December 18th, 2025 – This notice explains how Executive Order 14346 and a new U.S.–Switzerland–Liechtenstein trade framework change the application of U.S. “Reciprocal” tariffs. It outlines revised tariff rates, new exemptions, filing instructions, and steps importers must take to correct past entries.
Key Points Summary
Legal and Policy Background
EO 14346 (Sept. 5, 2025) authorizes Commerce, DHS, and USTR to implement reciprocal tariff changes and amend the HTSUS as needed.
Framework announced Nov. 14, 2025 between the U.S., Switzerland, and Liechtenstein establishes modified tariff treatment.
Federal Register Notice (Dec. 18, 2025) implements tariff-related elements of the Framework, adjusting IEEPA “Reciprocal” tariffs under EO 14257.
Effective Dates and Systems
Changes apply to covered products entered or withdrawn for consumption on or after 12:01 a.m. ET, Nov. 14, 2025.
Modifications are live in ACE, and filers may update prior entries.
Changes to Reciprocal Tariffs (Core Rule)
Tariff treatment depends on the Column 1 ad valorem rate:
Column 1 ≥ 15% → No additional Reciprocal tariff (0%)
Column 1 < 15% → Combined rate equals 15% ad valorem
Applies separately to:
Switzerland: HTSUS 9903.02.82 (≥15%), 9903.02.83 (<15%)
Liechtenstein: HTSUS 9903.02.87 (≥15%), 9903.02.88 (<15%)
For specific or compound duties, an ad valorem equivalent must be calculated.
Drawback eligibility for Reciprocal tariffs continues.
Headings 9903.02.36 and 9903.02.58 are discontinued after Nov. 13, 2025.
New Exemptions from Reciprocal Tariffs
Effective Nov. 14, 2025, certain products from Switzerland and Liechtenstein are no longer subject to Reciprocal tariffs, including:
Certain agricultural goods and unavailable natural resources
Articles of civil aircraft (excluding unmanned aircraft)
Non-patented pharmaceuticals, ingredients, and chemical precursors
Specific HTSUS Chapter 99 exemption headings are provided for each country and product category. Importers must maintain supporting documentation, especially for pharmaceutical claims.
Ongoing Exemptions
Existing exemptions under HTSUS 9903.01.30–9903.01.34 and 9903.02.78 remain in effect.
HTSUS Sequencing and Duty Reporting
Duties must be reported against the correct HTSUS number and cannot be combined.
Required reporting order:
Chapter 98 (if applicable)
Chapter 99 additional duties (in a specified sequence)
Trade remedies (Section 301, IEEPA, Section 232/201)
Replacement duties or MTB
Other quotas
Chapter 1–97 primary classification
Entered value is generally reported on the Chapter 1–97 subheading.
Previously Filed Entries
Unliquidated entries: File a Post Summary Correction (PSC) to request refunds.
Liquidated entries: File a protest within 180 days of liquidation under 19 U.S.C. §1514.
Read the full CSMS here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-4005e74?wgt_ref=USDHSCBP_WIDGET_2
Should you have any questions, please contact our Import Compliance team or call us at 518-785-6000.
