The following guidance was published in part on CSMS# 64680374 on April 8th, 2025:

The purpose of this message is to provide guidance on the additional duties due on imported merchandise, which were imposed by Executive Order, “Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits,” issued on April 2nd, 2025.

This guidance is an update to CSMS # 64649265 issued on April 4th, “GUIDANCE – Reciprocal Tariffs, April 5th, 2025, Effective Date,” which adds the actions that are effective April 9th, along with those effective on April 5th.

GUIDANCE

APPLICATION OF ADDITIONAL DUTY RATES

The additional rates of duty established by reciprocal tariffs are in addition to any other duties, taxes, fees, exactions and charges that apply to imported articles.

All imported goods, other than those that fall within the identified exceptions, entered for consumption, or withdrawn from warehouse for consumption on or after April 5th at 12:01 AM EDT, are subject to the following HTSUS secondary classification and duty rate:

9903.01.25: Additional ad valorem duty rate of 10%

Effective April 9th, a country-specific ad valorem rate of duty will apply to imported goods of 83 countries and will replace the 10% additional ad valorem duty rate under 9903.01.25. Imported goods of the countries identified below in 9903.01.43 – 9903.01.76, other than those that fall within the identified exceptions, entered for consumption, or withdrawn from warehouse for consumption on or after April 9th, 2025 at 12:01 AM EDT, are subject to the following HTSUS classifications and additional ad valorem duty rates. 

EXCEPTIONS

Until further notice, for all imported merchandise that is:

a)  entered for consumption, or withdrawn from warehouse for consumption on or after 12:01 AM EDT on April 5th and for which an HTSUS classification is required to be declared, if the secondary classification under heading 9903.01.25 is not declared, or

b)  entered for consumption, or withdrawn from warehouse for consumption on or after 12:01 AM EDT on April 9th and for which an HTSUS classification is required to be declared, if heading 9903.01.43 – 9903.01.76 is not declared, then one of the following HTSUS secondary classifications must be declared, to specify the particular exception pursuant to which the reciprocal tariff in heading 9903.01.25 or 9903.01.43 – 9903.01.76 does not apply to the imported articles that are excluded from the additional ad valorem duties:

9903.01.26: Articles the product of Canada, including those products of Canada entered free of duty as under the United States-Mexico-Canada Agreement, including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTSUS. Articles properly classified in 9903.01.10 through 9903.01.15 should declare a secondary classification under 9903.01.26 to be excepted from the reciprocal tariff.

9903.01.27: Articles the product of Mexico, including those products of Mexico entered free of duty as under the United States-Mexico-Canada Agreement, including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTSUS. Articles properly classified in 9903.01.01 through 9903.01.05 should declare a secondary classification under 9903.01.27 to be excepted from the reciprocal tariff.

9903.01.28: Articles the product of any country that were (1) loaded onto a vessel at the port of loading and in transit on the final mode of transport prior to entry into the United States before 12:01 AM EDT on April 5th, AND (2) are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 AM EDT on April 5th, and before 12:01 AM EDT on May 27th, 2025.

NOTE: Articles the product of the countries that have an additional country-specific rate of duty, identified in 9903.01.43 – 9903.01.76, that were (1) loaded onto a vessel at the port of loading and in transit on the final mode of transport on or after 12:01 AM EDT on April 5th and before 12:01 AM EDT April 9th and (2) are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 AM EDT on May 27th are subject to the 10% additional rate in lieu of the country-specific rate of duty. Articles to which this in transit scenario applies must be reported under 9903.01.25.

To prevent importers from abusing the exceptions for goods that were in transit before April 5th, 2025 or April 9th, as applicable, CBP will permit heading 9903.01.28, or heading 9903.01.25 for products of countries covered by headings 9903.01.43 – 9903.01.76, as applicable, to be declared only for goods that are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 AM EDT on May 27th, 2025, after which time the exceptions would no longer realistically apply due to the passage of time.

9903.01.29: Articles the product of any Column 2 rate country identified in general note 3(b); currently limited to Belarus, Cuba, North Korea and Russia.

9903.01.30: Articles that are donations, by persons subject to the jurisdiction of the United States, of articles, such as food, clothing, and medicine, intended to be used to relieve human suffering.

9903.01.31: Articles that are informational materials, including but not limited to, publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.

9903.01.32: Articles of any country, classified in the subheadings enumerated in the subdivision (v)(iii) of U.S. note 2, identified in Annex II. The only merchandise that is eligible for this exception is that which is listed in Annex II. 

9903.01.33: Articles of iron or steel, derivative articles of iron or steel, articles of aluminum, derivative articles of aluminum, passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks and parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks, of any country, subject to Section 232. actions.

9903.01.34: For articles in which at least 20% of the value of article is US originating, the US content will not be subject to the reciprocal tariff. The reciprocal tariff will be assessed on the non-US content. (See below for reporting instructions.)

CHAPTER 98

The additional duties imposed by the headings above shall not apply to goods for which entry is properly claimed under a provision of chapter 98 of the HTSUS pursuant to applicable CBP regulations, and whenever CBP agrees that entry under such a provision is appropriate, except for goods entered under heading 9802.00.80; and subheadings 9802.00.40, 9802.00.50, and 9802.00.60. For subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duties apply to the value of repairs, alterations, or processing performed, as described in the applicable subheading. For heading 9802.00.80, the additional duties apply to the value of the article assembled abroad, less the cost or value of such products of the United States, as described.

FOREIGN TRADE ZONE

Subject articles, excluding those encompassed by 50 U.S.C. 1702(b), except those that are eligible for admission to a foreign trade zone under “domestic status” as defined in 19 CFR 146.43, and are admitted into a United States foreign trade zone on or after 12:01 AM EDT on April 9th, 2025, must be admitted as “privileged foreign status” as defined in 19 CFR 146.41. Such articles will be subject, upon entry for consumption, to the duties imposed by this order and the rates of duty related to the classification under the applicable HTSUS subheading in effect at the time of admission into the United States foreign trade zone.

DRAWBACK

Drawback is available with respect to the additional duties imposed pursuant to this Executive Order.

DE MINIMIS

Until further notice, except as otherwise provided in Executive Order 14256, issued April 2nd, “Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports,” 90 FR 14899 (April 7th, 2025), which is effective May 2nd, the administrative exemption from duty and certain taxes at 19 U.S.C. 1321(a)(2)(C), known as the de minimis exemption, continues to be available for articles covered by headings 9903.01.25 and 9903.01.43 – 9903.01.76 and that are otherwise eligible for the exemption, including eligible articles sent to the United States through the international postal network.

Please note that we are still pending further instructions and a Federal Register Notice (FRN) in order to confirm all details of the reciprocal tariffs. RIM will continue to closely monitor this evolving situation and provide updates as necessary. Please reach out to your RIM representative should you have any further questions.