Updated Guidance on New Tariff Structure for Products of Japan

2025-09-28T13:06:14-04:00September 28th, 2025|

U.S. Customs and Border Protection (CBP) has issued updated guidance (CSMS # 66242844) detailing the implementation of Executive Order 14345 (“Implementing the United States-Japan Agreement”) (EO 14345), which modifies duties applicable to imported articles from Japan. This EO was signed pursuant to the International Emergency Economic Powers Act (IEEPA) and Section 232 of the Trade Expansion Act of 1962.

  • Effective Date for Modified Duties: The new duty rates apply, retroactively, to products of Japan entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on August 7, 2025.

General Reciprocal Tariff (RT) (The 15% Baseline):

The Agreement establishes a baseline 15 percent tariff on nearly all Japanese imports entering the United States.

  • Tariff Calculation: The application of the additional reciprocal tariff is dependent on the Column 1 ad valorem duty rate.
  • If the Column 1 duty rate is less than 15 percent, the sum of the Column 1 rate and the reciprocal tariff rate will equal 15 percent.Filers must use HTSUS heading 9903.02.73.
  • If the Column 1 duty rate is 15 percent or greater, the additional reciprocal tariff is zero (0). Filers must use HTSUS heading 9903.02.72.
  • Note on Specific Duties: For products subject to a specific or compound rate of duty under Column 1-General, the ad valorem equivalent (AVE) rate must be calculated to determine which category applies.

Modification of Section 232 Duties (Automobiles and Automobile Parts):

EO 14345 modifies Section 232 duties on Japanese passenger vehicles, light trucks (automobiles), and automobile parts, effective on or after September 16, 2025.

  • The same 15 percent ad valorem duty rate standard applies based on the Column 1 duty rate.
  • For products where the Column 1 rate is less than 15 percent, the combined Column 1 and additional Section 232 duty rate is 15 percent, utilizing HTSUS headings 9903.94.41 (Automobiles) or 9903.94.43 (Automobile Parts).
  • For products where the Column 1 rate is 15 percent or greater, the additional Section 232 duty rate is zero (0), utilizing HTSUS headings 9903.94.40 (Automobiles) or 9903.94.42 (Automobile Parts).

Civil Aircraft Exemption (Tariff Removal):

Certain Civil Aircraft products of Japan are no longer subject to additional tariffs imposed under previous actions (EO 14257, Proclamations 9704, 9705, and 10962).

  • This exemption covers civil aircraft (all aircraft other than military and unmanned aircraft), their engines, parts, components, and ground flight simulators.
  • Filers must use HTSUS heading 9903.96.02, effective September 16, 2025.

Exemptions and Exclusions:

  • Section 232 Exemption from RT: Products of Japan that are subject to existing Section 232 actions (Aluminum, Steel, Copper, and certain Automobiles/Parts) will continue to be exempt from the new Reciprocal tariffs. Filers should continue to use HTSUS heading 9903.01.33 for these exemptions.
  • Other exemptions previously provided under Reciprocal tariffs (9903.01.25, 9903.01.30-9903.01.33, and 9903.01.34) remain in effect for products of Japan.

Retroactive Corrections: Since the modified duty rates are effective retroactively to August 7, 2025, filers must update previously filed entries to reflect the modified duty rates using the new HTSUS numbers (9903.02.72 or 9903.02.73, etc.).

Timing for Corrections: To avoid needing refunds, filers should take action to correct entries as soon as possible within 10 days of the cargo’s release from CBP custody and prior to estimated duties being deposited.

Refund Process:

  • For unliquidated entries where estimated duties have already been deposited, importers may request a refund upon liquidation by filing a post summary correction (PSC).
  • For liquidated entries, importers may request a refund by filing a protest pursuant to 19 U.S.C. 1514.

If you have any questions, please contact our Compliance Team or your JSC account supervisor.

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