On April 2nd, 2025, invoking his authority under the International Emergency Economic Powers Act of 1977 (IEEPA), President Donald Trump announced reciprocal tariffs against all countries. Certain countries with which the United States has the largest trade deficits will be subject to higher, individualized reciprocal tariffs. Below are the pertinent details from the Executive Order and White House Fact Sheet.

The US will impose additional 10% tariffs on all imports, but not on Mexican and Canadian goods, information goods like books, music or films, or any goods either subject to Section 232 tariffs or among goods that Trump is considering protecting under Section 232, including pharmaceuticals, copper, lumber, paper, wooden furniture and cabinetry, semiconductors, certain critical minerals, and energy and energy products.

• Effective April 5th, 2025, an additional 10% tariff will be imposed on all imports from all countries that the US sees as good actors.
• In-Transit Exemption: Goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before the above effective date will not be subject to such additional duty. We are pending further guidance on this from US Customs.

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.
• Among the other top sources of imports to the US, effective April 9th, 2025 at 12:01 AM EDT, individualized reciprocal tariff rates higher than 10% will be imposed on certain countries enumerated in Annex I. Below are examples of the additional tariff rates (all countries with only the 10% universal tariff are omitted from the table). We still are not clear on whether or not Free Trade Agreements will be exempt.

• US Content Carve-Out: The reciprocal tariffs will not apply to US content of an imported article if the subject article has least 20% US content.
• Importers cannot use Foreign Trade Zones (FTZ) to avoid reciprocal duties.
• The Executive Order and Fact Sheet are silent on whether or not drawback duty refunds are available. All recent tariff actions expressly excluded the use of drawback refunds.
• Other than China-origin goods, imported goods qualifying for de minimis treatment (i.e. commercial value lower than $800) are not subject to reciprocal tariffs at this time. The administration said it is ending de minimis for Chinese goods. To avoid the problem of mail packages not including Harmonized Tariff Schedule codes, the order imposes either a 30% duty or a $25 per item fee, and that $25 fee will go to $50 on June 1st. De minimis ends May 2nd, at 12:01 AM EDT.

Please note that we are still pending further instructions from US Customs. Once published, we will share further details.

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.