Following up on our message of yesterday, the Executive Order was published, and we have now had an opportunity to fully review it to present the impact to you.  We have not yet received the final implementing instructions from CBP, but we have carefully reviewed the EO, and you can trust the below as of this writing.  All of the below are in effect as of Midnight tonight.  That means, goods which have not arrived and entered yet will get the benefit of this Executive Order.

• Duties under IEEPA, the Reciprocal tariff for goods or Chinese Origin of 125% has been paused until August 14, 2025.
• Duties under IEEPA, Reciprocal tariffs will now revert to the same as all other countries of 10%.
• Duties under IEEPA, Reciprocal tariff for goods of Chinese Origin will be at 24%, however, this is paused, the same as all other countries until July 9, 2025.
• Duties under IEEPA for stemming the flow of narcotics (Fentanyl tariff) continue at 20%.
• Duties under 301 remain at rates generally between 7.5% – 25%.

While it has not changed, a reminder:

• Goods falling under the 232 actions (National Security) for Aluminum and Steel or Auto Parts are EXEMPT from the Reciprocal tariffs.  This applies not only to China but all other countries.

For example, you have goods originating in China which DO NOT fall under a 232 action:

For example, you have goods which fall under a designated Auto Parts classification (see our website for listing) originating in China which DO fall under a 232 action:

The above tables are ‘general’.  If your goods fall into a specific exemption (you know if they do, such as special Chapter 98 provisions), then the above may be applied differently.  For the purposes of most of our clients, the above is accurate.

Please let us know if you have any questions.

May 13, 2025