May 1st, 2025 – International Emergency Economic Powers Act (IEEPA) Frequently Asked Questions
Applicability of In Transit Provisions for Reciprocal Duties Under IEEPA: Important!
This table provides guidance for entries that qualify for the in-transit provision under Reciprocal Tariffs, which applies to vessels only. The importer is responsible for confirming a shipment qualifies for the in-transit provisions. Please refer to the most recent guidance provided by CBP as tariff rates are subject to change.
| Date Goods Loaded onto a Vessel at the Port of Loading and in Transit on the Final Mode Transport | Date Goods Entered for Consumption or Withdrawn from Warehouse for Consumption into the U.S. | Secondary HTSUS Classification for Reciprocal Tariff | Reciprocal Tariff Duty Rate | Notes |
| Before April 5, 2025 | On and after April 5, 2025, and before May 27, 2025 | 9903.01.28 | Excepted from reciprocal tariffs | – |
| On or after April 5, 2025, through April 8, 2025 | Prior to May 27, 2025 | 9903.01.25 | 10% | Applies unless the shipment qualifies for another exception from the reciprocal tariffs |
| April 9, 2025 | Prior to May 27, 2025 | 9903.01.25 | 10% | Only applies to products of China, including products of Hong Kong and Macau, unless the shipment qualifies for another exception from the reciprocal tariffs |
This table provides additional guidance concerning applicability of the in-transit provisions. The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation; they do not apply to other modes of transportation such as air, rail, truck, etc. As defined in 19 U.S.C. 1401 and 19 CFR 4.0, vessel includes every description of watercraft or other contrivance used or capable of being used as a means of transportation on water but does not include aircraft. The in-transit provisions do not apply when the shipment begins by vessel and then arrives in the United States using a different final mode of transportation, often referred to as transloading.
For entries transported other than by vessel that were filed using HTS 9903.01.28, filers should take immediate action to correct such entries, as necessary, as soon as possible. For those entries that have been filed with CBP erroneously using HTS 9903.01.28, importers should correct the entry summary by filing a post summary correction.
Guidance is available through the Cargo Systems Messaging Service (CSMS). CSMS postings are available here.
Should you have any questions or concerns, please contact our Import Compliance team or give us a call at 518-785-6000.
