2025: Navigating the Changing Trade Environment

US importers should stay informed and prepare for potential disruptions and rising costs as Trump’s tariff proposals move forward.

Executive Actions & Measures

Overview of Presidential Authority & Provisions

Congress has enacted multiple laws that empower the President to independently impose tariffs.

China

  • Additional 60% - 100% tariffs on goods from China

  • Revocation of China’s Permanent Normal Trade Relations (PNTR) Status (HTS Rate of Duty US Column 1 to Column 2)

Mexico & Canada

  • 25% - 75% tariffs on Mexico/Canada to crack down on immigration and fentanyl

  • 100% tariffs on automobiles made in Mexico

All Countries

  • Blanket 10% - 20% tariffs on goods from all countries

 

Required Investigation | No

Trade Act of 1974, Sec 122

  • Impact: Tariffs up to 15% for 150 days

  • Potential Deployment: High

Revoke China’s PNTR | Requires Congress.

  • Impact: Increase in tariffs

  • Potential Deployment: Possible

Tariff Act of 1930, Sec 338 | Requires proof the US is being discriminated against vis-à-vis other nations.

  • Impact: Additional duties up to 50%, ban in imports, 3rd country action

  • Potential Deployment: Possible

International Emergency Economic Powers Act of 1977 (IEEPA)/Trading with the Enemy Act of 1917, Sec. 5(b)(1)(B) | Consultation with Congress and declaration of a National Emergency required.

  • Impact: Virtually all trade powers vested to President

  • Potential Deployment: Likely

 

Required Investigation | Yes

Trade Act of 1974, Sec 301

  • Impact: Tariffs and Quotas

  • Potential Deployment: High

  • For China, the investigation was completed during the first Trump Administration and any subsequent actions could be amendments to current tariff rates.

Trade Expansion Act of 1962, Sec. 232(b)

  • Impact: Tariffs and Quotas

  • Potential Deployment: Possible

Trade Act of 1974, Sec. 201

  • Impact: Duties, other measures

  • Potential Deployment: Less Likely

 

Strategic Measures (3 R's)

Remediate

  • Tariff Engineering & Strategic Sourcing

  • Monitor Federal Trade Registers

  • Participate in opportunities to provide public comments & advocate for reductions in tariffs via exclusions.

Reduce Impact

  • Entry Valuation

    • First Sale (Nissho Iwai American Corp. v. United States, 982 F.2d 505 (Fed. Cir. 1992))

    • CBP Reconciliation Program

  • Duty Deferral

    • Bonded warehouse

    • Foreign Trade Zones

    • Duty Payments

      • Pay duties via Periodic Monthly Statements (PMS)

      • Apply for an ACH payer unit number. CBP Form 400

      • Notify your bank to ensure they recognize CBP as an ACH party.

      • Avoid CBP Liquidated Damages. Ensure your bank limitations set for ACH withdrawals are sufficient.

Recover

  • Post Summary Corrections

  • Protests

  • 520(d)

  • Duty Drawback Program

 

We have your back!

We’ve got you covered. We understand the challenges these proposed tariffs may bring, and as your trusted partner, we will work closely with you to adjust your strategies and stay compliant throughout.

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