04/13/2025

U.S. Tariffs - Latest Client Updates

The U.S. tariff landscape is changing fast. GEODIS has collected the latest updates from the U.S. administration to help you understand the impact on your business. Use our updates to make informed choices and manage your freight forwarding.

 

Please see our latest customs and tariff updates below. Please note that due to the rapidly changing situation with U.S. tariffs, some of this information may quickly become outdated, so always check with your customs brokerage representative for the latest details. We also have a comprehensive guide on how to reduce your tariff exposure.

 

For specific questions about how these changes may impact your supply chain, please contact your GEODIS representative.

 

United States

 

Canada

 

Mexico

 

For other countries, please get in touch with your local point of contact, or visit the GEODIS website at geodis.com.

 

Please note that due to the rapidly changing nature of tariffs, some of the older information on this page may be outdated. Always speak with your GEODIS customs team for the most up-to-date information. 

This information is for general informational purposes only, and does not constitute, and should not be considered, to be legal advice or customs advice specific to your company’s circumstances. The information herein is presented without any representation or warranty, including as to the accuracy or completeness of the information presented.

 

April 11 2025 - Update - Tariff Exemptions Under Presidential Memorandum

 

As outlined in the April 11, 2025, Presidential Memorandum, certain products are now exempt from the additional tariffs imposed by Executive Order 14257 (as amended). These exemptions apply to goods that are correctly classified under specific headings and subheadings of the Harmonized Tariff Schedule of the United States (HTSUS), listed below.

 

This exemption starts for any goods entered into the U.S. for consumption—or taken out of a warehouse for consumption—on or after 12:01 AM EDT, April 5, 2025.

 

HTSUS codes covered by the exemption:

 

  • 8471
  • 8473.30
  • 8486
  • 8517.13.00
  • 8517.62.00
  • 8523.51.00
  • 8524
  • 8528.52.00
  • 8541.10.00
  • 8541.21.00
  • 8541.29.00
  • 8541.30.00
  • 8541.49.10
  • 8541.49.70
  • 8541.49.80
  • 8541.49.95
  • 8541.51.00
  • 8541.59.00
  • 8541.90.00
  • 8542

     

For products classified under the specified HTSUS codes, secondary classification code 9903.01.32 must be reported to indicate the applicable exemption. Customs entries already filed can be updated accordingly to reflect this exemption. This applies to products covered under the following tariff headings:

 

  • 9903.01.25
  • 9903.01.43 through 9903.01.62
  • 9903.01.64 through 9903.01.76
  • 9903.01.63 

     

 

 

April 11 2025 - Revisions to President Trump's reciprocal tariffs order

 

On April 2, 2025, President Trump published an Executive Order outlining the reciprocal tariffs that were established from the “Reciprocal Trade and Tariffs” Memorandum review. The order established a Reciprocal Tariff Policy, imposing an additional 10% ad valorem duty on all imports, with higher country-specific rates for certain trading partners listed in Annex I. These tariffs remain until economic conditions justify their removal. 

 

The tariffs were set to be implemented in two stages per the original order:  

 

  • Effective April 5, 2025, a 10% tariff applies to all imports: 
  • Rates of duty apply with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 am Eastern Daylight Time on April 5, 2025, except for goods loaded onto a vessel at the port of loading and in transit on the final mode of transit to the U.S. prior to April 5, 2025 (see timeline below). 
  • Effective April 9, 2025, higher tariffs apply to designated trading partners per Annex I: 
  • Rates of duty apply with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 am eastern daylight time on April 9, 2025, except for goods loaded onto a vessel at the port of loading and in transit on the final mode of transit to the U.S. prior to April 9, 2025 (see timeline below). 

 

Revisions to the order

In the past week, there have been several changes to the original order. Those changes are outlined below: 

 

  • China, Hong Kong, and Macau had their specific country rate applicable increased to 84% effective April 9, 2025 - Executive Order  and CSMS – issued April 8, 2025  
     
  • All country specific reciprocal tariffs (outside of China, Hong Kong and Macau) were delayed 90 days until July 9, 2025 – Executive Order and CSMS  - issued April 9, 2025. These tariffs are currently at 10%.  
     
  • China, Hong Kong, and Macau had the specific country rate applicable increase to 125% - Executive Order and CSMS  - issued April 9, 2025 

 

Summary

 

  • As of April 10, 2025, goods with country-of-origin China, Hong Kong, and Macau have a reciprocal tariff rate of 125%. 
     
  • All other countries have a reciprocal tariff rate of 10%. On July 9, 2025, that 10% reciprocal tariff is due to increase to the country-specific rates. 
     
  • The country-specific rates can be found in the Federal Register. 

 

Exceptions

It is important to note that regardless of the changes noted above, the exceptions outlined in the original order are still applicable: 

 

  • 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 in order 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 in order 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 a.m. EDT on April 5, 2025, AND (2) are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on May 27, 2025. 

 

  • 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 U.S. originating, the U.S. content will not be subject to the reciprocal tariff. The reciprocal tariff will be assessed on the non-U.S. content. (See below for reporting instructions.) 
  • Additional guidance related to substantiation of this claim has not yet been provided by US Customs and Border Protection. As more information is provided, we will provide those updates via the Customs Corner.  

 

Import Duty Summary Examples by HTS Code and Country of Origin 

HTS  COO  Ad Valorum   Section 301  IEEPA Fentanyl  Reciprocal  Section 232   Total Duty 
6110.30.3059  China  32%  7.5%  20%  125%  N/A  184.5% 
7307.91.5050  China  5.5%  25%  20%  N/A covered by the IEEPA exception. See exceptions above.  25%   75.5% 
7307.91.5050  Canada  5.5%  N/A  25% USMCA does not apply.  N/A covered by the IEEPA exception. See exceptions above.  N/A  30.5% 
7307.91.5050  Canada  5.5%  N/A  N/A  USMCA applies.   N/A covered by the IEEPA exception. See exceptions above.  N/A  0% 
7307.91.5050  India  5.5%  N/A  N/A  10%  N/A  15.5% 
4202.92.4500  China  20%  25%  20%  125%  N/A  190%

 

For articles correctly classified under 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 U.S. Customs and Border Protection (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. 

 

Drawback

Drawback is available with respect to the additional duties imposed pursuant to this Executive Order. A reminder that Section 232 and IEEPA Fentanyl are not eligible for drawback.  

 

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 a.m. EDT on April 9, 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.  

 

Deminimis

Deminimis is another area that has undergone changes since April 2, 2025.  

 

As of April 2, 2025  following the Secretary of Commerce’s notification that adequate systems are in place to collect tariff revenue, President Trump is ending duty-free de minimis treatment for covered goods from the People’s Republic of China (PRC) and Hong Kong starting May 2, 2025 at 12:01 a.m. EDT. 

 

Imported goods sent through means other than the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties, which shall be paid in accordance with applicable entry and payment procedures. 

 

All relevant postal items containing goods that are sent through the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption are subject to a duty rate of either 30% of their value or $25 per item (increasing to $50 per item after June 1, 2025). This is in lieu of any other duties, including those imposed by prior Orders. 

 

As of April 8, 2025 an Executive Order was signed where it increased the ad valorem rate of duty from 30 percent to 90 percent; increase the per postal item containing goods duty in section 2(c)(ii) of Executive Order 14256 that is in effect on or after 12:01 a.m. eastern daylight time on May 2, 2025, and before 12:01 a.m. eastern daylight time on June 1, 2025, from 25 dollars to 75 dollars; and increase the per postal item containing goods duty in section 2(c)(ii) of Executive Order 14256 that is in effect on or after 12:01 a.m. eastern daylight time on June 1, 2025, from 50 dollars to 150 dollars. 

 

As of April 9, 2025 an Executive Order was signed where it increased the ad valorem rate of duty set forth in section 2(c)(i) of Executive Order 14256 of April 2, 2025 (Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports), as modified by the Executive Order dated April 8, 2025, from 90 percent to 120 percent. The order increased the per postal item cost on June 1, 2025, from 75 dollars to 100 dollars; and increased the per postal item from 150 dollars to 200 dollars. 

 

Free Trade Agreements

Free Trade Agreements can still be used where the products qualify under the rules of the agreement, to eliminate the ad valorem duties; the reciprocal duties still apply under IEEPA Reciprocal. Although Generalized System of Preferences (GSP) is expired, it is still eligible to be claimed with duties paid with hopes to receive a retroactive refund once renewed.    

 

List of Free Trade Agreements 

The United States has 14 comprehensive free trade agreements in effect with 20 countries. 

 

Other U.S. Trade Agreements 

 

See link for MPF and Preferential Trade Programs. 

 

 

Bonds

 

  • Bond considerations with the additional tariffs and the duty amounts paid by importers drastically increasing, below are some notes to consider: 
  • Based on CBP regulations, the importer’s continuous bond must cover 10% of duties, taxes, fees, ADD/CVD and new tariffs (232s, 301s, 201s) over a rolling 12-month period.  
  • Sufficient bond value coverage reduces the risk of the accumulation of bond liability and bond stacking.  
  • Bond stacking is having more than one customs bond open within a 12-month period which creates cumulative liability and additional risk. 
  • If CBP deems a bond is saturated, the bond is terminated and requires a new higher bond value to be on file with CBP.  A 30-day deadline for compliance starts. 
  • A bond termination requires advance notice of 15 days, if a saturated bond is not timely replaced and is rendered insufficient by CBP, the importer will not be able to transmit new ISF and customs entries during this time period.  
  • Increased bond value amounts & bond stacking create risk for the surety.   

  • The surety’s underwriter in order to protect their interests and manage risk may require collateral from the importer by means of a letter of credit.  

     

 

April 3 2025 - Liberation Day - Reciprocal Tariffs

 

On April 2, 2025, President Trump published an Executive Order outlining the reciprocal tariffs that were established from the “Reciprocal Trade and Tariffs” Memorandum review. The order establishes a Reciprocal Tariff Policy, imposing an additional 10% ad valorem duty on all imports, with higher country-specific rates for certain trading partners listed in Annex I. These tariffs remain until economic conditions justify their removal.
 

The Federal Register Notice and CSMS message providing additional information are still pending and will be provided as a follow-up to this advisory notice. 
 

Key takeaways

 

  • Tariffs will be initiated in two phases, starting April 5, 2025 and April 9, 2025
  • Implementation is based on when the goods are entered but transit details must be considered. 
  • Exclusions are noted for certain goods subject to other retaliatory tariffs and certain products currently under investigation. 
  • Outside of the exemptions listed, these tariffs are in addition to the ad valorem duty (column 1 rates), other applicable retaliatory tariffs and Antidumping and Countervailing orders. 
  • The Executive Order does not provide guidance on drawback applicability. Pending further updates in the Federal Register Notice. 


Implementation details

 

  • Effective April 5, 2025, a 10% tariff applies to all imports:
    • Rates of duty apply with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 am eastern daylight time on April 5, 2025, except for goods loaded onto a vessel at the port of loading and in transit on the final mode of transit to the U.S. prior to April 5, 2025 (see timeline below).
  • Effective April 9, 2025, higher tariffs apply to designated trading partners per Annex I:
    • Rates of duty apply with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 am eastern daylight time on April 9, 2025, except for goods loaded onto a vessel at the port of loading and in transit on the final mode of transit to the U.S. prior to April 9, 2025 (see timeline below).
Loaded onto a Vessel at Port of Loading and In Transit on Final Mode of Transit to US Entered for Consumption or Withdrawn from Warehouse Reciprocal IEEPA Tariff
Prior to April 5, 2025 After April 5, 2025 Not subject to additional duties
On or after April 5, 2025 On or after April 5, 2025 but before April 9, 2025 10%
Prior to April 5, 2025 On or after April 9, 2025 Rates set forth in Annex I
On or after April 5, 2025 but before April 9, 2025 On or after April 5, 2025 but before April 9, 2025 10%
Prior to April 9, 2025 After April 9, 2025 10%
On or after April 9, 2025 On or after April 9, 2025 Rates set forth in Annex I

 

Exclusions

 

  • Goods 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.
  • Goods 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.
  • Steel and aluminum goods and derivatives subject to Section 232 duties
  • Automobiles and automobile parts subject to Section 232 duties
  • Goods from Canada and Mexico subject to additional 25% duties (10% potash duties) under Executive Orders 14193 and 14194 (Fetanyl/migration IEEPA tariffs)
  • Goods from Canada and Mexico that qualify under USMCA
  • Other items under Annex II including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products
  • Countries subject to duties in Column 2 of the HTS (Republic of Belarus, Cuba, North Korea, Russian Federation)
  • Low Value Shipment goods from China removed from de minimis status effective May 2, 2025
  • Non-USMCA goods from Canada and Mexico will be subject to 12% reciprocal tariff if  IEEPA is terminated or suspended. 
  • De minimis treatment shall remain available for goods until adequate systems are in place to process and collect duty revenue. De minimis treatment will be revoked for goods from CN effective May 2, 2025

 

Modification and enforcement

 

  • The President may adjust tariffs based on retaliation, economic shifts, or security concerns.
  • The Commerce Secretary & USTR are authorized to implement and modify the policy.
  • Regular reports to Congress are required regarding the national emergency behind these measures.

 

Free Trade Agreement application

 

  • Ad valorem duties will not apply for FTA claims, however reciprocal tariffs will still be applicable. 

 

Country-by-country tariff detail

 

Annex 1 

Country Tariffs and Trade Barriers Charged to the U.S.A. Reciprocal Tariffs
China 67% 34%
European Union 39% 20%
Vietnam 90% 46%
Taiwan 64% 32%
Japan 46% 24%
India 52% 26%
South Korea 50% 25%
Thailand 72% 36%
Switzerland 61% 31%
Indonesia 64% 32%
Malaysia 47% 24%
Cambodia 97% 49%
United Kingdom 10% 10%
South Africa 60% 30%
Brazil 10% 10%
Bangladesh 74% 37%
Singapore 10% 10%
Israel 33% 17%
Philippines 34% 17%
Chile 10% 10%
Australia 10% 10%
Pakistan 58% 29%
Turkey 10% 10%
Sri Lanka 88% 44%
Colombia 10% 10%
Algeria 59% 30%
Oman 10% 10%
Uruguay 10% 10%
Bahamas 10% 10%
Lesotho 99% 50%
Ukraine 10% 10%
Bahrain 10% 10%
Qatar 10% 10%
Mauritius 80% 40%
Fiji 63% 32%
Iceland 10% 10%
Kenya 10% 10%
Liechtenstein 73% 37%
Guyana 76% 38%
Haiti 10% 10%
Bosnia and Herzegovina 70% 35%
Nigeria 27% 14%
Namibia 42% 21%
Brunei 47% 24%
Bolivia 20% 10%
Panama 20% 10%
Venezuela 29% 15%
North Macedonia 65% 33%
Ethiopia 10% 10%
Ghana 17% 10%
Peru 10% 10%
Nicaragua 36% 18%
Norway 30% 15%
Costa Rica 17% 10%
Jordan 40% 20%
Dominican Republic 10% 10%
United Arab Emirates 10% 10%
New Zealand 20% 10%
Argentina 10% 10%
Ecuador 12% 10%
Guatemala 10% 10%
Honduras 10% 10%
Madagascar 93% 47%
Myanmar (Burma) 88% 44%
Tunisia 55% 28%
Kazakhstan 54% 27%
Serbia 74% 37%
Egypt 10% 10%
Saudi Arabia 10% 10%
El Salvador 10% 10%
Côte d'Ivoire 41% 21%
Laos 95% 48%
Botswana 74% 37%
Trinidad and Tobago 12% 10%
Morocco 10% 10%
Moldova 61% 31%
Angola 63% 32%
Democratic Republic of the Congo 22% 11%
Jamaica 10% 10%
Mozambique 31% 16%
Paraguay 10% 10%
Zambia 33% 17%
Lebanon 10% 10%
Tanzania 10% 10%
Iraq 78% 39%
Georgia 10% 10%
Senegal 10% 10%
Azerbaijan 10% 10%
Cameroon 22% 11%
Uganda 20% 10%
Albania 10% 10%
Armenia 10% 10%
Nepal 10% 10%
Sint Maarten 10% 10%
Falkland Islands 82% 41%
Gabon 10% 10%
Kuwait 10% 10%
Togo 10% 10%
Suriname 10% 10%
Belize 10% 10%

 

April 3 2025 - Revocation of De Minimis for China

 

President Donald J. Trump signed an Executive Order on April 2, 2025 eliminating duty-free de minimis treatment for low-value imports from China and Hong Kong, effective May 2, 2025. This move aims to counter the flow of synthetic opioids into the U.S.

 

Key provisions

 

  • All non-postal imports valued at $800 or less will now be subject to full applicable duties.
  • Postal imports valued at $800 or less will face a 30% duty or $25 per item (rising to $50 per item after June 1, 2025), replacing all other prior tariffs.
  • Carriers must report shipments, hold international carrier bonds, and remit duties to U.S. Customs and Border Protection (CBP).
  • CBP can require formal entry for any postal package.
  • The Commerce Secretary will report within 90 days on the Order’s impact and potential expansion to Macau.

 

This policy tightens import controls while ensuring tariff revenue collection from low-value shipments previously exempt from duties.

 

References: Fact Sheet: President Donald J. Trump Closes De Minimis Exemptions to Combat China’s Role in America’s Synthetic Opioid Crisis – The White House

 

April 3 2025 - Adjusting imports of automobiles and automobile parts into the United States – annexes released 

 

As follow up to the Presidential Proclamation issued on March 26, 2025, 90 FR 14705 was published in the Federal Register outlining the specifics of the order. 

 

Key takeaways

 

  • On February 17, 2019, the Secretary of Commerce reported that imports of automobiles and certain automobile parts threaten U.S. national security.
  • The report identified that these imports are being brought in such quantities and under such circumstances that they impair national security.
  • The U.S. automotive industry's challenges include material and parts shortages, labor shortages, and increased competition from foreign industries with unfair subsidies.
  • Agreements such as the United States-Korea Free Trade Agreement and the United States-Mexico-Canada Agreement (USMCA) have not sufficiently mitigated the national security threat posed by these imports.
  • To address the ongoing threat, a 25% tariff on imported automobiles will be imposed starting April 3, 2025.
  • Tariffs on auto parts will begin on May 3,2025. 
  • For automobiles qualifying for preferential treatment under the USMCA, tariffs will apply only to the non-U.S. content of the vehicle, provided accurate documentation is submitted and verified.
  • No drawback (refund) of the imposed tariffs will be available.

 

 

Detailed information

On February 17, 2019, the Secretary of Commerce reported that imports of automobiles and certain automobile parts were threatening U.S. national security. Subsequent actions, including Proclamation 9888 of May 17, 2019, concurred with this finding and initiated negotiations to address the threat. However, these negotiations did not yield the desired agreements, and recent updates indicate that national security concerns have escalated, exacerbated by the COVID-19 pandemic and supply chain vulnerabilities. 

 

To address this ongoing threat, a 25% ad valorem tariff will be imposed on imported automobiles starting April 3, 2025. For automobile parts, the tariffs will be implemented by May 3, 2025. Importers of automobiles qualifying for preferential treatment under the USMCA may submit documentation detailing U.S. content, with the tariff applied only to the non-U.S. content. Inaccurate declarations will result in the full value of the automobile being subject to the tariff, both retroactively and prospectively. The 25% tariff will not apply to automobile parts under the USMCA until a process is established to apply the tariff exclusively to non-U.S. content. 

 

CSMS # 64624801 - GUIDANCE: Import Duties on Certain Automobiles was issued April 2, 2025 providing additional details and clarifications. 

 

 

Tariff implementation

 

  • Start Date: The new tariffs will take effect at 12:01 a.m. Eastern Daylight Time on April 3, 2025, for automobiles. For automobile parts, the tariffs will be imposed on a date specified in the Federal Register, but no later than May 3, 2025.
  • Tariff Rate: A 25% ad valorem tariff will be applied to the specified imports of automobiles and certain automobile parts. This means that 25% of the value of the imported goods will be added as a duty.
  • Scope for Automobiles : The tariffs will apply to all imports of the specified articles listed in Annex I of the proclamation or any subsequent annexes published in the Federal Register.
    • 9903.94.01 – 25% additional ad valorem duty applies to imports of passenger vehicles and light trucks from all countries except as provided for in headings 9903.94.02, 9903.94.03, and 9903.94.04. 
      1. Annex 1 covers subheadings 8703.22.01, 8703.23.01, 8703.24.01, 8703.31.01, 8703.32.01, 8703.33.01, 8703.40.00, 8703.50.00, 8703.60.00, 8703.70.00, 8703.80.00, 8703.90.01, 8704.21.01, 8704.31.01, 8704.41.00, 8704.51.00 and 8704.60.00.
    • 9903.94.02  – 0% additional ad valorem duty - Applies to imports classifiable under the Chapter 87 HTSUS classifications listed above,
      1. that are not passenger vehicles and light trucks; or
      2. the U.S. content of passenger vehicles and light trucks that have received approval from the Secretary of Commerce as noted under HTSUS 9903.94.03.
  1. No duties should be reported based on the U.S. content under this HTSUS until further guidance is provided. 
  2. No duties should be reported based on the non - U.S. content under this HTSUS until further guidance is provided. 
    • 9903.94.04:  0 % additional ad valorem duty - Applies to all entries of passenger vehicles and light trucks from all countries classifiable in the headings or subheadings listed above that were manufactured in a year at least 25 years prior to the year of the date of entry.
      1. Any importer entering the passenger vehicle or light truck covered shall provide any information that may be required, and in such form, as is deemed necessary by CBP in order to permit the administration of this heading.
  • 9903.94.03:  25% additional ad valorem duty - Applies to the non-U.S. content of passenger vehicles and light trucks eligible for special tariff treatment under the United States-Mexico-Canada Agreement (USMCA), upon approval from the Secretary of Commerce to apply the 25% ad valorem rates of duty exclusively to the value of the non-U.S. content of the automobile. 

 

  • Scope for Automobile Parts : The tariffs will apply to all imports of the specified articles listed in Annex I of the proclamation or any subsequent annexes published in the Federal Register 
    • 9903.94.05: 25% additional ad valorem duty – applies to parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans and cargo vans) and light trucks classifiable in the provisions of the HTSUS outlined below. 
      • These parts are found in various subheading of Chapter 40, 73, 83, 84, 85, 87, 90 and 94 as outlined in the FRN.
      • 9903.94.06: 0% additional ad valorem duty 
        1. For goods that fall under the above list of subheadings but are not automobile parts
        2. Goods that qualify for special tariff treatment under USMCA. These parts are exempt from the tariffs until the Commerce Secretary and CBP establish a procedure to exempt U.S. content and publish a notice in the FRN. 

 

U.S. content consideration

 

  • Importers must contact the U.S. Commerce Department for details on the process to request such approval from the Secretary of Commerce to apply the 25% ad valorem rates of duty exclusively to the value of the non-U.S. content of the passenger vehicles and light trucks.
  • As noted above, no duties should be reported based on the U.S. content until further guidance is provided.  
  • Importers of automobiles that qualify for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA) may submit documentation detailing the U.S. content in each imported model. The tariff will be applied exclusively to the value of the non-U.S. content of the automobile. The non-U.S. content is determined by subtracting the value of the U.S. content from the total value of the automobile.
  • The Secretary of Commerce will verify the submitted documentation. If the U.S. Customs and Border Protection (CBP) finds inaccuracies in the declared non-U.S. content, the full value of the automobile will be subject to the 25% tariff.

 

Penalties for inaccurate declarations

 

  • Full Tariff Application: If the CBP determines that there has been an overstatement of U.S. content, the 25% tariff will apply to the entire value of the automobile, both retroactively and prospectively.
  • Retroactive and Prospective Application: The retroactive application will cover the period from April 3, 2025, to the date of the inaccurate overstatement. The prospective application will cover the period from the date of the inaccurate overstatement to the date the importer corrects it.
  • No Impact on Other Fees: This penalty will not affect other applicable fees or penalties.

 

Exemptions and special provisions

 

  • Automobile Parts under USMCA: The 25% tariff will not apply to automobile parts qualifying for preferential treatment under the USMCA until a process is established to apply the tariff exclusively to the non-U.S. content of these parts.
  • Exclusions: The exemption does not apply to automobile knock-down kits or parts compilations. It is limited to individual automobile parts as defined in Annex I.

 

Foreign Trade Zones

 

  • Privileged Foreign Status: Any automobile or automobile part subject to the tariff and admitted into a U.S. foreign trade zone must be classified as "privileged foreign status" and will be subject to the applicable ad valorem rates upon entry for consumption.

 

No drawback available

 

  • No drawback (refund) will be available for the duties imposed under this proclamation. This ensures that the tariffs remain effective in addressing the national security threat.

     

Chapter 98 provisions

 

  • Goods for which entry is claimed under a provision of chapter 98, and which are subject to the additional duties prescribed herein shall be eligible for and subject to the terms of such provision and applicable CBP regulations, except that duties under subheading 9802.00.60 shall be assessed based upon the full value of the imported article. 
  • No claim for entry or for any duty exemption or reduction shall be allowed for the passenger vehicles or light trucks that are subject to the additional duties prescribed herein under a provision of chapter 99 that may set forth a lower rate of duty or provide duty-free treatment, taking into account information supplied by CBP, but any additional duty prescribed in any provision of this subchapter or subchapter IV of chapter 99 shall be imposed in addition to the duty in headings 9903.94.01 and 9903.94.03.

 

 

References

Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits – The White House

Fact Sheet: President Donald J. Trump Declares National Emergency to Increase our Competitive Edge, Protect our Sovereignty, and Strengthen our National and Economic Security – The White House

Fact Sheet: President Donald J. Trump Closes De Minimis Exemptions to Combat China’s Role in America’s Synthetic Opioid Crisis – The White House

https://www.whitehouse.gov/presidential-actions/2025/03/adjusting-imports-of-automobiles-and-autombile-parts-into-the-united-states/

https://www.federalregister.gov/documents/2025/04/03/2025-05930/adjusting-imports-of-automobiles-and-automobile-parts-into-the-united-states 

https://content.govdelivery.com/bulletins/gd/USDHSCBP-3da18a1?wgt_ref=USDHSCBP_WIDGET_2

Annex-II.pdf

Annex-I.pdf

 

April 3 2025 - Bond Sufficiency Reminder 

 

Key takeaways

 

The continuous import bond amount calculation is based on 10% of the total duties, taxes and fees paid or payable in a 12 month period.  

 

Please note that the bond coverage is a rolling continuous 12 months. Therefore, to ensure proper bond sufficiency coverage, estimated future duties, taxes, sanctions, tariffs, fees, ADD/CVD, etc. need to be calculated on the value of anticipated import volumes. 

 

If GEODIS is your bond management provider, bond sufficiency reports can be requested in order to review your current bond saturation.  Furthermore, GEODIS can assist in determining the proper bond sufficiency going forward associated with the impact of the new tariffs on your total bond amount.  If GEODIS does not manage your customs bond, please contact GEODIS Trade Services to discuss bond coverage solutions.   

 

CBP is tasked with monitoring the bond amounts and if saturation occurs only 15 days are allotted to comply before the bond is deactivated. 

 

Therefore, we recommend that proactive measures be taken to analyze and access accordingly.   

 

 

March 26 2025 - US Customs and Border Protection Updates 232 FAQ 

 

US Customs and Border Protection released FAQs related to Section 232 which provides guidance on unknown smelt and cast countries, sets, etc. The latest update was issued on March 24, 2025.

 

Key Takeaways

  • CBP provides guidance on reporting the melt and pour country, and country of smelt and cast or derivative steel and aluminum, when unknown. 
    • For derivative steel, filers can report OTH for the country of melt and pour. 
    • For derivative aluminum, filers may report “RU” for Russia if the filer does not know the country of smelt or cast; and pay the 200 percent Russia aluminum duty pursuant to Presidential Proclamation 10522 (88 FR 13267, March 2, 2023.)
  • There is no minimum amount of derivative steel or aluminum content provided for by Proclamations 10895 and 10896.
  • Guidance is provided for processing clearance for products that do not contain steel and / or aluminum content but have a tariff that are subject to Section 232. 
  • Clarity on the requirement for Certificates of Analysis. 
  • Clearance of sets where 232 duties may be involved. 


Detailed Information:

As of March 12, the changes to Section 232 of the Trade Expansion Act primarily involve adjustments to tariffs and quotas on imported steel / iron and aluminum products and an expansion to derivative products of those materials. With these modifications comes questions that US Customs and Border Protection is addressing under their existing FAQs located on their website. 

 

March 12 2025 - Increases to Aluminum and Steel Tariffs

On February 10, 2025, the President issued Proclamations 10895 and 10896, imposing specific tariff rates on aluminum and steel products and their derivatives, with tariffs on derivatives outside of Chapters 73 and 76 based on the value of their aluminum or steel content. The Department of Commerce has issued a notice, to be published today, confirming that systems are in place to process and collect these tariffs effective 12:01 a.m. EDT on March 12, 2025.

 

Key Takeaways

  • 25% Section 232 Duties on Steel and Aluminum Products Effective 12:01 a.m. EDT on March 12, 2025
  • 25% Section 232 Duties on Steel and Aluminum Derivatives Effective 12:01 a.m. EDT on March 12, 2025

 

Aluminum Articles and Derivatives

 

Provisional Tariff Breakdown:

  • 9903.85.02: Aluminum products except derivative articles listed in subdivision (g) – 25% additional duty. 
  • 9903.85.04: Derivative aluminum products listed in subdivision (i) (existing aluminum derivative articles subject to Section 232) – 25% additional duty. 
  • 9903.85.07: Derivative aluminum products listed in subdivision (j) (new aluminum derivative articles classified in Chapter 76 subject to Section 232) – 25% additional duty. 
  • 9903.85.09: Derivative aluminum articles listed in subdivision (j) or (k) (new derivative aluminum articles), where the derivative aluminum products were processed in another country from aluminum articles that were smelted and cast in the United States – 0% additional duty. 
  • 9903.85.08: Derivative aluminum products listed in subdivision (k) (new aluminum derivative articles not classified in Chapter 76 subject to Section 232): the import duty is based upon the value of the aluminum content
  • 9903.85.67- for aluminum products from Russia – 200% additional duty 
  • 9903.85.68 - for aluminum derivative products from Russia - 200% additional duty
  • 9903.85.70 – (FTZ specific) for aluminum derivative products from Russia – 200% additional duty

 

Click here to view or download the "List of Aluminum HTS Subject to Section 232".

 

FTZ – Foreign-Trade Zone 

  • Goods admitted into the zone on, or, after March 12,2025 (except for domestic goods) must be admitted in “privileged foreign status” and will be subject at time of entry to any duties in place at time of admission. 
  • The smelt and cast reporting requirements also apply to goods admitted into an FTZ and withdrawn from FTZ on, or, after March 10, 2025. 

 

Reporting Smelt and Cast Countries

  • To report the primary country of smelt, secondary country of smelt, or country of most recent cast importers must report the International Organization for Standardization (ISO) code on aluminum articles and derivative aluminum articles on all countries subject to section 232.   
  • Filers must report “Y” for primary country of smelt; and/or secondary country of smelt. Filers may not report “N” for both primary country of smelt and secondary country of smelt.
  • If the imported aluminum is manufactured only from recycled aluminum, then filers should report “Y” for the secondary country of smelt, and report the country reported as the country of origin of the imported article as the secondary country of smelt code.  Take note that aluminum manufactured only from recycled aluminum is not very common. Importers must be able to provide manufacturing documents, upon request, to substantiate the manufacturing process for the recycled aluminum product.
  • Country of Origin United States is not covered by the countries of smelt and cast reporting requirements.  If the imported product was smelted and cast in the United States, then the importer will report “US” for the country of smelt and “US” for the country of cast.

 

 

Steel Articles and Derivative Steel Articles

 

Provisional Tariff Breakdown:

  • 9903.81.87: Iron or steel products listed in subdivision j (except derivative articles) – 25% additional duty.
  • 9903.81.88: (FTZ specific) Iron or steel products except for derivative articles listed in subdivision (l), (m) and (n) that are admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 12, 2025. - 25% additional duty.
  • 9903.81.89: Derivative iron or steel products listed in subdivision (l) (existing steel derivative articles subject to Section 232).
  • 9903.81.90: Derivative iron or steel products listed in subdivision (m) (new steel derivative articles classified in Chapter 73 subject to Section 232). - 25% additional duty
  • 9903.81.93: (FTZ specific) Derivative products of iron or steel, as specified in subdivisions (l) and (m) (existing derivative steel products, and new derivative steel products in Chapter 73) admitted to a U.S. foreign trade zone under “privileged foreign status” before March 12, 2025, and entered for consumption on or after March 1, 2025. – 25% additional duty. 
  • 9903.81.92: Derivative steel or iron products listed in subdivision (m) or (n) (new derivative steel articles) where the derivative iron or steel product was processed in another country from steel articles that were melted and poured in the United States. – 0% additional duty. 
    • HTS 9903.81.92 also applies to such goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before March 12, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after March 12 (see Foreign Trade Zone section below).
  • 9903.81.91: Derivative iron or steel products listed in subdivision (n) (new steel derivative articles not classified in Chapter 73 subject to Section 232): the import duty is on the value of the steel content.
    • 9903.81.91 also applies to such goods that were admitted to a U.S. foreign trade zone and granted “privileged foreign status” before March 12, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after a date to be certified in the Federal Register by the Secretary of Commerce

 

Click here to view or download the "List of Steel HTS Subject to Section 232".

 

FTZ – Foreign-Trade Zone 

  • Goods admitted into the zone on, or, after March 12,2025 (except for domestic goods) must be admitted in “privileged foreign status” and will be subject at time of entry to any duties in place at time of admission. 
  • Unlike aluminum, any steel or derivative steel article (with the exception of domestic goods) previously granted “privileged foreign status” prior to March 12, 2025, will also be subject upon entry to additional duties. 
  • Tariffs to be used are indicated above under the “Provisional Tariff Breakdown,” as well. 
    • 9903.81.88: Iron or steel products (including those classified under GAEs). 
    • 9903.81.93: All iron or steel derivative products, except as noted below:  
      • 9903.81.91: Iron or steel derivative products classified outside of Chapter 73. 
      • 9903.81.92: Iron or steel derivative products with a melt and pour of United States

 

Melt and Pour Reporting Requirements:

  • The reporting of the country of melt and pour and applicability code is mandatory for both steel and steel derivatives. 
  • To report the country of melt and pour, importers must report the International Organization for Standardization (ISO) code on steel articles and derivative steel articles subject to Section 232. 
  • For steel articles, importers must report the ISO code where the steel was originally melted and poured. 
  • For steel derivatives, importers must report the ISO code where the steel was originally melted or “OTH” (for other countries). 
  • For products melted and poured in the United States, importers must indicate “US” as the country of melt and pour.

 

References:

 

March 7 2025 - Duties Delayed on Goods from MX and CA That Qualify Under USMCA

 

Trump announces tariffs on goods from MX and CA that qualify under USMCA are exempt from duties.

 

On March 6, 2025, President Trump announced adjustments to tariffs imposed on imports from Canada and Mexico in recognition of the structure of the automotive supply chain that strives to bring production into America.

 

As of 12:01 am EST on March 7, 2025, the new International Emergency Economic Powers Act (IEEPA) duties on goods from Canada and Mexico, for the time being are:

 

  • 25% tariffs on goods that do not satisfy U.S.-Mexico-Canada Agreement (USMCA) rules of origin.
  • A lower 10% tariff on those energy products imported from Canada that fall outside the USMCA preference.
  • A lower 10% tariff on any potash imported from Canada and Mexico that falls outside the USMCA preference.
  • No tariffs on those goods from Canada and Mexico that claim and qualify for USMCA preference.
  • The following new HTSUS classification applies to products that qualify for USMCA. 

 

Canada:

9903.01.14: Articles that are entered free of duty under the terms of general note 11 to the HTSUS, including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTS, as related to the USMCA.

 

Potash

Effective on or after 12:01 a.m. eastern standard time March 7, 2025, potash that is the product of Canada entered for consumption or withdrawn from warehouse for consumption is exempt from the additional duty rates that were implemented March 4, 2025, if the potash qualifies for USMCA. If the potash does not qualify for USMCA, it will be subject to an additional 10% duty as opposed to the 25% under 9903.01.10.

 

The following new HTSUS classification applies to potash that does not qualify for USMCA and for which the additional 10% duty applies:

 

9903.01.15: Potash that is a product of Canada, as provided for in U.S. note 2(I) to this subchapter.

 

Mexico:

9903.01.04: Articles that are entered free of duty under the terms of general note 11 to the HTSUS, including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTS, as related to the USMCA.

 

Potash

Effective on or after 12:01 a.m. eastern standard time March 7, 2025, potash that is the product of Mexico entered for consumption or withdrawn from warehouse for consumption is exempt from the additional duty rates that were implemented March 4, 2025, if the potash qualifies for USMCA. If the potash does not qualify for USMCA, it will be subject to an additional 10% duty as opposed to the 25% under 9903.01.01.

 

The following new HTSUS classification applies to potash that does not qualify for USMCA and for which the additional 10% duty applies:

 

9903.01.05:  Potash that is a product of Mexico, as provided for in U.S. note 2(c) to this subchapter.

 

The applicable HTSUS subheadings for potash are as follows:

2815.20.0050

2815.20.0090

3104.20.0010

3104.20.0050

3104.30.0000

3104.90.0100

3105.10.0000

3105.20.0000

3105.60.0000

 

There is currently no published expiration date for the USMCA exemption.

 

References:

CSMS # 64336037 - GUIDANCE – Update on Additional Duties on Imports from Canada – USMCA Qualifying Products and Potash

CSMS # 64335789 - GUIDANCE – Update on Additional Duties on Imports from Mexico - USMCA Qualifying Products and Potash

Amendment to Duties to Address the Flow of Illicit Drugs Across Our Northern Border – The White House

Amendment to Duties to Address the Flow of Illicit Drugs Across Our Southern Border – The White House

Fact Sheet: President Donald J. Trump Adjusts Tariffs on Canada and Mexico to Minimize Disruption to the Automotive Industry


 

 

March 4 2025 - Increases to China, Canada, and Mexico Tariffs

 

Shortly before 5 p.m., on March 3, 2025, President Donald Trump issued an Executive Order (EO) raising tariffs on China and Hong Kong from 10% to 20%, citing insufficient efforts to curb drug smuggling. In addition, on March 3, 2025, U.S Customs and Border Protection (CBP) issued notices regarding the implementation of 25% tariffs on most goods from Canada and all goods from Mexico. 

 

Key Takeaways

 

  • IEEPA Tariffs for goods from CN/HK increase from 10%-20% effective March 4, 2025 
  • 25% IEEPA Tariffs in place for goods from CA and MX effective March 4, 2025 
  • Drawback not allowed for IEEPA tariffs 

  • De-minimis currently available until further notice

     

China / Hong Kong IEEPA Increase - Update to tariffs, increase from 10% to 20%  

 

  • As directed by the EO, CBP is updating the additional duties from 10% to 20% and implementing a new Chapter 99 HTSUS number. 
  • 9903.01.20: All imports of articles that are products of China and Hong Kong, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, and other than products for personal use included in accompanied baggage of persons arriving in the United States, will be assessed an additional ad valorem rate of duty of 10%. This applies to products of China and Hong Kong, loaded on vessel at port of loading or in transit on final mode of transit to US on or after February 1, 2025, and entered for consumption, or withdrawn from warehouse for consumption before March 4, 2025. 
  • 9903.01.24: All imports of articles that are products of China and Hong Kong, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, and other than products for personal use included in accompanied baggage of persons arriving in the United States, will be assessed an additional ad valorem rate of duty of 20%. This will now apply to goods that are the products of China and Hong Kong, loaded on vessel at port of loading or in transit on final mode of transit to US on or after February 1, 2025, and entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern standard time March 4, 2025. Tariff available in ACE.  
  • Exclusions: 
  • 9903.01.21: Articles the product of China and Hong Kong 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. 
  • 9903.01.22: Articles the product of China and Hong Kong 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. 
  • 9903.01.23: Except for products described in headings 9903.01.21 and 9903.01.22, and other than products for personal use included in accompanied baggage of persons arriving in the United States, articles the product of China and Hong Kong that: (1) were loaded onto a vessel at the port of loading, or in transit on the final mode of transport prior to entry into the United States, before 12:01 a.m. eastern standard time on February 1, 2025; and (2) are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern standard time on February 4, 2025, and before 12:01 a.m. eastern standard time on March 7, 2025. 
  • Foreign-Trade Zone – Goods that “are admitted into a United States foreign trade zone on or after 12:01 a.m. Eastern Standard Time on February 4, 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 not available for IEEPA tariffs.  

  • De-minimis continues to be available until further notice. 

     


 

Loaded on Vessel at Port of Loading or In Transit on Final Mode of Transit to US 
Entered for Consumption or Withdrawn from Warehouse 
CN IEPPA HTS 
CN IEPPA Duty Rate 
Prior to February 1, 2025 
Between February 4, 2025 – March 7, 2025 
9903.01.23 
0% 
On or after February 1, 2025 
Before March 4, 2025 
9903.01.20 
10% 
On or after February 1, 2025 
On or after March 4, 2025 
9903.01.24 
20% 

References: 

Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People's Republic of China – The White House 

 

CSMS # 64299816 - UPDATE – Additional Duties on Imports from China and Hong Kong 

 

Canada IEEPA Tariffs 

 

  • Effective on or after 12:01 a.m. Eastern Standard Time on March 4, 2025, with respect to goods that are the product of Canada entered for consumption, or withdrawn from warehouse for consumption, the following HTSUS classifications and additional duty rates apply: 
  • 9903.01.10:  All imports of articles that are products of Canada, other than products classifiable under headings 9903.01.11, 9903.01.12, and 9903.01.13, and other than products for personal use included in accompanied baggage of persons arriving in the United States, will be assessed an additional ad valorem rate of duty of 25%. Tariff available in ACE. 
  • 9903.01.13:  Imports of energy or energy resources of Canada, as defined in section 8 of Executive Order 14156 of January 20, 2025 (Declaring a National Energy Emergency) as: crude oil, natural gas, lease condensates, natural gas liquids, refined petroleum products, uranium, coal, biofuels, geothermal heat, the kinetic movement of flowing water, and critical minerals, as defined by 30 U.S.C. 1606 (a)(3) will be assessed an additional ad valorem rate of duty of 10%. Tariff available in ACE. 
  • Exclusions: 
  • 9903.01.11:  Articles the product of Canada 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. Tariff available in ACE. 
  • 9903.01.12:  Articles the product of Canada 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. Tariff available in ACE. 
  • Free Trade Agreement - Products of Canada that are eligible for special tariff treatment under general note 3(c)(i) to the tariff schedule (e.g., the United States-Mexico-Canada Agreement), or that are eligible for temporary duty exemptions or reductions under subchapter II to chapter 99, are subject to the additional ad valorem rate of duty imposed by headings 9903.01.10 and 9903.01.13.  
  • The additional duties imposed by headings 9903.01.10 and 9903.01.13 that apply to products of Canada include both goods of Canada under the rules of origin set forth in part 102 (with a Country of Origin CA,) title 19 of the Code of Federal Regulations, as applicable, as well as goods for which Canada was the last country of substantial transformation prior to importation into the United States.  
  • Foreign-Trade Zone - Goods that “are admitted into a United States foreign trade zone on or after 12:01 a.m. Eastern Standard Time on March 4, 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 not available for IEEPA tariffs.  
  • De-minimis continues to be available until further notice.  
  • Chapter 98 exemptions with exclusions. 

 

Reference:  

 CSMS # 64297449 - GUIDANCE: Additional Duties on Imports from Canada 

 

 

Mexico IEEPA Tariffs 

 

  • Effective on or after 12:01 a.m. Eastern Standard Time on March 4, 2025, with respect to goods that are the product of Mexico entered for consumption, or withdrawn from warehouse for consumption, the following HTSUS classification and additional duty rate apply: 
  • 9903.01.01: All imports of articles that are products of Mexico, other than products classifiable under headings 9903.01.02 and 9903.01.03 and other than products for personal use included in accompanied baggage of persons arriving in the United States will be assessed an additional ad valorem rate of duty of 25%. Tariff available in ACE. 
  • Exclusions: 
  • 9903.01.02:  Articles the product of Mexico 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. Tariff available in ACE. 
  • 9903.01.03:  Articles the product of Mexico 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. Tariff available in ACE. 
  • Free Trade Agreement- Products of Mexico that are eligible for special tariff treatment under general note 3(c)(i) to the tariff schedule (e.g., the United States-Mexico-Canada Agreement), or that are eligible for temporary duty exemptions or reductions under subchapter II to chapter 99, are subject to the additional ad valorem rate of duty imposed by headings 9903.01.01.  
  • The additional duties imposed by headings 9903.01.01 that apply to products of Mexico include both goods of Mexico under the rules of origin set forth in part 102, title 19 of the Code of Federal Regulations, as applicable, as well as goods for which Mexico was the last country of substantial transformation prior to importation into the United States.  
  • Drawback not available for IEEPA tariffs.  
  • De-minimis continues to be available until further notice.  
  • Chapter 98 exemptions with exclusions.  

 

Reference: 

CSMS # 64297292 - GUIDANCE: Additional Duties on Imports from Mexico 

 

Feb 18 2025 - Increases to U.S. steel and aluminum tariffs - Effective March 12, 2025

 

GEODIS wants to keep you informed about significant changes to U.S. Section 232 tariffs on steel and aluminum imports, which will impact global trade operations beginning March 12, 2025. 

 

Key takeaways

 

  • All existing country exemptions for Section 232 steel and aluminum tariffs will be eliminated
  • Steel and aluminum tariffs will be set at 25% for imports into the U.S.
  • No new tariff exclusions will be granted; existing exclusions are valid until expiration or volume completion, whichever occurs first.
  • New derivative products will be subject to tariffs (specific lists pending) (list is available under Annex I of the Federal Register)
  • Additional documentation requirements for U.S.-processed materials

 

Detailed information

 

Steel Tariff Changes:

 

  • Effective March 12, 2025, existing alternative agreements will be terminated for: Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, South Korea, the U.K., and Ukraine
  • The Section 232 steel tariff exclusion process is ending:
    • No new exclusions will be considered or renewed
    • Existing exclusions remain valid until expiration or volume completion, whichever occurs first.
    • All general product exclusions terminate March 12
  • New 25% tariff on additional steel derivative products (implementation pending Commerce Department systems readiness)
  • For derivatives outside Chapter 73, tariffs will apply only to aluminum content
  • Exemption available for derivatives processed from U.S.-melted and poured steel, with required CBP documentation
  • The Federal Register has been published which includes the steel derivative HTS under Annex I
  • Importers of derivatives will be required to provide CBP information necessary to identify the steel content used in the manufacture of the articles
  • CBP shall prioritize reviews of the classification of imported steel articles and derivative steel articles and, in the event that it discovers misclassification resulting in loss of revenue of the ad valorem duties proclaimed herein, it shall assess monetary penalties in the maximum amount permitted by law

 

 

Aluminum Tariff Changes:

 

  • Tariff rate increases to 25% on March 12, 2025 for all countries except Russia
  • Effective March 12, 2025, exemptions and quota agreements will be terminated for: Argentina, Australia, Canada, Mexico, the EU, and the U.K.
  • The Section 232 aluminum tariff exclusion process is ending:
    • No new exclusions will be considered or renewed
    • Existing exclusions remain valid until expiration or volume completion, whichever occurs first
    • All general product exclusions terminate March 12
  • New 25% tariff on additional aluminum derivative products (implementation pending Commerce Department systems readiness)
  • Derivative articles in Annex I from Russia where any amount to of primary* aluminum is smelted or cast in Russia is subject to 200% duties.
    • Primary aluminum is defined as new aluminum metal that is produced from alumina (or aluminum oxide) by the electrolytic Hall-Heroult process.
  • For derivatives outside Chapter 76, tariffs will apply only to aluminum content
  • Exemption available for derivatives made from U.S.-smelted and cast aluminum, with required CBP documentation
  • The Federal Register has  been published which includes the aluminum derivative HTS under Annex I
  • Importers of derivatives will be required to provide CBP information necessary to identify the aluminum content used in the manufacture of the articles
  • CBP shall prioritize reviews of the classification of imported aluminum articles and derivative aluminum articles and, in the event that it discovers misclassification resulting in loss of revenue of the ad valorem duties proclaimed herein, it shall assess monetary penalties in the maximum amount permitted by law

 

Additional Provisions:

 

  • Producers and trade associations may request additions to the derivative products list for both steel and aluminum
  • Implementation of certain derivative tariffs pending Commerce Department system updates
  • No new exclusions will be granted or renewed for either steel or aluminum

 

GEODIS customs brokerage and trade advisory teams are closely monitoring these developments and will provide updates as additional information becomes available.

 

References: Presidential Proclamation, White House Fact Sheet.

 

February 7, 2025 - De Minimis Exemption Temporarily Reinstated for China and Hong Kong

 

On February 5, 2025, President Donald Trump issued an Executive Order amending a previous order from February 1, 2025, which had removed the de minimis exemption for goods of China and Hong Kong valued under $800.

The amendment reinstates the de minimis exemption temporarily, allowing duty-free entry for eligible low-value packages until the Secretary of Commerce confirms that adequate systems are in place to efficiently process and collect the applicable tariffs.

This move aims to provide time for the Commerce Department to establish procedures to manage inspections and levy collections on these shipments

 

Feb 5 2025 - U.S. Tariffs on Canada and Mexico are Paused, China Tariffs Remain

 

On February 1, 2025, President Trump announced major changes to U.S. tariff policies affecting trade with Canada, Mexico, and China. The Trump Administration announced these changes via Executive Orders (EOs) under the International Emergency Economic Powers Act (IEEPA).

 

Since making this announcement, the planned tariffs on Canada and Mexico have been paused for 30 days while leaders from the U.S., Mexico, and Canada negotiate stronger border controls and other matters. New tariffs on China are in place.

 

Key Takeaways

 

  • New U.S. tariffs on Canadian goods were set at 25% (10% for energy products), Chinese goods at 10%, and Mexican goods at 25%
  • Mexican and Canadian tariffs have been temporarily suspended for 30 days pending agreement on border security measures
  • De minimis exemptions are revoked for all affected countries, which is currently just China
  • U.S. tariffs on China took effect on February 4, 2025, at 12:01 AM Eastern Time
  • China has announced counter tariffs on some U.S. goods coming into China
  • Canada’s plans to implementing 25% surtax / tariffs on $30 billion worth of U.S. goods are currently on hold

 

New U.S. Tariff Rates

The additional tariff rates originals established by the United States were:

 

  • Canada: 25% on all goods, with energy products at 10% (on hold for 30 days)
  • Mexico: 25% on all goods (on hold for 30 days)
  • China: 10% on all goods


 

These rates apply in addition to existing Section 301, 232, 201, Antidumping, and Countervailing duties.

 

Other impacts of U.S. Tariffs

The Executive Orders make further changes to tariff arrangements beyond the increase in tariff rates:

 

  • De minimis exemptions: Revoked for China, Canada (temporarily paused), and Mexico (temporarily paused)
  • Drawback: Not permitted on goods subject to these EO duties (currently China)

 

Foreign-Trade Zones (FTZ) Operations

Products subject to additional tariffs may be admitted into Foreign Trade Zones (FTZs) but must enter under "Privileged Foreign Status" or have duties and tariffs paid before being received in Domestic Status.

 

Mexico and Canada Tariff Suspension

The  U.S. has temporarily paused the 25% tariff increase on Mexican imports for 30 days. The U.S. has also temporarily paused Canadian tariffs for 30 days.