Trade War 2025 Resource Center

Only Section 301 and the reciprocal IEEPA are eligible for drawback.

Section 232 (steel, aluminum, auto) Fentanyl IEEPA (Canada, Mexico, China & Hong Kong) are NOT eligible for drawback.

No. Goods entered into a bonded warehouse are not subject to duties until they are withdrawn for consumption and enter U.S. commerce.

Good subject to reciprocal tariffs must be admitted into a Foreign Trade Zone under privileged foreign status. This ensures that, if goods are later entered into U.S. commerce, they will be subject to the duties and tariff rates that were in effect at the time of FTZ admission – based on their classification under the applicable HTSUS subheading.

In most cases, yes – new tariffs will be compounded with existing duties. However, there are exceptions. Specifically, Reciprocal IEEPA tariffs and Section 232 tariffs are mutually exclusive and will not be applied together on the same goods.

The value to be declared for the steel/aluminum content should be based on the actual value of the steel or aluminum, as it was invoiced from the mill that produced it.  Such an invoice may be the type of supporting documentation Customs might request to substantiate it. 

As long as the transshipment was a part of the shipment’s itinerary to the US, then the exemption would apply according to the feeder vessel’s details at the port of origin.

No. Goods moving under in-bond status – meaning they are under U.S. Customs control but not entered for consumption – are generally not subject to reciprocal tariffs, as long as they are not withdrawn for consumption in the U.S.

Additionally, the Executive Order includes a savings clause stating that goods loaded onto a vessel and in transit on their final mode of transport before April 5, 2025 (for the 10% baseline tariff) or before April 9, 2025 (for country-specific tariffs) are exempt from the new duties, even if they enter the U.S. afterward.

This exemption primarily applies to goods transiting through the U.S. without entering U.S. commerce.

Effective April 10, 2025, most imports from China – including goods from Hong Kong and Macau, unless specifically excluded – will be subject to a 125% Reciprocal IEEPA additional duty under HTSUS 9903.01.63. This is in addition to any existing tariffs already in place, such as Section 301 and Fentanyl-related IEEPA tariffs.

Please note that this situation is fluid and subject to further clarification or change.

The increased Reciprocal tariff is in effect only for China, Hong Kong, and Macau. The country-specific increased rates for the other countries have been paused for 90 days, meaning almost all countries are currently subject to the base Reciprocal tariff of 10% (exceptions are China, Hong Kong, Macau, Canada, Mexico, Republic of Belarus, Cuba, North Korea, and Russian Federation).

Key points to note:
-Exemptions: Standard IEEPA exemptions still apply.
-Effective Dates: Vary depending on the specific tariff measure.
-In-Transit Clause: The latest Executive Order changed the in-transit exception criteria to more clearly reflect that goods must be in transit before the effective date to qualify for exemption.

We are awaiting formal confirmation and clarification from U.S. Customs and the administration. Until then, it is safest to assume the new language applies strictly and to review all China-origin shipments carefully.

The posted bond must be sufficient to cover the inclusion of relevant Section 301 and Section 232 duties, but not Fentanyl IEEPA duties. Confirmation of the inclusion of Reciprocal IEEPA duties is still pending.

Please note that if a continuous Customs bond limit is not sufficient to cover the required amount, a single transaction bond for the difference will need to be issued.

Yes. U.S. goods that are exported, undergo processing or value-added work abroad, and are then re-imported are generally subject to reciprocal tariffs. However, the tariff is applied to only the foreign value added – not to the original U.S.-origin value.

Details:
– Value-Added Basis:
The reciprocal tariff applies to the portion of the goods value that was added during processing, repair, or assembly in the foreign country.

–Example:
A U.S. made item worth $5000 is exported and repaired overseas for $1000. Upon re-importation, the reciprocal tariff would apply only to the $1000 repair cost.

–Exceptions:
Some items may be exempt, such as those falling under Section 232 exclusions or USMCA-Compliant Goods.

–Tariff Calculation:
The duty rate is based on the reciprocal tariff schedule, which mirrors the rates that foreign governments impose on similar U.S. exports.

If the transaction qualifies for the first sale rule, and an invoice earlier in the supply chain is being used, this will lower the dutiable value of the merchandise and, consequently, the applicable duties, fees, and taxes.

There is a 3-part test to determine if the rule applies to a shipment:
1. The goods are clearly destined for export to the United States,
2. The manufacturer and the middleman deal each other at arm’s length, and
3. There is the absence of any non-market influences that affect the legitimacy of the sales price.

To see if merchandise qualifies for the use of the first sale rule, it is recommended to seek the guidance of a trade attorney.

If you are unsure of the value breakdown of aluminum or steel content in a derivative product, Section 232 duties will apply to the full value of the product. If you are unsure of melt & pour (steel) or smelt & cast (aluminum) for derivative products – OTH can be entered for country of melt & pour for steel and any country other than the United States if the filer does not know the country of smelt or cast for aluminum. Importers may submit a post-summary correction to update the country of smelt or cast or melt & pour when they obtain information on the actual country(ies) of smelt or cast or melt & pour.

Importers must now consider multiple layers of potential tariffs beyond the standard duty rate including section 301 tariffs, IEEPA tariffs, Section 232 tariffs on steel/aluminum and derivatives, Auto tariffs and more. It is more important than ever to review tariff exposure on a case by case basis. Reach out to your LOGISTEED contact for additional assistance.

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A. Please reach out to your LOGISTEED account representative or contact your local LOGISTEED America branch to talk with a customs brokerage expert.

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