Reciprocal Tariff Act Resources for Customs Brokers & Logistics Professionals: How To Navigate the Policy Changes

Updated 8/29/2025: Federal Circuit Court rules Trump’s IEEPA-based tariffs illegal but stays enforcement until October 14.

Updated 8/27/2025: India begins redirecting exports post-50% tariffs announcement; warnings of nearly halved garment industry growth.

Updated 8/18/2025: Section 232 tariffs expanded to 50% on new steel/aluminum categories

Updated 8/7/2025: Reciprocal Tariffs Fully Activated

Updated 8/1/2025: Trump’s executive order imposes new tariffs on 66–69 countries, with immediate enforcement for Canada and crop‑specific rates for India (25%), South Africa (30%), Taiwan (20%) and others. Markets drop sharply amid weak jobs data and investor concern.

Updated 7/22-23/2025: Bilateral Trade Deals

Updated 7/8/2025: President Trump imposed new tariffs on 14 countries, including Bangladesh, Japan, and South Korea. Simultaneously, a 'mini trade deal' with India was announced, aiming to strengthen bilateral trade relations.

Updated 6/23/2025: New guidance on specific HS codes issued 6/16/2025.

Updated 5/30/2025: The Trump administration's appeal to uphold tariffs through IEEA was granted. Liberation Day tariffs are still currently in effect. Read the court's judgemet here: https://www.cafc.uscourts.gov/opinions-orders/25-1812.ORDER.5-29-2025_2522636.pdf

Updated 5/29/2025: US District judge Rudolph Conteras ruled yesterday Trump's use of the IEEA act to establish tariffs was illegal and an overreach of presidential power. Read the full judgement here: https://storage.courtlistener.com/recap/gov.uscourts.dcd.279804/gov.uscourts.dcd.279804.35.0.pdf

Updated 4/16/2025: new updates per latest White House fact sheet including tariffs on China at 245%.

Summary of the IEEPA Reciprocal tariffs:

• 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 a.m. ET on April 5. 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 U.S.

• 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 a.m. ET on April 9. 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 U.S.

• President Trump issued two executive orders on April 2 invoking the International Economic Emergency Powers Act (IEEPA) authority.

  • Imposing a minimum universal tariff on all countries of 10%, except as noted below, although some countries are having an even greater reciprocal tariff.

  • Eliminating de minimis/section 321 eligibility for Chinese goods.

• Updates to the Harmonized Tariff Schedule included in the White Houses' Annex 3.

On Mexico & Canada

Goods from Canada and Mexico are exempt from the IEEPA Reciprocal tariffs until such time as the IEEPA Border 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.

Modification Situations to Tariffs (Tariff Increases or Decreases):

• 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.

On Tariff Exemptions

April 2nd List of Automotive Parts Subject to Section 232 Tariffs

Exceptions: Products Excluded from Additional IEEPA Reciprocal Tariff

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 are exempted:

• Copper

• Pharmaceuticals

• Semiconductors,

• Lumber

• Certain critical minerals

• Energy and energy products

On Cars & Automotive

232 Autos and Auto Part Annex Released

The full proclamation with the Annex was released today.

• Autos: Effective 12:01 a.m. ET, April 3, 25% tariffs shall apply to certain autos and light trucks.

• Parts: Effective 12:01 a.m. ET, May 3, 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.

On Duty Drawback

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

Additions to Tarrifed Items

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 a.m. ET, April 4.

The products are:

• Beer, classified in HTSUS 2203.00.00; and

• Empty aluminum cans classified in HTSUS 7612.90.10

Additional Resources:

• National Customs Brokers & Forwarders Association of America's Website

• White House Annex 1 - Additional Country-Specific Reciprocal Tariffs

• White House Annex 2 - Commodities Excluded from Tariffs

• White House Annex 3 - Updates to HS Codes

• The subreddit's sidebar links were updated

4/10/2025 Update: New Guidance from US Customs & Border Protection on Reciprocal Tariffs

This update provides new guidance on additional tariffs for imported goods following three recent Executive Orders (April 2, 8, and 9, 2025) concerning reciprocal tariffs to address trade deficits and foreign retaliation.

Key Updates:

• Imports from China (including Hong Kong and Macau):

• Effective April 10, 2025, at 12:01 a.m. ET

• Subject to a 125% additional ad valorem duty

• Classified under HTSUS 9903.01.63

• Exceptions are listed in prior CSMS #64680374.

Imports from all other countries (excluding China, Hong Kong, and Macau):

• Also effective April 10, 2025

• Subject to a 10% additional ad valorem duty

• Classified under HTSUS 9903.01.25

• Excludes products listed in HTSUS 9903.01.26–9903.01.34.

Suspension of Country-Specific Rates: Rates effective April 9, 2025, are now suspended.

4/16/2025 Update: New White House tariff policy and fact sheet announced:

Fact Sheet: President Donald J. Trump Ensures National Security and Economic Resilience Through Section 232 Actions on Processed Critical Minerals and Derivative Products

1. New Section 232 Investigation:

President Trump has ordered a Section 232 investigation under the Trade Expansion Act of 1962 to assess national security risks tied to U.S. dependence on imported processed critical minerals and their derivative products.

The goal is to examine supply chain vulnerabilities, foreign market manipulation, and recommend actions like tariffs or other trade remedies to boost domestic production and resilience.

2. National Security and Economic Threats:

Critical minerals (e.g., rare earths, gallium, antimony) are vital for defense systems, infrastructure, and advanced technologies.

The U.S. remains heavily reliant on foreign—especially Chinese—suppliers, exposing it to economic coercion and supply disruptions.

Recent Chinese export bans on rare earths and other key materials underscore the urgent need to secure domestic supply chains.

3. Tariff Policy and Broader Trade Strategy:

If the investigation finds national security threats, new Section 232 tariffs may replace current reciprocal tariffs under Trump’s April 2nd directive.

This order aligns with Trump’s broader “America First” trade agenda, which includes:

• A 10% base tariff and individualized higher tariffs on major trade deficit partners.

• Paused tariffs for 75+ countries in talks for new trade deals (except China).

• China faces up to 245% tariffs, including penalties tied to fentanyl and digital policies.

• Restored and increased tariffs on steel and aluminum.

• Related investigations into copper, timber, and lumber imports for national security threats.

5/13/2025: Updated Guidance Post US/China Tariff Deal

Full Executive Order

Joint Statement

Temporary Tariff Reduction (Section 2)

Effective May 14, 2025, all goods from the PRC, including Hong Kong and Macau, will face a 10% ad valorem duty instead of previously higher rates.

This reflects a suspension of 24 percentage points from the prior tariff rate, originally set at 34%, for an initial 90-day period.

Harmonized Tariff Schedule Modifications (Section 3)

Changes are made to several tariff classifications (HTSUS headings 9903.01.25, 9903.01.63, and relevant notes), reflecting the new lower duty rate.

The 125% duty rate on certain items is suspended and temporarily replaced with 34%.

Implementation and Oversight (Section 5)

The Departments of Commerce, Homeland Security, and USTR are authorized to enforce this order, including via temporary regulation changes.

Coordination with agencies including Treasury, State, and the National Security Council is mandated.

General Provisions (Section 6)

The order does not override existing agency authorities, nor does it create enforceable rights.

The Department of Commerce will cover publication costs.

Update - 6/23/2025: New Updates from Federal Register Issued 6/16/2025:

The Department of Commerce Bureau of Industry and Security (BIS) announced the inclusion of household appliances under the Section 232 Steel Derivatives tariffs effective June 23, 2025.

The following steel derivative products will be subject to Section 232 for the steel content:

• Combined refrigerator-freezers under HTSUS subheading 8418.10.00;

• Small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;

• Washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;

• Dishwashers under HTSUS subheading 8422.11.00;

• Chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;

• Cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;

• Food waste disposals under HTSUS subheading 8509.80.20;

Welded wire rack under statistical reporting number 9403.99.9020. Products classified under 9403.99.9020 continue to be subject to Section 232 duties for their aluminum content. Products on both lists are subject to payment of duties for both steel and aluminum content.

The HTSUS numbers are added to HTSUS Chapter 99, Subdivision III, Note 16(n), for steel derivative products outside of Chapters 72 and 73, declared with HTSUS 9903.81.91 when the steel is not melted and poured in the U.S.

The BIS Section 232 inclusion process allows U.S. manufacturers and trade associations to request the inclusion of new derivative articles under Section 232 Steel and Aluminum tariffs. Inclusions may be submitted during three defined periods each year with the first period opening May 1, 2025 and closing June 4, 2025.

Read the full Federal Register notice here.

Updated 7/8/2025: President Trump imposed new tariffs on 14 countries, including Bangladesh, Japan, and South Korea. Simultaneously, a 'mini trade deal' with India was announced, aiming to strengthen bilateral trade relations.

These tariffs are part of President Trump's broader strategy to enforce reciprocal trade policies aimed at protecting U.S. economic interests.

Updated 7/10/2025: President Trump announces a 50% tariff on Brazilian imports, citing political concerns

Trump administration expanded its tariff measures by issuing formal notices to eight more countries, bringing the total to 22 nations. These letters outlined new reciprocal tariff rates effective August 1, 2025. Notable adjustments include:

• Brazil: Tariff increased to 50%, citing concerns over digital trade practices and alleged attacks on democratic institutions.

• Cambodia: Tariff reduced from 49% to 36%.

• Japan: Tariff set at 25%, a slight increase from the initial 24%.

• Philippines: Tariff raised to 20%, up from the previous 17%.

These tariffs are in addition to the existing 10% baseline tariff and are part of the broader "Liberation Day" tariff strategy.

Updated 7/22 to 7/23/2025: President Trump announces a 50% tariff on Brazilian imports, citing political concerns

Japan: Finalized a major trade agreement reducing reciprocal tariffs from 25% to 15%, alongside a $550 billion Japanese investment in the U.S. economy.

Indonesia: Concluded a bilateral agreement on July 23, cutting U.S. reciprocal tariffs from 32% to 19%, with Indonesia removing non-tariff barriers and aligning regulatory standards.

August 1, 2025: Trump’s executive order imposes new tariffs on 66–69 countries, with immediate enforcement for Canada and crop‑specific rates for India (25%), South Africa (30%), Taiwan (20%) and others. Markets drop sharply amid weak jobs data and investor concern.

Major U.S. Trade Actions Take Effect

• Executive Order Signed (Late July 31)
  President Trump signed an executive order imposing steep new tariffs on 66–69 countries, including the EU, India, Taiwan, Brazil, Canada, South Africa, and others. These tariffs range broadly—some as high as 41%—and were scheduled to begin August 7, though Canadian tariffs (35%) activated on August 1 due to special fentanyl-related measures.

• Tariff Scope & Country Rates

  • Canada: 35% duties on most goods, tied to fentanyl tensions.

  • India: 25% tariffs initiated.

  • South Africa: 30% rate applied.

  • Taiwan: 20% duty enacted.
    Several countries were exempted or negotiated reduced rates (e.g. Cambodia, Lesotho, Madagascar).

August 7, 2025 Reciprocal Tariffs Fully Activated

Updated tariff rates and enforcement rules kicked in. Notably, goods caught transshipping to evade duties are now subject to a 40% duty. The U.S. Customs and Border Protection (CBP) also issued new guidance for European goods. Meanwhile, a 50% tariff on Indian imports is scheduled for August 27, unless India halts its oil trade with Russia.

August 18, 2025 Section 232 tariffs expanded to 50% on new steel/aluminum categories

U.S. expanded its steel and aluminum tariffs to include 407 additional finished goods. This extension ramps up costs further for navigating metal-intensive manufacturing imports.

August 27, 2025 India begins redirecting exports post-50% tariffs announcement; warnings of nearly halved garment industry growth.

In response to the 50% U.S. tariffs (effective August 27), Indian exporters, particularly from garments, rice, and jewelry sectors, are actively redirecting shipments to alternative global markets. Analysts warn the tariffs could nearly halve revenue growth in India’s ready-made garment industry year-over-year, affecting financial stability and creditworthiness.

August 29, 2025 Federal Circuit Court rules Trump’s IEEPA-based tariffs illegal but stays enforcement until October 14.

Federal Circuit Court ruled in V.O.S. Selections, Inc. v. Trump that President Trump exceeded his authority by imposing sweeping tariffs using the International Emergency Economic Powers Act (IEEPA). Although the tariffs were deemed illegal, the ruling was stayed until October 14, allowing them to remain in effect during the appeals process.

Updated Tariff rates as of August 27, 2025