August 7th, 2025 – The following summarizes updated guidance on the application of additional duties under Executive Order 14257, as amended by the July 31, 2025, EO, “Further Modifying the Reciprocal Tariff Rates.” These updates detail applicable tariff classifications, exemptions, reporting requirements, and enforcement measures effective August 7th, 2025.
General Application
Effective Date: Applies to entries on or after 12:01 a.m. EDT, August 7, 2025.
Affected Goods: Products from countries listed in Annex I of the EO (excluding exceptions) are subject to HTSUS headings 9903.02.02 – 9903.02.71.
EU Products:
≥15% Column 1 duty → No additional duty, classified under 9903.02.19.
<15% Column 1 duty → Increased to total 15%, filed under 9903.02.20.
China-Specific
China (including Hong Kong and Macau) remains under 10% reciprocal tariff, heading 9903.01.25 per EO 14298.
Exemptions
In-Transit (before Aug 7, 2025, arriving by Oct 5, 2025) → subject to 10% tariff, heading 9903.01.25.
9903.01.26: Products of Canada, even if entered duty-free under USMCA.
9903.01.27: Products of Mexico, even if entered duty-free under USMCA.
9903.01.29: Products of Column 2 countries (e.g., Belarus, Cuba, North Korea, Russia).
9903.01.30: Donations of food, clothing, medicine to relieve human suffering.
9903.01.31: Informational materials (e.g., books, films, CDs, artwork).
9903.01.32: Specific classified articles per Annex III of EO 14257 and April 11, 2025 Presidential Memo.
9903.01.33: Section 232 items, including steel, aluminum, copper, autos, and parts.
9903.01.34: Goods with ≥20% U.S. content – reciprocal duty applies only to non-U.S. content.
Chapter 98 Treatment
Exempt from IEEPA duties except entries under:
Subchapter XIX (AGOA) – 9819
Subchapter XX (CBTPA) – 9820
Subchapter XXII (Other FTAs) – 9822
9802.00.40/.50/.60/.80
TIB Entries (9813): Must report applicable IEEPA Chapter 99 numbers for bonding but are duty-free if compliant.
Transshipment
Goods found to be transshipped to evade duties are subject to 40% additional duty under 9903.02.01 in addition to other penalties and duties.
HTSUS Reporting Requirements
Do not combine multiple HTSUS duties in a single line.
For goods with ≥20% U.S. content (9903.01.34), split into two lines:
U.S. content (duty-free)
Non-U.S. content (subject to reciprocal duty)
HTSUS entry sequence:
Chapter 98 (if applicable)
Chapter 99 (additional duties)
Section 301
IEEPA Fentanyl
IEEPA Reciprocal
Section 232 or 201
Related quotas
Replacement duty/MTB
Other quota (if applicable)
Chapter 1–97 for commodity tariff
Read the full CSMS here: https://content.govdelivery.com/accounts/USDHSCBP/bulletins/3ec7b5e
Should you have any questions, please contact our Import Compliance team or call us at 518-785-6000.
