Updates to U.S. tariffs

U.S. – Japan trade deal tariff impact

On September 4, 2025, the White House signed an executive order to implement a trade agreement reached between the U.S. and Japan. The full details will not be available until the Department of Commerce publishes its Federal Register notice and Customs and Border Protection issues its communication with entry filing instructions. In the meantime, here is a summary of the executive order.

IEEPA reciprocal:

Effective retroactively to August 7, 2025, the duty rate for products of Japan will be determined by a product’s current regular HTSUS Column 1 (MFN) rate of duty. If the MFN rate of duty is equal to or less than 15%, then the reciprocal HTS number will be 15% and the regular HTS number will be 0%. If the MFN rate of duty is greater than 15%, then the reciprocal HTS number will be 0% and the regular HTS number rate of duty will apply. The current reciprocal rate of duty for Japan is 15%. If an importer paid more than 15% combined reciprocal and MFN, they will be eligible to apply for a refund through a PSC or protest after CBP provides its guidance.

Natural resources unavailable (or unavailable at sufficient scale to satisfy domestic demand in the U.S.), generic pharmaceuticals, generic pharmaceutical ingredients, and generic pharmaceutical chemical precursors will be exempt for IEEPA reciprocal tariffs. The list of HTSUS numbers is unknown at this time but may be reflected in the new Annex III list published September 5, 2025 in a separate executive order.

Civil aircraft:

Effective on the date of the Commerce Federal Register notice, products of Japan that fall under the Civil Aircraft Agreement, except for unmanned aircraft, will be exempt from the following trade remedy tariffs:

• IEEPA Reciprocal
• Section 232 Aluminum
• Section 232 Aluminum
• Section 232 Copper

Autos / auto parts:

Effective on the date of the Commerce Federal Register notice, products of Japan that are on the Section 232 auto/auto parts lists will be granted a Section 232 rate based on the same rules as the reciprocal rate rather than 25%. If the regular rate of duty is equal to or less than 15%, then the Section 232 HTS number will be 15% and the regular HTS number will be 0%. If the regular rate of duty is greater than 15%, then the Section 232 HTS number will be 0% and the regular HTS number rate of duty will apply.

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Reciprocal tariffs Annex II list modified and new Annex III list announced (September 8, 2025)

On September 5, 2025, the White House signed an executive order to modify the Annex II list that is applied to IEEPA reciprocal tariffs.

Effective Date: September 8, 2025

Current List: Annex II

Some products were added, such as certain critical minerals, bullion-related articles, and certain pharmaceutical products. A few products were removed, namely, aluminum hydroxide, resin, and silicone products. Importers should review the new list to determine if their products are impacted.

The list also provides for an Annex III list that will be implemented with certain countries as individual trade deals are finalized and if the country is granted benefits associated with this list. This list includes natural resources that are not naturally available or produced in the U.S., civil aircraft products, and generic pharmaceuticals. Importers should review this list and determine if their products are impacted. Then watch for the list to be made available in the future for specific countries.

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IEEPA Russian oil tariff implementation for India (August 29, 2025)

On August 25, 2025, CBP issued guidance regarding the Executive Order that implemented a new IEEPA tariff on products of India origin to address the purchase of oil from Russia.

Key details:

Effective Entry Date: August 27, 2025

Country of Origin: India

IEEPA Duty Rate: 25%

Chapter 99 Number: 9903.01.84

There is an in-transit exemption, using 9903.01.85:

• Applies only to ocean shipments.
• Must be loaded onto the vessel before 12:01 a.m. ET on August 27, 2025.
• Vessel must be the final mode of transportation – in other words, the vessel destined to the U.S. Feeder vessels don’t count.
• Must be entered for consumption before 12:01 a.m. ET on September 17, 2025.

Other exemptions:

• 9903.01.86 - articles on the Annex II IEEPA Reciprocal exemption list as noted in HTSUS Chapter 99, Subchapter III, U.S. Note 2(v)(iii)
• 9903.01.87 - used if Section 232 duties are actually paid for iron or steel, aluminum, autos, auto parts, or copper
• 9903.01.88 - donations
• 9903.01.89 - informational articles

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Department of Commerce adds steel and aluminum articles to Section 232 lists (August 18, 2025)

On August 15, 2025, the Department of Commerce, Bureau of Industry (BIS) posted a notice scheduled to be published on Tuesday, August 19, 2025 in the Federal Register. BIS added 407 HTSUS subheadings to the lists subject to Section 232 Steel/Aluminum tariffs that are effective August 18, 2025. CBP issued a corresponding guidance regarding the entry declaration of these additional HTS numbers on the steel and aluminum lists. CBP attached the full list of subject HTSUS numbers in its messages. The new HTS numbers are in bold to distinguish them from the existing numbers. It is vital that all importers review these lists to determine if they import subject products.

Many of these numbers are on both lists so both steel and aluminum must be reported as applicable. If the product contains both steel and aluminum, the importer must report both the steel and aluminum Chapter 99 numbers and pay Section 232 duties on both.

If the importer can provide the weight and value of the steel/aluminum, they may report the article in two entry summary lines to pay Section 232 duties on only the steel/aluminum content. IEEPA Reciprocal is only exempted on the steel/aluminum line and must be paid on the non-aluminum line. If the importer is unable to break out the weight and value of the aluminum, the Section 232 duties must be paid on the full value of the merchandise.

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IEEPA Brazil tariff implemented (August 8, 2025)

On August 1, 2025, CBP issued guidance regarding the Executive Order that implemented a new IEEPA tariff on products of Brazilian origin.

Key details:

Effective Entry Date: August 6, 2025

Country of Origin: Brazil

IEEPA Brazil Duty Rate: 40%

Chapter 99 Number: 9903.01.77

There is an in-transit exemption, using 9903.01.78:

• Applies only to ocean shipments.
• Must be loaded onto the vessel before 12:01 a.m. ET on August 6, 2025.
• Vessel must be the final mode of transportation – in other words, the vessel destined to the U.S. Feeder vessels don’t count.
• Must be entered for consumption before 12:01 a.m. ET on October 5, 2025.

Other exemptions:

• 9903.01.79 - donations
• 9903.01.80 - informational articles
• 9903.01.81 – Annex I and II of the EO provide the comprehensive list of HTS numbers at the 8-digit level for products such as Brazil nuts, orange juice, energy products, iron ore, pig iron, tin oxide/chloride, potash, fertilizer, wood pulp, siler, and gold.
• 9903.01.82 - civil aircraft, engines, parts, and ground flight simulators and parts - Annex I and II of the EO provide the comprehensive list of HTS numbers at the 8-digit level. The articles must meet the criteria of General Note 6 of the HTSUS, regardless of whether a product is entered with SPI C. Thus, if the article is classified in a cited HTS number but is not used in civil aircraft, it is not eligible for the exemption.
• 9903.01.83 – used if Section 232 duties are actually paid for iron or steel, aluminum, autos, auto parts, or copper.

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IEEPA reciprocal tariffs amended (August 1, 2025)

The White House signed an Executive Order late on July 31, 2025, amending the IEEPA Reciprocal tariffs effective at 12:01 a.m. ET on August 7, 2025.

Further Modifying the Reciprocal Tariff Rates – The White House

Rather than assigning a Chapter 99 number to a rate, this time each country with a specific rate has its own new Chapter 99 number. The number and associated rate can be found in Annex II to the Executive Order.

There is an in-transit exception:

• Applies only to ocean shipments.
• Must be loaded onto the vessel before 12:01 a.m. ET on August 7, 2025.
• Vessel must be the final mode of transportation – in other words, the vessel destined to the U.S. Feeder vessels don’t count.
• Must be entered for consumption before 12:01 a.m. ET on October 5, 2025.

 

IEEPA fentanyl duty rate increases for Canadian products

On July 31, 2025, CBP issued an update to provide guidance regarding the President’s Executive Order issued on July 31, 2025 regarding the IEEPA Fentanyl duty rate increase from 25% to 35%.

Key details:

• Effective Entry Date: August 1, 2025 – 12:01 a.m. EDT
• Country of Origin: Canada
• IEEPA Fentanyl Duty Rate: 35%
• Chapter 99 Number: 9903.01.10
• USMCA-Eligible Goods: Not subject to payment of the duties by reporting 9903.01.14
• Other Exclusions Continued: 9903.01.11 (donations), 9903.01.12 (informational articles), 9903.01.13 (energy at 10%), 9903.01.15 (potash at 10%

 

New Section 232 copper duties

On July 31, 2025, CBP issued an update to provide guidance regarding the new duties ordered on copper and copper derivative articles in accordance with the President’s July 30, 2025 Proclamation.

Effective Entry Date: August 1, 2025 – 12:01 a.m. EDT

Product: Copper and copper derivatives – nearly all of Chapter 74 + electrical conductors

Section 232 Duty Rate: 50%

Chapter 99 numbers:

• 9903.78.01 = 50% on the copper content of semi-finished copper and intensive copper derivative products.
• 9903.78.02 = 0% on the non-copper content of semi-finished copper and intensive copper derivative products; and goods that contain no copper.

Should you have any questions or concerns, please reach out to your local DSV representative.

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U.S. and Vietnam announce trade agreement (July 3, 2025)

As of July 3, 2025, the U.S. President announced an upcoming trade agreement between the United States and Vietnam.

Key details of agreement

• 20% tariff on Vietnamese imports to the U.S.: According to CNBC, Vietnam will pay a flat 20% tariff on its goods entering the U.S., down from the previously imposed 46% and higher than the temporary 10% during negotiations.
• 40% tariff on trans-shipment: Any goods originating outside Vietnam (e.g., China) but routed through Vietnam to evade tariffs will have a 40% tariff implemented.
• 0% tariffs for U.S. exports to Vietnam: U.S. products will enter Vietnam duty-free.
• SUVs (Large Engine Vehicles): The agreement specifically encourages U.S. SUV manufacturers to export to Vietnam.
• No trans shipping: A strict two-tier tariff aims to avoid relabeling or minimal processing practices in Vietnam.
• Framework pending formalization: Important to communicate that while the framework has been announced, formal terms, rules of origin, enforcement mechanisms, and timelines are pending.
• Scope for context:
  • This is part of a broader “reciprocal tariff” strategy ahead of a July 9 deadline.
  • The agreement builds on earlier agreements with the U.K. and China during the 90 day pause on tariffs.

DSV remains watchful and will provide the official notices via the Federal Register when available. If you have any questions regarding import compliance or tariff classifications, please contact your local DSV representative.

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UK automotive and aerospace products receive preferential tariff treatment (June 30, 2025)

Effective Monday, June 30, 2025, automotive and aerospace products that are the origin of the United Kingdom receive preferential trade remedy tariff treatment. The Federal Register notice was published June 30, 2025 and CBP issued its filing instructions. Associated eligible HTSUS numbers are included in both publications.

Key details

• Tariff-rate quota on automobiles.
• Preferential tariff treatment for automotive parts of passenger vehicles and light trucks.
  • Section 232 Auto Parts – declare 9903.94.32 for 10% rate.
  • When paying Section 232 Auto Parts, the goods are excluded from paying IEEPA Reciprocal tariffs and Section 232 Stee/Aluminum tariffs.
• Preferential tariff treatment for certain civil aircraft and aircraft parts that meet the criteria of the Agreement on Trade in Civil Aircraft and classifiable in the listed HTSUS numbers.
  • Declare 9903.96.01 to receive preferential treatment of trade remedy duties.
  • Eligible goods are excluded from IEEPA Reciprocal tariffs and Section 232 Steel/Aluminum tariffs.
  • Continue to claim SPI “C” to claim the preferential treatment of regular duties.

Should you have any questions or concerns, please reach out to your local DSV representative.

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CBP requires "unknown" code for aluminum origin, imposing 200% duty rate (June 25, 2025)

Effective June 28, 2025, if an importer does not know the country of primary and/or secondary smelt or the country of cast for the aluminum, the code “UN” must be reported to indicate “unknown”. HTSUS number 9903.85.67 for aluminum articles or 9903.85.68 for derivative aluminum articles must be declared and the importer must pay the associated 200% rate of duty applicable to Russia. CBP issued the new instructions here on June 13, 2025.

Importers must report the primary country of smelt and/or secondary country of smelt; and report the country of cast. Country of smelt and cast are identified on the aluminum certificate of analysis for aluminum articles. For derivative aluminum articles, the importer must work through the supply chain to ascertain the required information.

• Primary country of smelt = largest volume of new aluminum metal produced from alumina (or aluminum oxide) by the electrolytic Hall-Heroult process.
• Secondary country of smelt = second largest volume of new aluminum metal.
• Country of cast = last liquified by heat and cast into a solid state, which may be a semi-finished or finished aluminum product.

These new instructions replace the current permission to report any country other than the United States in accordance with CBP’s guidance on its Section 232 Tariffs on Steel and Aluminum FAQ website.

If an importer can ascertain the correct country of smelt and cast in the future, and can provide the documentary evidence of such to CBP, a post-summary correction or protest may be filed to request a refund. Should you have any questions or concerns, please reach out to your local DSV representative.

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Department of Commerce adds household appliances to Section 232 steel tariffs (June 16, 2025)

In a Federal Register notice, the Department of Commerce Bureau of Industry and Security (BIS) announced the inclusion of household appliances under the Section 232 Steel Derivatives tariffs effective June 23, 2025.

The following steel derivative products will be subject to Section 232 for the steel content:

1. Combined refrigerator-freezers under HTSUS subheading 8418.10.00;
2. Small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;
3. Washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;
4. Dishwashers under HTSUS subheading 8422.11.00;
5. Chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;
6. Cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;
7. Food waste disposals under HTSUS subheading 8509.80.20;
8. Welded wire rack under statistical reporting number 9403.99.9020. Products classified under 9403.99.9020 continue to be subject to Section 232 duties for their aluminum content. Products on both lists are subject to payment of duties for both steel and aluminum content.

The HTSUS numbers are added to HTSUS Chapter 99, Subdivision III, Note 16(n), for steel derivative products outside of Chapters 72 and 73, declared with HTSUS 9903.81.91 when the steel is not melted and poured in the U.S.

The BIS Section 232 inclusion process allows U.S. manufacturers and trade associations to request the inclusion of new derivative articles under Section 232 Steel and Aluminum tariffs. Inclusions may be submitted during three defined periods each year with the first period opening May 1, 2025 and closing June 4, 2025. Should you have any questions or concerns, please reach out to your local DSV representative.

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Steel and aluminum tariffs increase to 50% (June 4, 2025)

The White House has doubled the tariffs on steel and aluminum imports from 25% to 50%, effective June 4, 2025. A proclamation issued the day prior outlines how the increase impacts steel and aluminum imports under Section 232 authority.

Key details:

• Steel, aluminum, and articles under Section 232 already stored in U.S. trade zones under “privileged foreign status” before June 4 will pay the tariff rate in effect when they entered the commerce of the U.S.
• The non-aluminum, non-steel content of all Section 232 aluminum and steel articles and derivative articles shall be subject to tariffs.
• The applicable tariff rates for articles of the United Kingdom pursuant to Proclamation 9704, as amended; Proclamation 9705, as amended; Proclamation 9980, as amended; Proclamation 10895; and Proclamation 10896 shall remain at 25%.

If you have any questions regarding import compliance or tariff classifications, please contact your local DSV representative.

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U.S. court strikes down IEEPA tariffs (May 29, 2025)

On May 28, 2025, the U.S. Court of International Trade ruled that the White House’s sweeping tariffs imposed under the International Emergency Economic Powers Act (IEEPA) exceeded presidential authority and are therefore unlawful.

Key ruling details

The three-judge panel concluded that the IEEPA does not authorize a U.S. president to levy universal duties on imports from around the world. The court specifically found that the White House’s "Worldwide and Retaliatory Tariff Orders" exceeded the scope of presidential power under the emergency economic powers statute.

This ruling specifically targets only the IEEPA-based tariffs. Other White House administration trade measures remain unaffected, including:

• Section 232 tariffs (national security-based duties)
• Section 301 tariffs (unfair trade practice duties)
• Other tariffs imposed under different statutory authorities

White House files appeal

The White House has already filed an appeal on the Court of International Trade decision. The case will now proceed to the U.S. Court of Appeals for the Federal Circuit, with the possibility of eventual Supreme Court review. The appeal process could take months or years to resolve.

Despite the court ruling, no immediate changes are expected in tariff collection. The additional IEEPA duties are expected to continue being collected by U.S. Customs and Border Protection while the appeal works its way through the federal court.

Should you have any questions or concerns, please reach out to your local DSV representative.

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U.S. / China agreement reduces tariffs and ends retaliatory measures (May 12, 2025)

On May 12, 2025, the White House announced a new agreement with China to lower Chinese tariffs, end retaliatory measures, maintain a baseline US tariff, and initiate future talks to expand market access for American exports.

U.S. actions

• The U.S. will reduce tariffs on Chinese imports from 145% to 30%.
• The new 30% rate is the sum of the 20% duty the current administration imposed early in its second term over alleged Chinese failures to curb fentanyl flows and the 10% universal tariff he has applied to nearly all imports.

Chinese actions

• China will lower its retaliatory tariffs on U.S. goods from 125% to 10%.
• China has agreed to remove retaliatory tariffs announced since April 4, 2025, and suspend non-tariff countermeasures imposed on the US since April 2, 2025. China will also suspend the initial 34% tariff on the U.S. from April 4, 2025 for 90 days, retaining a 10% tariff during that period.

Implementation timeline

Both countries have committed to implementing these measures by May 14, 2025.

Despite these reductions, it's important to note that goods traded between the U.S. and China will still be subject to other stackable tariffs that remain in place. The agreement addresses only reciprocal retaliatory measures while leaving the broader tariff structure intact.

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White House reduces tariff stacking with retroactive executive order (May 2, 2025)

On April 29, 2025 , The White House issued an executive order aimed at reducing the cumulative impact of overlapping tariffs on certain trade remedies. This action addresses the "tariff stacking" effect that has occurred over the past 100 days, while maintaining the administration's core policy objectives.

Impacted trade regimes:

• Canadian IEEPA Goods: Goods subject to the International Emergency Economic Powers Act (IEEPA) from Canada.
• Mexican IEEPA Goods: Goods subject to the IEEPA from Mexico.
• Auto and Auto Parts (Section 232): Vehicles and automotive parts that fall under the Section 232 tariffs, which are imposed for national security reasons.
• Steel and Steel Derivatives (Section 232): Steel products and their derivatives that are subject to Section 232 tariffs.
• Aluminum and Aluminum Derivatives (Section 232): Aluminum products and their derivatives that are also subject to Section 232 tariffs.

Additionally, the proclamation modifies the tariff action on automobiles and automobile parts by encouraging manufacturers to assemble their vehicles in the U.S. This will be achieved by offsetting a portion of the tariffs for auto parts used in U.S. assembled vehicles.

In general, goods subject to Section 232 tariffs will be excluded from reciprocal tariffs. However, each importer’s business is unique, and the impact of this executive order will vary depending on your specific situation. Therefore, we encourage you to reach out to your local DSV representative to clarify and maximize the benefits.

Fact sheet

CBP - Visual fact sheet

CBP - Section 232 Tariffs on Steel & Aluminum FAQ's

CBP - IEEPA Tariffs FAQ's

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Semiconductor exemptions for reciprocal tariffs (April 14, 2025)

On April 11, 2025, The White House clarified the exceptions for semiconductors on reciprocal tariffs under Executive Order 14257, which was initially issued on April 2, 2025. The specific provisions excluded from the tariffs fall under the following Harmonized Tariff Schedule of the United States (HTSUS) headings and subheadings:

• 8471
• 847330
• 8486
• 85171300
• 85176200
• 85235100
• 8524
• 85285200
• 85411000
• 85412100
• 85412900
• 85413000
• 85414910
• 85414970
• 85414980
• 85414995
• 85415100
• 85415900
• 85419000
• 8542

Importers are encouraged to update any entries previously filed to request a refund for tariffs collected on these semiconductor products after April 5, 2025.

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90-day pause on increase of reciprocal tariffs (April 10, 2025)

On April 9, 2025, the White House announced a 90-day pause on the increase of reciprocal tariffs.

• 90-day pause on the increase of reciprocal tariffs.
• Tariffs remain at 10% for all countries except China.
• For China, tariffs will be raised to 125% (reciprocal) + 20% (IEEPA).

Effective April 10, 2025, the De Minimis tariff Increase from China extends the previous executive orders aimed at addressing trade imbalances and national security concerns. The key changes are:

• Section 2(c)(i): Ad valorem duty rate increased from 90% to 120%.
• Section 2(c)(ii): Per postal item duty increased from $75 to $100, effective from May 2, 2025, to June 1, 2025.
• Section 2(c)(ii): Per postal item duty further increased from $150 to $200, effective from June 1, 2025.

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Implementation of reciprocal tariffs (April 3, 2025)

The U.S. government has announced new reciprocal tariffs. In an executive order issued on April 2, 2025, the White House outlined a phased implementation of these tariffs, which will apply to imports from all countries. These tariffs will be applied in two phases:

• April 5, 2025, at 12:01 AM ET – A 10% tariff on all imported goods from all countries.
• April 9, 2025, at 12:01 AM ET – An additional country-specific tariff rate, as detailed in Annex l of the executive order.

How these tariffs work

These new tariffs are in addition to any existing tariffs imposed under previous trade measures. This means that products already subject to duties—such as those under Section 301 (China tariffs) or Section 201 (safeguard tariffs on specific goods like solar panels and washing machines)—will now also face the new reciprocal tariffs unless specifically exempted. (Source: executive order, Section 3c – and may include other sections)

Exceptions to the tariffs

There are exceptions for goods from any countries if previously loaded onto a vessel, see exceptions noted in Annex III. Additionally, certain goods of above sections will not be subject to these additional tariffs. Highlights include:

• Articles protected under 50 U.S.C. 1702(b).
• Steel and aluminum products already subject to Section 232 tariffs under the Trade Expansion Act of 1962.
• Automobiles and automotive parts covered by previous Section 232 duties.
• Specific exempted goods, including copper, pharmaceuticals, semiconductors, lumber, critical minerals, and energy products (see Annex II for full details).
• Goods from trading partners listed in Column 2 of the Harmonized Tariff Schedule of the United States (HTSUS).
• Future products that may be subject to duties under Section 232.

List of countries with reciprocal tariffs
List of goods not subject to the additional tariffs

Impact on trade with Canada and Mexico

Trade with Canada and Mexico remains subject to IEEPA orders, meaning:

• USMCA-compliant goods will continue to be tariff-free (0%).
• Non-USMCA-compliant goods will maintain a 25% tariff.
• Non-USMCA-compliant energy and potash will be subject to a 10% tariff.

Elimination of China’s de minimis treatment

On April 2, 2025, the White House signed an executive order terminating Section 301 low value de minimis treatment for imports from China and Hong Kong, effective May 2, 2025, at 12:01 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.

Resources

For more details on the rationale behind these measures, refer to:

• White House Executive Order on Reciprocal Tariffs
• White House Fact Sheet
• Country rates
• 2025 National Trade Estimate Report on Foreign Trade Barriers
• IEEPA orders
• USMCA

Should you have any questions or concerns, please reach out to your local DSV representative.