Tariff Talk Thursday is Back!
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Tariff Talk Thursday is Back!
Visit our Events page for details or register here.
APRIL 8, 2025
At the stroke of midnight, imports from 83 countries will see a quick bump from the recently implemented 10% reciprocal tariff to a country-specific rate (OCEANAIR Reciprocal Tariff Chart), ranging from 11% (Cameroon or Republic of Congo) to 50% (Lesotho). The increased rate applies to goods loaded onto a vessel at the port of loading as of April 9; if in transit on or after April 5, the 10% rate remains applicable. Goods meeting these dates must also be imported by May 27 to qualify for exclusion.
Final rates are as announced, with key trading partners impacted, including China (34%), Vietnam (46%), EU nations (20%), Taiwan (32%), and Japan (24%). Except where an exclusion is listed, these reciprocal tariffs are in addition to any and all other applicable tariffs. China is the first to issue a matching retaliation rate on all U.S. goods. Other countries have stated they are preparing their tariffs, while some report being in negotiations with the White House.
Unlike other Trump-era tariffs, these reciprocals come with exclusions seemingly focused on the ability to manufacture within the U.S.:
U.S. Content: If an article contains U.S. content, only the non-U.S. content will be tariffed. Supporting documents are not specifically identified, but supply chain documentation such as costed bills of material and supplier invoices should be gathered.
Section 232: Articles already subject to Section 232 tariffs, including steel, aluminum, derivative articles, passenger vehicles, and similar products, are excluded.
Annex II: Articles listed on Annex II are excluded, including a wide array of items subject to Section 232, various paper-based goods, additional semiconductor items, pharmaceuticals, and raw materials such as chemicals, copper, and platinum.
USMCA: Articles from Mexico or Canada that meet USMCA requirements are excluded.
Humanitarian & Informational Materials: In line with other Trump administration actions, humanitarian relief donations and informational materials, such as publications, films, and records, are also excluded. Many HTS codes for informational materials are included in Annex II.
The order excludes articles from Belarus, Cuba, North Korea, and Russia. These are known as Column 2 countries in the Harmonized Tariff Schedule and are highly sanctioned. The rate for Column 2 countries, for example, is 70% for a basic toy—compared to free for others—while an ice bag is 4.2% for most countries and 25% for Column 2.
Since tariffs are applied based on the country of manufacture rather than physical origin, U.S.-returned goods are not impacted by reciprocals.
Contrary to other recent tariff programs, these reciprocals are also available for drawback, allowing importers potential relief if goods are re-exported, either in the same condition or remanufactured. Drawback participation requires a formal approval process prior to submission of claims. Aside from changes to de minimis treatment for China, effective May 2, low-value processing remains available and exempt.
What remains missing from the Executive Orders and U.S. Customs guidance is a clear path for avoiding tariffs on items built in the U.S., as presented during the reciprocal tariff announcement. The current parameters do not provide an exclusion or guidance for such conditions. OCEANAIR will continue to monitor and inform clients if relief becomes available through importing under this tariff framework.
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