Reciprocal Import Tariffs

Please note that this is an evolving situation and the information below may be subject to change or clarification at any time.

On April 5, President Trump implemented reciprocal tariffs for many countries. The additional tariffs are being assessed in addition to any other applicable duties, fees, taxes, exactions, or charges and will remain in place until the president determines that “the underlying conditions described [in the EO] are satisfied, resolved, or mitigated.”

Tariff Rates

Beginning April 10, the tariff rate was changed to 10 percent for imports from more than 75 foreign trading partners. There were higher reciprocal tariffs in place for these countries for 24 hours before the higher rate was suspended. Imports from many other countries have been subject to this 10 percent tariff since April 5. Read more here.

New! As of May 12, the White House anounced a reduction of the reciprocal tariffs on Chinese imported goods to 10% effective on May 14, 2025. The reduction will be in place for at least 90 days, or until August 12, 2025, while China and the U.S. continue discussions. Previously tariffs on China had been 125% (see here and here for more information). The announcement did not provide any indication that duties paid during the period April 9 – May 13 will be refunded.

ST&R offers a three-pronged approach to avoiding, mitigating, and/or recovering these and other tariffs. For more information on which of these strategies might be most effective for your business, please contact ST&R.

Country Exemptions

Goods from Canada and Mexico are exempt from reciprocal tariffs until such time as the IEEPA Border tariffs are terminated or suspended, at which time only USMCA qualifying goods will be exempt from these tariffs and non-USMCA goods will be subject to a 12% reciprocal tariff.

Exclusions

The additional tariffs will apply only to the non-U.S. content of a subject article provided that at least 20 percent of the article’s value is U.S.-originating. “U.S. content” refers to the value of an article attributable to the components produced entirely, or substantially transformed in, the U.S. The EO authorizes CBP to require the collection of such information and documentation regarding an imported article, including with the entry filing, as is necessary to enable it to ascertain and verify (1) the value of the U.S. content of an article and (2) whether an article is substantially finished in the U.S.

The EO excludes the following from the additional tariffs.

all articles encompassed by 50 USC 1702(b) (e.g., communications, donations, and informational materials)
all articles and derivatives of steel and aluminum already subject to Section 232 duties
all automobiles and automotive parts already subject to Section 232 duties
copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products
all articles from a trading partner subject to Column 2 duty rates
all articles that may become subject to duties pursuant to future Section 232 actions

An April 11 presidential memorandum specified that the exception for semiconductors applies to products properly classified in the following HTSUS headings and subheadings: 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, and 8542. Such products include smartphones, laptop computers, semiconductor manufacturing equipment, memory chips, flat panel displays, etc.

De Minimis

Duty-free de minimis treatment will remain available for all goods subject to the increased tariffs (except those imported from China) until the commerce secretary notifies the president that adequate systems are in place to “fully and expeditiously process and collect” revenue from these tariffs for articles otherwise eligible for de minimis treatment.

For goods imported from China, the April 9 EO updated the dury rats on de minimis treatment. As of May 2, such shipments sent through the international postal network will be subject to a duty rate of either 120 percent (up from 90 percent) of their value or $100 per item (up from $75), increasing to $200 (up from $150) as of June 1.