The following update on the imposing Reciprocal Tariffs is our interpretation of the information received to date. Details cannot be finalized until a Federal Register Notice (FRN) is issued.

All imported articles are subject to a 10% ad valorem IEEPA duty effective on April 5th at 12:01 AM EDT. This does not apply to in-transit goods that are loaded onto a vessel at the port of lading and in final mode of transit to the US before the effective date.

The rates for countries in Annex I shall apply, effective on April 9th at 12:01 AM EDT (from April 5th – 8th it is 10% and on April 9th the rate is per Annex I). The same in-transit rule applies, which is that goods that are loaded onto a vessel at the port of lading and in final mode of transit to the US before April 5th are excluded.

The following goods will not be subject to additional reciprocal tariffs (see Annex II of the Executive Order for the full list):

1. Steel and aluminum articles subject to Section 232 tariffs;
2. Autos and auto parts subject to the additional duties imposed in Proclamation 10908;
3. Copper, pharmaceuticals, semiconductors, lumber articles, energy, energy products, bullion, and certain critical minerals that are not available in the United States and other products enumerated in Annex II;
4. All articles that may become subject to future Section 232 tariffs.

Canada and Mexico: Goods from Canada and Mexico are not subject to reciprocal tariffs because the earlier IEEPA tariffs, linked to drug smuggling and migration, still apply and will continue to be subject to 25% under the existing IEEPA tariff actions. Goods that qualify as originating under the US-Mexico-Canada Agreement (USMCA) continue to be exempt from the 25% tariff. The order also states that if the administration decides that the 25% and 10% tariffs on Mexican and Canadian goods over those issues are no longer warranted, it will replace them with a 12% tariff.

Our interpretation of the application of duties is as follows:

Good NOT subject to Section 232 : 
Regular MFN General Duty Rate %
AD/CVD (if applicable)
Section 301 Duty Rate (if applicable) 
Original IEEPA Duty Rate
Reciprocal Duty Rate:

• April 5th – April 8th =  10%
• April 9th and after – the country specific duty rate in Annex I OR 10% will apply

Example Goods Country of Origin China after April 9^th HTS 9401.99.2580
Regular MFN General Duty Rate %           Free
AD/CVD (if applicable)                                N/A
Section 301 Duty Rate (if applicable)       7.5%
Original IEEPA Duty Rate                            20%
Annex I Rate                                                  34%
Total Duty                                                     61.5%

Goods that ARE subject to 232:
Regular MFN Duty Rate
AD/CVD (if applicable)
Section 301 Duty Rate (if applicable) 
Original IEEPA Duty Rate
Section 232 Duty Rate

Example: Goods Country of Origin China HTS 7326.90.8688
Regular MFN Duty Rate                             2.9%
AD/CVD (if applicable)                               
Section 301 Duty Rate (if applicable)       25%
Original IEEPA Duty Rate                            20%
Section 232 Duty Rate                                 25%
Total Duty                                                     72.90%

Goods that qualify for Special Rates of Duty / Free Trade Agreements:
Duty-free claim is still permitted against the general rate of duty; however, you do have to pay the reciprocal rate.

Example: Goods that qualify for Korea Free Trade
KOREA FTA GENERAL RATE OF DUTY = FREE
RECIPROCAL TARIFF = 26%
TOTAL DUTIES = 26%

Please see Annex III for a list of all modified HTSUS.

Please note that we are still pending further instructions from US Customs and a 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.