.01.25.
- Country-Specific Duties (Effective April 9, 2025): Beginning April 9, 2025, this 10% general duty will be replaced by country-specific ad valorem duty rates for goods originating from 83 identified countries. These rates, listed under HTSUS classifications 9903.01.43 through 9903.01.76, vary by country. For example, goods from Cameroon or the Democratic Republic of the Congo will face an 11% additional duty under 9903.01.43, while goods from China (including Hong Kong and Macau) will be assessed a 34% duty under 9903.01.63. (Annex III)
- Exceptions: Certain categories of goods are exempt from these reciprocal tariffs. To claim an exception, importers must declare the corresponding HTSUS secondary classification. These exceptions include products of Canada and Mexico (under USMCA), goods in transit before the effective dates (with a deadline), products of Column 2 rate countries (like Belarus, Cuba, North Korea, and Russia), donations for human suffering, informational materials, certain items listed in Annex II, goods subject to Section 232 actions, and the U.S. content of articles with at least 20% U.S. origin.
- Foreign Trade Zones: Subject articles entering a U.S. foreign trade zone on or after April 9, 2025, must be admitted under “privileged foreign status” and will be subject to these duties upon entry for consumption. Drawback and De Minimis:
- Drawback and De Minimis: Drawback is available for these additional duties. The de minimis exemption generally continues to apply.
- Reporting Requirements: Specific instructions are provided for reporting these duties and exceptions on entry summary lines, especially for entries with multiple HTSUS numbers or articles with U.S. content.
- Binding Rulings and Assistance: Importers can request binding rulings from CBP on tariff classification and related matters. Contact information is provided for entry summary errors and general questions.
The complete guidance from CBP may be found 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. |