To summarize, many countries have differing tariff rates according to Annex I in the Executive Order. Any country not listed in Annex I will continue with the 10% tariff as before.

Goods from the European Union (EU) will have it a little differently. If a good has a general duty rate of under 15%, then the Reciprocal Duty rate will equate to 15%. If a good has a general duty equal to or greater than 15%, then that rate will apply and the Reciprocal Duty rate will be 0%.

Goods determined by US Customs to have been transshipped to evade applicable duties will be subject to an additional 40% in lieu of the Reciprocal Duty rate. This does not include any other applicable fines or penalties. US Customs is not allowing for mitigation or remission of penalties for goods found to have been transshipped.

As is usual, this situation is fluid and is subject to change with little warning. Also, the US is in negotiations with various countries, and their Reciprocal Duty rate may change.

As always, we will keep you informed of any changes as we become aware of them.

Thank you.

As before, the situation is fluid and changes may arrive with very little notice. We will continue to post changes as they become available. The information presented here is from other sources and may not be considered legally binding.

The US will lower the Reciprocal Tariff to 10% for a period of 90-days. This is down from 125% imposed last month. However, the 20% Fentanyl Tariff remains in effect as does the original Section 301 Tariffs from Trump’s first term (7.5% or 25% depending on the HTS number used) as well as the Section 232 Tariffs (Aluminum/Steel and Autos/Auto Parts).

We are awaiting further information from US Customs on implementation. The information above is garnered from news reports and is not legally binding. We will keep monitoring the situation and provide additional information as it becomes available.

The statements above are based on the best information available to us at the time. They are not legally binding and are subject to change as new information becomes available.

• Section 301 Tariffs from 2018 of 7.5%, 25%, or 100% (on a few items)
  • The tariff rate applied is determined by the tariff classification number used for importation
• IEEPA Fentanyl Tariff of 20%
• IEEPA Reciprocal Tariff of 125%

If you combine all the maximum tariffs listed above together, you will get 245%. Does this mean that all Chinese products are 245%. No. Most products will be between 132.5% and 170%.

The products which have 100% tariffs include photovoltaic cells, electric vehicles, electric vehicle batteries, battery parts, and syringes.

As always, the situation remains fluid and information can change with very little notice. We will endeavor to keep this page updated as new information comes in.

The IEEPA Reciprocal Tariff rate for China has, which had been increased to 84%, has now been reportedly increased to 125%. When combined with the earlier IEEPA Fentanyl Tariff rate of 20%  and the Section 301 tariffs enacted in 2018, that means the China tariffs reach from 152.5% to 170%.

Again, this is information being reported by the news outlets and has not been officially confirmed from US Customs. We will continue to post new information as it becomes available.

*** Update: 4/10/2025***

We’re received guidance from US Customs that the information above is correct. Goods with country of origin of China that crossed after 12:01 a.m. EDT 4/9/2025, but before 12:01 a.m. EDT 4/10/2025, will have an IEEPA Reciprocal Tariff rate of 84%. Such goods that cross after 12:01 a.m. EDT 4/10/2025 will have an IEEPA Reciprocal Tariff rate of 125%, Please remember that previous duty rates still apply.

President Trump signed an Executive Order on April 2^nd invoking Section 232 of IEEPA Authority. This Executive Order imposed a universal 10% tariff for imports of all countries except as noted below.

Selected countries will have a greater tariff than the baseline 10%.

All imports subject to the 10% duty will be assessed the duty effective 12:01 a.m. ET on Saturday 4/5/2025 (that’s 9:01 p.m. PT on Friday 4/4/2025).

Annex I lists countries that subject to a tariff greater than 10%. Imports from the countries listed in

Annex I countries are subject to the specified tariffs effective 12:01 a.m. ET Wednesday 4/9/2025 (that’s 9:01 p.m. PT on Tuesday 4/8/2025).

In both cases, goods that are loaded onto a vessel at the port of lading and in final mode of transit before the times stated will NOT be subject to the tariff.

Exceptions:

The additional duty will not apply to:

• Goods exempted under 50 USC 1701
  • Goods for personal use
  • Donations of food, clothing, and medicine intended to relieve human suffering
  • Merely informational materials
• Products subject to existing Section 232 tariffs
  • Steel and derivatives
  • Aluminum and derivatives
  • Autos and auto parts
• The following products and any others listed in Annex II
  • Copper
  • Pharmaceuticals
  • Semiconductors
  • Lumber
  • Certain critical minerals
  • Energy and energy products
• Products from countries subject to Column 2 rates
  • Cuba
  • North Korea
  • Russia
  • Belarus
• Goods from Canada and Mexico covered under USMCA
  • Non-USMCA articles are still subject to the additional 25% duty
    • When then additional 25% duty is terminated or suspended, then such goods will be subject to a 12% IEEPA Reciprocal tariff
  • The value of US content of any goods provided that there is US content of no less than 20% of the value of the article
  • Section 321 de minimis goods of countries other than China.

If a country retaliates against US goods as a result of these tariffs, the President may increase or expand the scope of the tariffs.

If a country remedies the non-reciprocal trade agreements, the President may decrease or limit the scope of the tariffs.

SEC 232 – IEEPA Reciprocal Tariffs – Annex I

SEC 232 – IEEPA Reciprocal Tariffs – Annex II

Note:

The information above is borrowed heavily from an analysis performed by an NCBFAA Legislative Advisor of Sandler, Travis, & Rosenberg P.A.

As normal, the information is the best interpretation of the declaration available to us; however, this information is subject to change with very little notice. It may not be construed to be legally binding.

Automobiles that qualify for preferential treatment under USMCA may allow for the Importer to submit documentation identifying the amount of of US content in each model being imported into the US. Thereafter, the 25% tariff will apply to the non-US content of the vehicle.

Automobile parts that qualify for preferential treatment under USMCA will be exempt from the 25% tariff.

The full text of the proclamation may be found here.

As is usual, this is a very fluid matter and changes may occur with little warning. We will post such changes as we become aware of them.