Client Advisory: Updates on U.S. Import Tariffs, 90 Day Pause
Client Advisory: Updates on U.S. Import Tariffs and China's Retaliatory Measures
Effective Dates:
· April 5, 2025, 12:01 a.m. EDT: Implementation of a 10% ad valorem tariff on all imported goods into the U.S.
· April 9, 2025, 12:01 a.m. EDT: Introduction of country-specific tariffs, notably a 125% tariff on Chinese imports.
1. Overview of Tariff Changes
Baseline Tariff: A 10% ad valorem tariff has been imposed on all imported goods into the U.S., effective April 5, 2025.
Country-Specific Tariffs: Initially, additional tariffs were scheduled for various countries starting April 9, 2025. However, on April 9, 2025, President Trump announced a 90-day pause on these tariffs for most countries, reducing the tariff rate to 10% during this period.
Exception – China: China is excluded from this pause. The tariff on Chinese imports has been increased to 125%, effective April 9, 2025.
2. Goods in Transit Exemptions
Goods in transit are exempt from the new tariffs if they meet the following criteria:
· Loaded and in Transit: Goods that were loaded onto a vessel or aircraft at the port of origin and were in transit on their final mode of transport before 12:01 a.m. EDT on the respective effective dates (April 5 for the baseline tariff; April 9 for country-specific tariffs) are exempt.
· Entry Deadline: Such goods must be entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. EDT on May 27, 2025, to qualify for the exemption.
Ensure your customs broker possesses on-board documentation (e.g., bill of lading date, loading confirmation) to substantiate eligibility for exemption.
3. Scope of Tariffs
· Baseline Tariff: Applies universally to all countries starting April 5, 2025.
· Country-Specific Tariffs: Initially planned for April 9, 2025, these have been paused for 90 days for most countries, maintaining a 10% tariff rate during this period.
· China Exception: Imports from China are subject to a 125% tariff, effective April 9, 2025.
4. China's Retaliatory Measures
· In response to the U.S. tariffs, China has announced:
· Increased Tariffs: An 84% tariff on all U.S. goods, effective April 10, 2025.
· Restrictions on U.S. Companies: Imposition of restrictions on certain U.S. companies, primarily in defense-related industries.
5. Return and Repair Shipments
The Executive Order does not explicitly address exceptions for returns, repairs, or temporary exports.
However, standard tariff exemptions under HTS Chapter 98 (e.g., 9801 for U.S. goods returned and 9802 for goods sent abroad for repair) may still apply.
Clients should ensure:
· Accurate HTS Classification: Proper classification of goods under applicable HTS codes.
· Supporting Documentation: Provision of necessary documents, such as proof of U.S. origin and repair invoices.
6. Surety Bond Requirements – Action May Be Required
All importers are required to have a valid Customs surety bond on file.
Due to the increase in tariff liabilities, many importers may now have insufficient bond coverage.
What to Do:
· Review Your Bond: Assess your current bond amount in light of increased duties.
· Consult Your Broker or Surety Agent: Determine if an increase or re-filing of your bond is necessary to remain compliant.
7. No Product-Specific Exemptions Announced
The Executive Order broadly applies to all goods, with exemptions primarily based on transit status or specific HTS provisions.
Further guidance may be forthcoming from U.S. Customs and Border Protection (CBP) or the Office of the U.S. Trade Representative.
8. Recommended Actions for Importers
· Review Shipment Timelines: Assess loading dates for all shipments arriving on or after April 5, 2025.
· Recalculate Landed Costs: Update cost analyses to reflect new tariff impacts.
· Confirm Transit Status: Verify shipment documentation and potential exemptions.
· Review Your Customs Bond: Ensure bond amounts cover increased liabilities.
· Collaborate with Brokers: Ensure accurate declarations and application of HTS exemptions.
· Monitor Ongoing Developments: Stay informed about further updates or retaliatory measures.
9. Consult with Your Broker
It is advisable for all importers to consult with their customs broker regarding:
· Current Shipments: Understanding how existing cargo may be affected.
· Compliance Measures: Ensuring all necessary actions are taken.
Need help navigating the new tariff environment?
Compass Forwarding’s compliance experts are here to support you. From reviewing your HTS classifications and ensuring bond adequacy to advising on in-transit documentation and landed cost strategies, we’re ready to help you stay compliant and cost-efficient.
Contact your Compass representative to discuss how these changes impact your shipments — and what actions to take next.
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