Updates on global trade and tariffs

A CBP guidance was issued identifying certain HTSUS classified products as excluded from reciprocal tariffs. This guidance followed a Presidential Memorandum on April 11, 2025.

The guidance issued under CSMS 64724565 listed multiple headings and subheadings of the Harmonized Tariff Schedule of the United States (HTSUS) that are excluded from the reciprocal tariffs issued under Executive Order 14257:

 

• 8471
• 8473.30
• 8486
• 8517.13.00
• 8517.62.00
• 8523.51.00
• 8524
• 8528.52.00
• 8541.10.00
• 8541.21.00
• 8541.29.00
• 8541.30.00
• 8541.49.10
• 8541.49.70
• 8541.49.80
• 8541.49.95
• 8541.51.00
• 8541.59.00
• 8541.90.00
• 8542

These headings describe products such as computers and parts, machines that manufacture semiconductor wafers and integrated circuits, smartphones and other electronic communication products, solid state storage devices, flat panel display modules, monitors, and other semiconductor devices. Imported products properly classified under the listed HTSUS provisions are excluded from
the reciprocal tariffs.

The guidance addressed possible refunds on entries made with these HTSUS provisions for products classified under the referenced HTSUS provisions that are entered for consumption or withdrawn from warehouse for consumption on or after April 5, 2025, filers should promptly take corrective action to ensure the applicable exception under heading 9903.01.32 is properly reflected. Such corrections should be made within 10 days of the release of the cargo from CBP custody.

To request a refund, importers may submit a post summary correction (PSC) for unliquidated entries. For entries that have already liquidated but remain within the protest period, a formal protest may be filed, provided the liquidation is not yet final.

The Presidential Memorandum can be found here and the CBP Guidance here.

As per revised guidance issued by U.S. Customs and Border Protection on Friday, April 11, electronic imports are now excluded from the U.S. Administration's reciprocal tariffs. This exemption, retroactively effective from April 5, encompasses items such as smartphones, computers, and components like semiconductors and memory cards.

Following a tit-for-tat exchange of tariffs between the US and China, China has imposed a significant retaliatory tariff of 125% on U.S. products. This new tariff will take effect on April 12.

The U.S. Administration has announced to temporarily lower the new tariffs for nearly all trading partners, excluding China. This announcement came less than 24 hours after the new tariffs would take effect.

According to official statements, new targeted tariffs on other trading partners would be suspended for 90-days to allow time for U.S. officials to negotiate with willing countries; however, the 10% blanket duty on nearly all imports, along with existing tariffs on autos, steel, and aluminium, appear to remain in place. Simultaneously, the U.S. Administration mentioned an increase of the tariff on Chinese imports to 125% from the 104% that came into effect at midnight on April 9.

The U.S. Administration first introduced a 34% tariff increase on Chinese imports. In response to China's 34% retaliatory tariffs on American goods, an additional 50% duty was imposed. This raised the cumulative tariff to 104%, factoring in the existing 20%. The new tariff officially took effect on April 9.

The U.S. President signed an Executive Order eliminating duty-free treatment under 19 U.S.C. 1321(a)(2)(C) for imported products of China and Hong Kong. Section 321 of the U.S. Tariff Act allows for the duty-free importation of goods valued at $800 or less per shipment, provided they are imported by one person on one day and meet all other eligibility requirements.

With the removal of this favorable treatment, imported goods sent through networks other than international postal systems that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties, including Section 301 (up to 25%) and IEEPA (International Emergency Economic Powers Act) tariffs (20%), and an entry would be required.

Shipments that are sent through the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption are subject to a duty rate of either 30% of their value or $25 per item (increasing to $50 per item after June 1, 2025).

The Executive Order can be found here.

China retaliates against the U.S. with a 34% tariff on all American products as of April 10. Also the European Union and Canada announced retaliatory measures.

Universal tariff

Using the authority of the International Emergency Economic Powers Act of 1977 (IEEPA), the President signed an Executive Order confirming that on April 5th, 2025, a 10% tariff on all imported products from all countries will be imposed.
These tariffs shall apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 5, 2025, except for goods loaded onto a vessel 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, and entered for consumption or withdrawn from warehouse for consumption after 12:01 a.m. eastern daylight time on April 5, 2025, shall not be subject to such additional duty.

Tariffs on cars

As announced earlier, a 25% tariff will apply to cars as of April 3rd, 2025. If a car is built in the U.S., there will be no tariff, and parts covered under the United States–Mexico–Canada Agreement (USMCA) trade deal will not be impacted initially.

Reciprocal tariffs

The Executive Order also imposes higher country-specific rates to countries deemed to have excessive tariffs and trade barriers against U.S. products imported into their country.
Although not specified in the Executive Order, at a Rose Garden event on April 2nd the President indicated that the following tariff rates would apply to these countries:

•    49% on Cambodian goods
•    48% on Laotian goods
•    47% on goods from Madagascar
•    46% on Vietnamese goods
•    44% on Sri Lankan goods
•    44% on goods from Myanmar
•    37% on Serbian goods
•    37% on goods from Botswana
•    37% on Bangladeshi goods
•    36% on Thai goods
•    34% on Chinese goods
•    32% on Taiwanese goods
•    32% on Indonesian goods
•    31% on Swiss goods
•    30% on South African goods
•    29% on Pakistani goods
•    28% on Tunisian goods
•    27% on Kazakh goods
•    26% on Indian goods
•    25% on South Korean goods
•    24% on Malaysian goods
•    24% on Japanese goods
•    21% on goods from Cote D'Ivoire
•    20% on Jordanian goods
•    20% on EU goods
•    18% on Nicaraguan goods
•    17% on Israeli goods
•    17% on Filipino goods
•    15% on Norwegian goods

Those duties will apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 9, 2025, except for goods loaded onto a vessel 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, and entered for consumption or withdrawn from warehouse for consumption after 12:01 a.m. eastern daylight time on April 9, 2025, shall not be subject to these country-specific ad valorem rates of duty set forth in Annex I to the Order.      
Additional details and countries will be updated after the publication of the Executive Order.  Expect U.S. Customs and Border Protection (“CBP”) to also issue guidance on how the entries should be filed.

U.S. President Trump announced a 25% tariff on all automotive imports, effective April 2, the same date he plans to announce reciprocal tariffs. If a car is built in the U.S., there will be no tariff, and parts covered under the United States–Mexico–Canada Agreement (USMCA) trade deal will not be impacted initially.

Canada is imposing a 25% tariff on $29.8 billion in products imported from the United States (U.S.). These tariffs only apply to goods originating from the U.S., which shall be considered in accordance with the Determination of Country of Origin for the Purpose of Marking Goods (CUSMA Countries) Regulations.

The Canadian government has stated that these countermeasures will remain in place until the U.S. eliminates its tariffs against Canadian steel and aluminum products. Canada’s countermeasures do not apply to U.S. goods that are in transit to Canada on the day on which they come into force. Additional details on the administration of these tariffs are available on the Canada Border Services Agency website: Customs Notices (cbsa-asfc.gc.ca).

To see the full list of affected U.S. goods, click here. This list outlined at the tariff item level in the table should be read in conjunction with the Schedule to Canada’s Customs Tariff.

Today, a 25% tariff on aluminum and steel imports to the U.S. from all countries has taken effect. The EU has announced retaliatory measures set to take effect in April.

On Wednesday, the U.S. exempted automotive goods from the 25% tariffs that had been imposed on imports from Canada and Mexico as of Tuesday.

Now, the U.S. also announced a one-month suspension of the 25% tariffs on all goods compliant with the United States-Mexico-Canada Agreement (USMCA). Kuehne+Nagel is closely monitoring all details, including the impact on duties already paid since March 4, 2025, on goods that are now exempted.

According to the latest reports, a 25% tariff on imports of steel and aluminum will still take effect as scheduled on March 12, 2025.

A 25% tariff on Canadian and Mexican imports into the U.S. went into effect after midnight on March 4th, except for Canadian energy products, which are subject to a 10% tariff. Additionally, a 10% tariff on Chinese imports into the U.S. was implemented, applying on top of existing tariffs (meaning a total of 20% tariffs now apply).

In response, China has imposed tariffs on various food and agricultural products from the U.S. The Canadian prime minister has stated that they will immediately apply a 25% tariff on a wide range of U.S. products, and that these tariffs will be expanded if the U.S. tariffs against Canada remain in place after 21 days.

Media reports state that a 25% U.S. tariff on imports from Mexico and Canada will go into effect on March 4th, contrary to earlier reports suggesting a potential delay until April 2nd.

Furthermore, the U.S. president has announced an additional 10% tariff on all goods from China, which are to be applied on the same date, March 4th, on top of the existing 10% tariff which came into effect earlier this month.