IMPORTANT: Please note that the information provided below may be subject to change or clarification when the full notices with Annexes are available, the Federal Register Notice (FRN) has been published and/or the CSMS from CBP has been sent to the ports for implementation. Until a Federal Register Notice is published and/or a CSMS is officially issued by CBP and sent to the ports for implementation, the following information is supposition and subject to change. Previous FRN’s and CSMS Messages differ from previously issued Executive Orders.

President Trump issued two executive orders today invoking the International Economic Emergency Powers Act (IEEPA) authority (also attached)

1. imposing a minimum universal tariff on all countries of 10%, except as noted below, although some countries are having an even greater reciprocal tariff , and
2. eliminating de minimis/section 321 eligibility for Chinese goods.

In addition, the following notices were released:

1. the list of products that are subject to the section 232 tariffs on passenger vehicles/light trucks and auto parts. (attached)
2. The Bureau of Industry and Security (BIS) at the Department of Commerce added two new products to the list of derivative aluminum articles.

IEEPA – Reciprocal Tariffs

A summary of the IEEPA Reciprocal tariffs is included below.

IEEPA authority based on threat caused by trade-in-goods deficits.

Except as noted below, all imported articles are subject to a 10% ad valorem IEEPA duty effective 12:01 am EDT April 5, 2025. For goods that are loaded onto a vessel at the port of lading and in final mode of transit before that time, they will NOT be subject to the 10% duty upon entry into the US.

Certain countries (Listed in Annex I) are subject to a tariff greater than 10%. For purposes of these tariffs, China includes Hong Kong and Macau.

The rates for countries in Annex I shall apply effective 12:01 am EDT on April 9, 2025. For goods that are loaded onto a vessel at the port of lading and in final mode of transit before that time, they will NOT be subject to the additional duty specified below upon entry into the US.

Exceptions: Products Excluded from Additional IEEPA Reciprocal Tariff

The additional duty will not apply to:

• Goods exempted under 50 U.S.C. 1702 (Goods that are for personal use, donations of food, clothing and medicine intended to relieve human suffering, Merely informational materials, etc.).
• The following products subject to existing 232 tariffs are exempt:
  • Steel and derivatives
  • Aluminum and derivatives
  • Autos/auto parts

• The following products, and any others listed in Annex II attached, are exempted:
  • Copper
  • Pharmaceuticals
  • Semiconductors,
  • Lumber
  • Certain critical minerals
  • Energy and energy products

• Products from countries subject to Column 2 duty rates are exempted (Cuba, North Korea, Russia, and Belarus)
• Products subject to future section 232 actions will be exempted (Note: section 232 rates will apply to the imported article and in some instances may be lower than the IEEPA reciprocal tariffs.)
• Goods from Canada and Mexico are exempt from the IEEPA Border tariffs until such time as the Border IEEPA is terminated or suspended, at which time only USMCA qualifying goods will be exempt from IEEPA Reciprocal tariffs and non-USMCA goods will be subject to a 12% IEEPA Reciprocal tariff.
• The value of US content of any goods provided that the US content is no less than 20% of the value of the article. “US content” is defined as “the value of an article attributable to the component produced entirely, or substantially transformed in, the US.”
• Section 321 de minimis goods other than those country of origin China (Hong Kong)—see below—are exempt until such time as Commerce establishes a system to collect the tariffs.

FTZ Goods

Products admitted to an FTZ after 12:01 eastern on April 9, must be admitted in privileged foreign status.

Goods eligible for admission to an FTZ under domestic status are exempt from the tariffs

Modification (Increase or Decrease)

• INCREASE
  • If a country retaliates against US goods as a result of these tariffs, the President may increase or expand the scope of the tariffs.
• DECREASE
  • If a country remedies the non-reciprocal trade arrangements, the President my decrease or limit the scope of the tariffs.

Duty Drawback

• There is no express prohibition to claiming duty drawback on these tariffs.

De Minimis For China

• Non-International Postal Shipping:
  • Goods that are country of origin China (including Hong Kong) that are shipped by any means other than by international postal network – are ineligible for Section 321/de minimis effective 12:01 am EDT May 5, 2025. Packages from Macau remain eligible for de minimis but a recommendation for extending the prohibition to Macau is to be issued within 90 days.
  • All entries must be made by an entity qualified to make entry using formal or informal entry in the Automated Commercial Environment (ACE)

• International Postal Shipping:
  • Goods that are country of origin China (Hong Kong) that are shipped by international postal networks that would otherwise be eligible will be subject to a duty rate equal to either:
    • 30% of their value effective 12:01 am EDT May 2, 2025.
    • or $25 per item effective 12:01 am EDT May 2, 2025 – before 12:01 am EDT June 1, 2025.
    • Or $50 per item effective 12:01 am EDT June 1, 2025
  • Carriers transporting the international postal package must pay the duties owed.
  • Carriers must report the total number of postal items containing goods and specify if the 30% duty or the $25/50 rate of duty is applied. Additional documentation and information may be required by CBP.
  • These duties are in lieu of the MFN, the IEEPA Drug tariffs and section 301 tariffs.
  • Carriers transporting goods must have an international carrier bond.
  • CBP may require formal entry for international postal packages in which case they will be subject to the duties applied to non-international postal shipped goods.

232 Autos and Auto Part Annex Released

The full proclamation with the Annex was released today. (See update sent March 27, 2025 for additional details on these tariffs).

• Autos: Effective 12:01 am EDT April 3, 2025, 25% tariffs shall apply to certain autos and light trucks.
• Parts: Effective 12:01 am EDT May 3, 2025, 25% tariffs shall apply to auto parts, defined as automobile parts including engines and engine parts, transmissions and powertrain parts, and electrical components, and parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks classified under the HTS provisions enumerated in subdivision (g) of the Annex.

BIS Adds Products to Aluminum Derivatives List

Bureau of Industry and Security added two items to its Aluminum Derivatives List today which will be subject to the 25% tariff effective 12:01 am EDT April 4, 2025.

The products are:

• beer, classified in HTSUS 2203.00.00; and

empty aluminum cans classified in HTSUS 7612.90.10