Guidance on Additional Tariffs – Canada, Mexico, and China, Steel and Aluminum Imports
Trade Update • March 5, 2025
he U.S. Customs and Border Protection (CBP) has released updated guidance on the implementation of new tariffs on imports from Canada, Mexico, and China, alongside a Federal Register notice detailing tariff adjustments on steel and aluminum products.
CANADA AND MEXICO [Amended]
U.S. Tariffs on Canada and Mexico Paused Until April 2 – details here.
Effective March 4, 2025, the United States implemented a 25% additional tariff on all imports (products) from Canada and Mexico, with a specific 10% tariff on Canadian energy products. These tariffs are applied in addition to any existing duties, taxes, or fees.
Products Excluded from Additional Tariffs (Canada and Mexico)
Autos and auto parts – 30 day pause on tariffs.
Personal Use Goods.
Humanitarian Donations: Food, clothing, medicine, and other aid items intended to relieve human suffering (HTSUS 9903.01.11 for Canada and HTSUS 9903.01.02 for Mexico).
Informational Materials: Publications, films, posters, photographs, microfilms, CDs, artworks, and news wire feeds (HTSUS 9903.01.12 for Canada and HTSUS 9903.01.03 for Mexico).
Chapter 98 Exemptions: Includes provisions for duty exemptions on certain temporary imports, U.S. goods returned, and specific categories of trade that meet qualifying criteria:
- 9801 – U.S. goods exported and returned from Mexico/Canada (not subject to duties even if of Mexico/Canada origin).
- 9802.00.40, 9802.00.50 – U.S. articles sent to Mexico/Canada for repairs/alterations, subject to duties on the value added.
- 9802.00.60 – U.S. metal articles sent to Mexico/Canada for processing, subject to duties on the value added.
- 9802.00.80 – Goods for use in the assembly of U.S. components, subject to duties on the value added.
Additional Notes
- No drawback is allowed for these tariffs. Duty drawback is allowed for other eligible duties paid.
- There is no grace period for goods in transit.
- Section 321 de minimis goods are not impacted until Commerce establishes a system to collect the tariffs.
Foreign Trade Zone (FTZ) Goods
For products of Canada and Mexico admitted into U.S. Foreign Trade Zones (FTZs) after March 4, 2025, the following applies.
- Privileged Foreign Status: Such articles must be admitted as “privileged foreign status,” meaning they will be subject to the duties imposed by the executive orders upon entry for consumption.
- Domestic Status: Articles eligible for admission under “domestic status” as defined in 19 CFR 146.43 are exempt from the additional tariffs.
CBP Notice on Additional Duties on Imports from Canada
CBP Notice on Additional Duties on Imports from Mexico
CHINA
In addition to the measures against Canada and Mexico, the United States increased tariffs on Chinese imports.
- Initial Tariff: A 10% additional tariff effective February 4, 2025.
- Increased Tariff: This rate was subsequently raised to 20% effective March 4, 2025.
Guidance on Increased Tariffs
Effective 12:01 a.m. EST on February 4, 2025, until March 3, 2025, goods from China and Hong Kong entered for consumption, or withdrawn from warehouse for consumption, will be subject to the following duty rates:
- HTS 9903.01.20 (Importers Should Use): Imports from China and Hong Kong, other than products classifiable under 9903.01.21 (donations), 9903.01.22 (informational materials), and 9903.01.23 (grace period until March 7 for goods “loaded onto a vessel/in transit” prior to Feb. 1), and personal use goods, will incur an additional 10% duty.
Effective 12:01 a.m. EST on or after March 4, 2025, goods from China and Hong Kong entered for consumption, or withdrawn from warehouse for consumption, will be subject to the following duty rates:
- HTS 9903.01.24 (Importers Should Use): Imports from China and Hong Kong, other than products classifiable under 9903.01.21 (donations), 9903.01.22 (informational materials), and 9903.01.23 (grace period until March 7 for goods “loaded onto a vessel/in transit” prior to February 1), and personal use goods), will incur an additional 20% duty.
Grace Period
HTSUS 9903.01.23 (Importers Should Use): Goods in transit before February 1, 2025, and entered for consumption between February 4, 2025, and March 7, 2025. Goods entered or withdrawn from warehouse for consumption after Feb. 4 will not pay the additional tariff.
Additional Notes
- No drawback is allowed for these tariffs.
- De minimis goods are not impacted until Commerce establishes a system to collect the tariffs.
CBP Notice on Additional Duties on Imports from China and Hong Kong
STEEL AND ALUMINUM
The Federal Register has released a notice on March 5, 2025 to detail further the President Proclamation on “Adjusting Imports of Aluminum into the United States.” This proclamation imposes new tariffs on aluminum imports, establishing specified rates of duty in response to trade and national security considerations. The modifications directed by the proclamation are reflected in the Harmonized Tariff Schedule of the United States (HTSUS) and are set to take effect on March 12, 2025, at 12:01 a.m. EST.
Steel and Derivative Imports
- A 25% tariff is applied to original steel products and their derivatives.
- Additional tariffs are introduced on a newly identified list of derivative steel products classified under HTS Chapter 73.
- Tariffs on derivative steel products not classified under HTS Chapter 73 will take effect at a later date, as determined by the Secretary of Commerce once a collection system is in place.
- The additional duty applies only to the declared value of the steel content of the derivative article, and the quantity of steel content must be reported in kilograms (KG).
- Importers must provide any required information to U.S. Customs and Border Protection (CBP) to facilitate tariff administration.
- A duty exemption applies only to the new list of derivative products, provided that they were processed in another country from steel articles melted and poured in the United States.
- This exemption does not apply to steel articles or derivatives on the original lists.
Aluminum and Derivative Imports
- A 25% tariff is applied to original aluminum products and their derivatives.
- Additional tariffs are introduced on a newly identified list of derivative aluminum products classified under HTS Chapter 76.
- Tariffs on derivative aluminum products not classified under HTS Chapter 76 will take effect at a later date, as determined by the Secretary of Commerce once a collection system is in place.
- The additional duty applies only to the declared value of the aluminum content of the derivative article, and the quantity of aluminum content must be reported in kilograms (KG).
Importers must report to U.S. Customs and Border Protection (CBP) the primary country of smelt, secondary country of smelt, and country of cast for all aluminum articles subject to Section 232 measures. - Derivative aluminum imports must comply with CBP reporting requirements to facilitate the proper administration of duties.
- A duty exemption applies only to the new list of derivative products, provided that the product was processed in another country from aluminum articles that were smelted and cast in the United States.
- This exemption does not apply to aluminum articles or derivatives on the original lists.
- Aluminum products originating from Russia or containing any amount of primary aluminum smelted in Russia or cast in Russia will be subject to a 200% tariff.
- Unlike aluminum from other origins, Russian aluminum and its derivatives do not qualify for the same tariff exemptions under HTS Chapter 98.
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.
Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.
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