CBP Guidance on Reciprocal Tariff Effective April 5 and April 9, 2025 (Updated)

Trade Update • April 14, 2025

.S. Customs and Border Protection (CBP) is issuing the following updated guidance regarding additional duties imposed on certain imported merchandise pursuant to the Executive Order titled, “Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits,” signed on April 2, 2025, and published in the Federal Register at 90 FR 15041 (Apr. 7, 2025).

This guidance applies to entries on or after 12:01 a.m. EDT on April 5, 2025 and incorporates additional measures that take effect beginning April 9, 2025.

Update – see section ‘Exclusion for Specific Products’.

Key Guidance

Chapter 99 Secondary Classification Required

Effective April 5, 2025, importers must include at least one relevant HTSUS Chapter 99 secondary classification on entries affected by reciprocal tariffs. All imported goods must be reported either under the applicable reciprocal tariff HTSUS subheading or under an exception subheading. This requirement is expanded to ensure accurate identification of goods subject to Executive Order 14257 or those qualifying for exemptions.

Additional Duty Rates – HTSUS 9903.01.25 and Country-Specific Rates

Effective April 5, 2025, all imported goods, unless specifically excepted, are subject to an additional 10% ad valorem duty under HTSUS 9903.01.25. This duty is in addition to all other applicable duties, taxes, fees, and charges.

Effective April 9, 2025, a country-specific ad valorem rate of duty will apply to imported goods of 83 countries and will replace the 10% additional ad valorem duty rate under 9903.01.25. These are assigned to HTSUS headings 9903.01.43 through 9903.01.76.

• 9903.01.43:

  Articles the product of Cameroon or the Democratic Republic of the Congo will be assessed an additional ad valorem rate of duty of 11%.

• 9903.01.44: Articles the product of Chad or Equatorial Guinea will be assessed an additional ad valorem rate of duty of 13%.
• 9903.01.45: Articles the product of Nigeria will be assessed an additional ad valorem rate of duty of 14%.
• 9903.01.46: Articles the product of Norway or Venezuela will be assessed an additional ad valorem rate of duty of 15%.
• 9903.01.47: Articles the product of Mozambique will be assessed an additional ad valorem rate of duty of 16%.
• 9903.01.48: Articles the product of Israel, Malawi, Philippines, or Zambia will be assessed an additional ad valorem rate of date of 17%.
• 9903.01.49: Articles the product of Nicaragua or Zimbabwe will be assessed an additional ad valorem rate of duty of 18%.
• 9903.01.50: Articles the product of Jordan or the European Union (Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden) will be assessed an additional ad valorem rate of duty of 20%.
• 9903.01.51: Articles the product of Côte d`Ivoire or Namibia will be assessed an additional ad valorem rate of duty of 21%.
• 9903.01.52: Articles the product of Vanuatu will be assessed an additional ad valorem rate of duty of 22%.
• 9903.01.53: Articles the product of Brunei, Japan, or Malaysia will be assessed an additional ad valorem rate of duty of 24%.
• 9903.01.54: Articles the product of South Korea will be assessed an additional ad valorem rate of duty of 25%.
• 9903.01.55: Articles the product of India will be assessed an additional ad valorem rate of duty of 26%.
• 9903.01.56: Articles the product of Kazakhstan will be assessed an additional ad valorem rate of duty of 27%.
• 9903.01.57: Articles the product of Tunisia will be assessed an additional ad valorem rate of duty of 28%.
• 9903.01.58: Articles the product of Pakistan will be assessed an additional ad valorem rate of duty of 29%.
• 9903.01.59: Articles the product of Algeria, Nauru, or South Africa will be assessed an additional ad valorem rate of duty of 30%.
• 9903.01.60: Articles the product of Libya, Moldova, or Switzerland will be assessed an additional ad valorem rate of duty of 31%.
• 9903.01.61: Articles the product of Angola, Fiji, Indonesia, or Taiwan will be assessed an additional ad valorem rate of duty of 32%.
• 9903.01.62: Articles the product of North Macedonia will be assessed an additional ad valorem rate of duty of 33%.
• 9903.01.63: Articles the product of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 34%.
• 9903.01.64: Articles the product of Bosnia and Herzegovina will be assessed an additional ad valorem rate of duty of 35%.
• 9903.01.65: Articles the product of Thailand will be assessed an additional ad valorem rate of duty of 36%.
• 9903.01.66: Articles the product of Bangladesh, Botswana, Liechtenstein, or Serbia will be assessed an additional ad valorem rate of duty of 37%.
• 9903.01.67: Articles the product of Guyana will be assessed an additional ad valorem rate of duty of 38%.
• 9903.01.68: Articles the product of Iraq will be assessed an additional ad valorem rate of duty of 39%.
• 9903.01.69: Articles the product of Mauritius will be assessed an additional ad valorem rate of duty of 40%.
• 9903.01.70: Articles the product of Falkland Islands or Syria will be assessed an additional ad valorem rate of duty of 41%.
• 9903.01.71: Articles the product of Myanmar (Burma) or Sri Lanka will be assessed an additional ad valorem rate of duty of 44%.
• 9903.01.72: Articles the product of Vietnam will be assessed an additional ad valorem rate of duty of 46%.
• 9903.01.73: Articles the product of Madagascar will be assessed an additional ad valorem rate of duty of 47%.
• 9903.01.74: Articles the product of Laos will be assessed an additional ad valorem rate of duty of 48%.
• 9903.01.75: Articles the product of Cambodia will be assessed an additional ad valorem rate of duty of 49%.
• 9903.01.76: Articles the product of Lesotho will be assessed an additional ad valorem rate of duty of 50%.

Exclusion for Specific Products (Updated)

Tariff Exclusion for Certain Products – Effective April 5

Products properly classified under the following HTSUS headings and subheadings are excluded from the reciprocal tariffs imposed under Executive Order 14257 (as amended), according to Section 3(b)(iv). This applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on April 5:

8471, 8473.30, 8486, 8517.13.00, 8517.62.00, 8523.51.00, 8524, 8528.52.00, 8541.10.00, 8541.21.00, 8541.29.00, 8541.30.00, 8541.49.10, 8541.49.70, 8541.49.80, 8541.49.95, 8541.51.00, 8541.59.00, 8541.90.00, 8542

How to Claim the Exclusion:

• Importers must also report secondary classification 9903.01.32 to show the product is excluded from tariffs listed in 9903.01.25, 9903.01.43–9903.01.62, 9903.01.64–9903.01.76, or 9903.01.63 (effective April 9).

Next Steps for Entries on or after April 5:
Filers must update entries to claim the exclusion under 9903.01.32 within 10 days of cargo release from CBP custody.

• Refunds may be requested:

  • Via post summary correction for unliquidated entries.

  • Or by filing a protest for liquidated entries still within the protest period.

Full Details: CSMS # 64724565 – UPDATED GUIDANCE – Reciprocal Tariff Exclusion for Specified Products; April 5, 2025 Effective Date

Exemptions

Until further notice, for all imported merchandise that is:

• (a) entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and for which an HTSUS classification is required, if HTSUS heading 9903.01.25 is not declared, or
• (b) entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 9, 2025, and for which an HTSUS classification is required, if a heading between 9903.01.43 and 9903.01.76 is not declared,

then one of the following Chapter 99 secondary classifications must be declared to specify the particular exception under which the reciprocal tariff (in heading 9903.01.25 or 9903.01.43–9903.01.76) does not apply to the imported articles that are excluded from the additional ad valorem duties:

• 9903.01.26 – Products of Canada, including USMCA-eligible articles. Articles properly classified in 9903.01.10 through 9903.01.15 should declare a secondary classification under 9903.01.26 in order to be excepted from the reciprocal tariff.
• 9903.01.27 – Products of Mexico, including USMCA-eligible articles. Articles properly classified in 9903.01.01 through 9903.01.05 should declare a secondary classification under 9903.01.27 in order to be excepted from the reciprocal tariff.
• 9903.01.28 – Goods in transit before April 5, 2025. This exception is valid only through May 26, 2025. To prevent importers from abusing the exception for goods that were in transit before April 5, 2025 when it is no longer realistic due to the passage of time, CBP will permit heading 9903.01.28 to be declared only for goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on May 27, 2025. NOTE: Articles the product of the countries that have an additional country-specific rate of duty, identified in 9903.01.43 – 9903.01.76, that were (1) loaded onto a vessel at the port of loading and in transit on the final mode of transport on or after 12:01 a.m. EDT April 5, 2025, and before 12:01 a.m. EDT April 9, 2025, and (2) are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. EDT on May 27 2025, are subject to the 10% additional rate in lieu of the country-specific rate of duty. Articles to which this in transit scenario applies must be reported under 9903.01.25. To prevent importers from abusing the exceptions for goods that were in transit before April 5, 2025 or April 9, 2025, as applicable, CBP will permit heading 9903.01.28, or heading 9903.01.25 for products of countries covered by headings 9903.01.43 – 9903.01.76, as applicable, to be declared only for goods that are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. EDT on May 27, 2025, after which time the exceptions would no longer realistically apply due to the passage of time.
• 9903.01.29 – Products from Column 2 rate countries (Belarus, Cuba, North Korea, Russia).
• 9903.01.30 – Humanitarian donations (food, clothing, medicine).
• 9903.01.31 – Informational materials (books, media, art).
• 9903.01.32 – Articles listed in Annex II (per U.S. Note 2(v)(iii)).
• 9903.01.33 – Section 232-regulated articles, including steel, aluminum, and vehicles.
• 9903.01.34 – Articles with 20%+ U.S. content (duty applies to non-U.S. portion only).

Chapter 98 Claims

Additional duties do not apply to goods entered under most Chapter 98 HTSUS provisions, except:

• 9802.00.40, 9802.00.50, 9802.00.60 – Duty applies to value of foreign repairs/processing
• 9802.00.80 – Duty applies to value of foreign assembly

Reporting Instructions (Expanded)

Report the reciprocal tariff (9903.01.25) separately from other duties within the entry summary line. If claiming 9903.01.34 (U.S. content exception), split the entry into two lines:

Line 1 – U.S. content:

• HTSUS Chapter 1-97
• Same country of origin
• 9903.01.34
• Value: total minus non-U.S. content
• Quantity: full
• Duties: as applicable

Line 2 – Non-U.S. content:

• HTSUS Chapter 1-97
• Same country of origin
• 9903.01.25
• Value: non-U.S. content only
• Quantity: zero
• Duties: 10% ad valorem + any other applicable duties

HTSUS Reporting Sequence (New)

For entry summary lines with multiple HTSUS numbers, the following sequence must be used:

1. Chapter 98 (if applicable)
2. Chapter 99 for additional duties:
   
   • Section 301
   • IEEPA Fentanyl (China, Canada, Mexico)
   • IEEPA Reciprocal
   • Section 232 or 201
   • Quotas under Section 201/232
3. Chapter 99 for replacement or MTB
4. Chapter 99 for other quotas
5. Chapters 1–97 for commodity classification

Note: Report entered value on Chapters 1–97 unless otherwise required by Chapter 98 provisions.

Foreign Trade Zone (FTZ) Impacts (Expanded)

Effective April 9, 2025, articles subject to reciprocal tariffs must be admitted into FTZs under Privileged Foreign Status (per 19 CFR 146.41), except where otherwise excluded. Duties will be assessed at the HTSUS rate in effect at the time of FTZ admission.

Drawback

Drawback claims and the de minimis exemption under 19 U.S.C. 1321(a)(2)(C) remain available for eligible articles covered by HTSUS 9903.01.25, including those sent through the international postal network, unless otherwise restricted by the April 2, 2025 Executive Order on synthetic opioids from China.

De Minimis

De minimis exemption under 19 U.S.C. 1321(a)(2)(C) remains available for eligible low-value shipments, except where otherwise restricted by the April 2, 2025 Executive Order concerning synthetic opioids from China.

Full Details: CSMS # 64680374 – GUIDANCE – Reciprocal Tariffs, April 5 and April 9, 2025, Effective Dates

Full Details: CSMS # 64649265 – GUIDANCE – Reciprocal Tariffs, April 5, 2025 Effective Date

The information presented is general in nature, and is not intended to constitute legal advice with respect to any event or occurrence, and may not be considered as such.​​ Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.​ Due to the complexity of Customs Regulations, valuations are based on information currently available and should not be considered binding, we recommend obtaining National Customs Rulings in areas of uncertainty.​

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.