CBP Clarifies Reciprocal Tariff In-Transit Exemption: Ocean Vessels Only

Trade Update • April 30, 2025

U.S. Customs and Border Protection has confirmed that exemptions from new reciprocal tariffs for in-transit goods apply only to ocean vessel shipments, not to truck, rail, or air imports.

ustoms and Border Protection (CBP) has updated its IEEPA FAQ page with new guidance/ a table chart for importers seeking to claim the in-transit exemption under the reciprocal tariffs imposed earlier this month. In its April 30 update, CBP stated unequivocally that only shipments arriving by vessel qualify for the in-transit exemption tied to the April 5 and April 9 effective dates.

“The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation,” the agency said, citing 19 U.S.C. 1401, which defines a vessel as a water craft.

The update clarifies that shipments transloaded onto another mode of transport—such as cargo that begins by vessel and finishes by truck or rail—do not qualify for the in-transit exemption.

CBP Warns Importers to Correct Non-Vessel Entries

CBP warned importers and brokers that any entries filed under Harmonized Tariff Schedule (HTS) code 9903.01.28—the in-transit exemption code—must be corrected if the goods did not arrive by vessel. Filers should take “immediate action” to fix such errors.

“Importers or their customs brokers should correct the entry summary by filing a post summary correction,” CBP said.

Additional Updates

In the same update, CBP clarified several other key issues:

• China-Origin Goods: Products that originate from China remain subject to reciprocal tariffs—even if they qualify for preferential treatment under the U.S.-Mexico-Canada Agreement (USMCA). These products must report HTS 9903.01.63 and pay the +125% tariff.

• Section 232 Derivatives: Derivative products made from steel or aluminum but not classified under Chapter 73 are not subject to reciprocal tariffs. CBP confirmed that only the steel or aluminum content is dutiable under Section 232, and the entire value is exempt from reciprocal tariffs.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Please contact your Client Care Manager or our Global Trade Services Team gts@ghy.com, or call +1 (800) 667-0771.