CBP Issues Updated Guidance on Newly Implemented IEEPA Reciprocal Tariffs

U.S. CBP has released updated and expanded guidance regarding the IEEPA Reciprocal Tariffs that took effect on April 5, 2025.

 Transit Exception Window:

Articles from any country that were loaded onto a vessel at the port of loading and in transit on their final mode of transport prior to entry into the United States before 12:01 a.m. EST on April 5, 2025 and are entered for consumption or withdrawn from a warehouse for consumption on or after April 5, 2025 and before 12:01 a.m. EST on May 27, 2025 will be exempt from the 10% reciprocal tariffs.

U.S. Origin Content Exemption:

For articles in which at least 20% of the article’s value is of U.S. origin, the U.S. content will not be subject to the reciprocal tariff. The reciprocal tariff will be assessed on the non-U.S. content.

Drawback Eligibility:

Unlike previous tariff implementations earlier this year, drawback is available for the additional duties imposed under this Executive Order.

References:

  • The most current version of Annex I, listing affected countries and their applicable tariff rates as of April 9, 2025, can be found here: Annex I 

Note: Countries not listed in Annex I remain subject to the current 10% tariff.

  • The Annex II list of exempted items is available here: Annex II

For complete guidance, please refer to the following official sources:

We will continue to monitor this and provide updates as they become available