U.S. Enforces on China 125% Reciprocal Tariff
Trade Update • April 9, 2025
ffective April 10, 2025 products originating from China and Hong Kong, imported into the U.S., will be subject to reciprocal duty rate of 125% (previously 84% on April 9).
Previously, on March 4, 2025, the U.S. imposed a 20% tariff (from 10% originally on February 4). Note: The 125% reciprocal tariff is on top of the IEEPA Fentanyl Tariff of 20% that came into effect on March 4, 2025.
IEEPA Reciprocal Tariff (125%)
(Update) – Reciprocal 125% Tariff on China Imports
Under the Executive Order of ‘Amendment to Reciprocal Tariffs and Updated Duties As Applied to Low-Value Imports from the People’s Republic of China’, imported goods from China—including those originating in Hong Kong and Macau—are subject to the following tariff measures, unless specifically exempted under CSMS #64680374.
- HTSUS Subheading 9903.01.63 – Products of China, including Hong Kong and Macau, will incur an additional ad valorem duty of 125%.
IEEPA Fentanyl Tariff (20%)
20% Tariff on Certain Imports
Under the Executive Order of ‘Imposing Duties to Address the Synthetic Opioid Supply Chain in the People’s Republic of China’, effective March 4, 2025, a 20% tariff (previously 10%, effective February 4, 2025) applies to “products of China and Hong Kong” and will be entered using HTSUS 9903.01.20. The standard for determining the origin of the good is substantial transformation.
The U.S. has implemented an additional 20% tariff on certain imports, including goods previously excluded from Section 301 tariffs and those eligible for duty exemptions under HTSUS Heading 9902 – example the Miscellaneous Trade Bill. This tariff applies regardless of prior exemptions or reductions.
Exemptions from the 20% Tariff
Certain categories of goods are not subject to the additional tariff, including:
- Personal use items
- Select Chapter 98 HTSUS entries, including U.S. goods returned and certain repaired or processed items – 9802.00.40, 9802.00.50, 9802.00.60, 9802.00.80, 9801 – Note: Does not apply to goods classified in Chapter 98, EXCEPT for goods repaired/altered/processed/assembled in Canada – duty will apply to the value of repair/alterations/processing done in Canada, or the value of the article assembled in Canada less the cost or value of such products of the United States.
- Humanitarian donations, such as food, clothing, and medicine (HTSUS 9903.01.21)
- Informational materials (HTSUS 9903.01.22)
Transit Exemption
Goods that were already in transit on the final mode of transport prior to February 1, 2025, and entered before 12:01 a.m. ET March 8, 2025, may be exempt from the additional tariff. Goods entered on or after March 8, 2025, will be assessed 20% duty. Importers must declare HTSUS 9903.01.23 to claim this exemption.
Foreign Trade Zone (FTZ) Treatment
Imports from China and Hong Kong admitted to an FTZ after March 4, 2025, at 12:01 a.m. ET must be in privileged foreign status, meaning they will be subject to the tariff rate in effect at the time of FTZ admission. However, goods eligible for domestic status upon FTZ admission are exempt from the additional duty.
This tariff adjustment introduces new cost considerations for importers, particularly those handling goods from China and Hong Kong. Businesses should review tariff classifications and exemptions to optimize compliance and minimize costs.
De Minimis Changes
De Minimis Exception Ends
Shipments from China and Hong Kong are no longer eligible for duty-free entry under Section 321 (de minimis rule for goods under $800). Instead, these goods require a formal or informal entry. Additionally, any goods arriving via international mail must go through formal entry procedures. No duty drawback is available for the 20% tariff, though standard duty drawbacks may apply to other eligible duties.
De Minimis Tariff Increases (Postal Items)
To strengthen enforcement and maintain the intent of Executive Order 14257 (as modified April 8, 2025), the ad valorem rate of duty set in Section 2(c)(i) of Executive Order 14256 has been further increased. Originally raised from 30% to 90% as of April 2, 2025, the rate is now increased to 120% under the April 9, 2025 order. This duty targets low-value imports linked to the synthetic opioid supply chain from the People’s Republic of China.
Per-Item Duty (May 2 – June 1, 2025): Increased to $100
The per-item duty on postal shipments set in Section 2(c)(ii) of Executive Order 14256 (as modified by the April 8, 2025 update to EO 14257) has increased. Originally set to rise from $25 to $75 for the period beginning 12:01 a.m. EDT on May 2, 2025, the duty is now increased further to $100 per item. This applies to shipments entering the United States between May 2, 2025, and before 12:01 a.m. EDT on June 1, 2025.
Per-Item Duty (On or After June 1, 2025): Increased to $200
For postal items arriving on or after 12:01 a.m. EDT on June 1, 2025, when ad valorem is not assessed — was previously set to increase from $50 to $150 per-item postal duty. Under the updated April 10 order, that duty is now further increased to $200 per item.
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?
Navigating the complex changes introduced by the USMCA Interim Final Rule can be challenging, but we are here to help. GHY provides comprehensive support, including ensuring compliance with USMCA requirements, streamlining certification submissions for Labor Value Content (LVC), steel, and aluminum, managing unique identifiers for entry documents, and assisting with Tariff Preference Level (TPL) requirements for textiles.
Additionally, GHY offers guidance on filing protests, maximizing duty deferral programs, and tailoring solutions to your specific trade needs. With decades of expertise, GHY is your partner in achieving seamless compliance and navigating today’s regulatory landscape.
Contact Us Today! gts@ghy.com, or call +1 (800) 667-0771.
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