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.
SCHEDULE A 30 MINUTE CONSULTATION ON US!
Email Us: team@junocustoms.com