New Executive Orders & Regulations

International Emergency Economic Powers Act (IEEPA) Tariffs

• Imposed on February 4, 2025, at 10%, increased to 20% on March 4, 2025, with additional reciprocal tariffs up to 84% starting April 5, 9.
• 90-Day Pause for Reciprocal Tariffs effective April 10, 2025, reducing rates to 10% for all countries, except China which was increased to 125%
• Not eligible for duty drawback.
• Example total duty burden: COO:CN HTS = 7%, Sec 301 = 25%, IEEPA = 20%, Reciprocal = 125% → Total = 177%

In-Transit Provision

U.S. Customs and Border Protection (CBP) provided guidance on its IEEPA webpage concerning the applicability of the in-transit provision. The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation and do not apply to other modes of transportation such as air, rail, truck, etc.

De Minimus Elimination

• Effective May 2, 2025, goods < $800 from China or Hong Kong are no longer allowed.
• Still applies to goods from other countries.
• Carriers must report shipment data to CBP; possible future expansion to Macau.

Section 232 Tariffs

• Steel and aluminum: 25% duty effective March 12, 2025, applies to HTS Chapters 73 & 76, including derivatives.
• Automobiles & Parts:
  • Cars: 25% from April 3, 2025
  • Parts: 25% from May 3, 2025
  • USMCA-eligible autos: Tariff applies only to non-U.S. content
  • Misstatements: Subject to retroactive tariffs and clawback provisions

In the Federal Register, U.S. CBP provided instructions for importers, customs brokers, and filers about submitting import entries for the 25% tariffs on certain automobile parts from all countries. The 25% tariff will take effect with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on May 3rd.

Tariff Rates by Country

Please reference the complete list here.