Update | Reciprocal Tariffs

Written By Steve Perez

Updated April 11, 2025

On April 2, 2025, Executive Order 14257, titled “Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits,” was issued. This order imposes additional duties on imports, with tariffs ranging from a baseline of 10% ad valorem duty to country-specific rates as high as 50%.

The following summary outlines the implementation and impact of these additional tariffs:

1| General Additional Duty:

  • Effective April 5, 2025, at 12:01 EDT a 10% ad valorem duty will apply to all imports (HTSUS 9903.01.25), unless exceptions are specified.

2 | Country Specific Duty:

  • Higher additional duties are imposed on imports from specific countries, ranging from 11% to 50%, based on Annex I and U.S. Note 2 to Subchapter III of Chapter 99 of the HTSUS. These duties take effect on April 9, 2025, unless exceptions are specified. 

3| Product Specific Exemptions:

  • Certain goods are exempt from additional duties, including:

    • 9903.01.32 – Specific goods listed in Annex-II.pdf (e.g., certain minerals, chemicals, and wood products, etc.).

    • 9903.01.33 – Section 232 Iron & Steel Products – (9903.81.87, 9903.81.88, 9903.81.89, 9903.81.90, 9903.81.91, 9903.81.92, 9903.81.93)

    • 9903.01.33 – Section 232 Aluminum Products – (9903.85.02, 9903.85.04, 9903.85.07, 9903.85.08, 9903.85.09)

    • 9903.01.33 – Section 232 Automotive Products - Passenger vehicles, light trucks, and their parts (9903.94.01–9903.94.05) are exempt.

    • 9903.01.30 – Products donated by U.S. persons for humanitarian purposes (e.g., food, clothing, medicine) to relieve human suffering are exempt unless the President determines they impair national emergency efforts, respond to coercion, or endanger U.S. Armed Forces. 

    • 9903.01.31 – Informational materials such as publications, films, posters, photographs, and digital media are exempt.

    • Products for personal use included in accompanied baggage of persons arriving in the U.S. are exempt.

4 | Special Provisions:

  • 9903.01.28 – Goods in transit before the effective dates are exempt.

    • All goods loaded onto a vessel from any country at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on April 5, 2025, are exempt from this additional duty. 

    • Goods loaded onto a vessel from country specific reciprocal tariffs at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on April 9, 2025, are exempt from the additional ad valorem duties imposed by the executive order. 

  • Products from Canada and Mexico are currently exempt from additional duties under the United States-Mexico-Canada Agreement (USMCA), including those entered under subchapter XXIII of Chapter 98 and subchapter XXII of Chapter 99 of the HTSUS.:

    • Canada – 9903.01.26

    • Mexico – 9903.01.27

  • In the event of the termination of Executive Order 14227 of March 2, 2025 (Amendment to Duties To Address the Situation at our Southern Border) and/or Executive Order 14231 of March 2, 2025 (Amendment of Duties To Address the Flow of Illicit Drugs Across Our Northern Border), the following rules are applicable:

    • Canada:

      1. 9903.01.36 – USMCA eligible goods remain exempt.

      2. 9903.01.35* – 12% additional duties should no other exemption apply.

    • Mexico:

      • 9903.01.40 – USMCA eligible goods remain exempt.

      • 9903.01.39** – 12% additional duty should no other exemption apply.

  • 9903.01.34 – US Origin Content:  Products with at least 20% of their customs value derived from U.S.-originating components are exempt from additional duties on the U.S. content portion.​ Duties apply only to the non-U.S. content U.S. Customs and Border Protection (CBP) will verify U.S. content and other exemptions. 

5 | Modification Authority:

  • The Secretary of Commerce and U.S. Trade Representative can recommend adjustments to duties based on effectiveness, retaliation, or compliance by trading partners. 

6 | Reporting:

  • Recurring and final reports on the national emergency and trade actions will be submitted to Congress.

7 | China/Hong Kong:

  • There is no provision within the Executive Order that excludes:

    • Section 301 (7.5% or 25%)

    • IEEPA – Addressing the Synthetic Opioid Supply Chain (20%)

    • If imported goods are subject to Section 301(9903.88.01), and factoring in existing IEEPA, the total duty rate will be 79%.

8 | Countries that import Venezuelan oil:

 

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Steve Perez
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Additional Tariffs on Countries Importing Venezuelan Oil