Effective:
The 10% additional duty will be applied from April 5th, while the higher additional duties for specific origins will be applied starting April 9th. The text in Annex III contradicts this, but the announcement makes it clear that is the intent.
Summary of new additional duties:
Add 10% to all goods, except for origins in Annex I which have their own higher percentages.
Exceptions:
- Annex 2 HS codes are exempt from the additional amount.
- Any HS code that has an existing 232 additional tariff is exempt
- Col2 countries are exempt, just pay Col 2 rate.
- USMCA goods from CA and MX are exempt for now.
- Penalties:
- 9903.01.25: The new 10% additional duty. Can be exempted/modified by 9903.01.26-34. Only applies to the countries NOT in Annex I9903.01.29: Exemption for countries in Annex I
- 9903.01.43-9903.01.77: The specific duty rate to add for each origin in Annex I
- Exemptions:
- 9903.01.26: Canada ( this will change when CBP is ready to charge “by percentage of US origin goods” for USMCA eligible goods. The penalty will be 12% instead of 10% for non US origin )
- 9903.01.27: Mexico ( ditto )
- 9903.01.28: Stuff in transit from before April 5, but entered for consumption after April 5th : exempted.
- 9903.01.30: donations exemptions
- 9903.01.31: publications/information exemptions
- 9903.01.32: The exemption for products from Annex II
- 9903.01.33: Iron or steel. [[ things previously penalized by 232 – that stays, this new duty is exempted ]]
- 9903.01.34: Cases when at least 20% of the product is “US content”, that percentage is exempted from the additional duty ( but you still have to pay the additional amount on the other percentage that is not US origin! )
- 9903.01.35 through 9903.01.42 deal specifically with the coding for USMCA goods from CA and MX respectively.
Descartes update timing:
The CBP has not officially published these changes, but Descartes is planning to update our systems Friday April 4th so they are current as of the 5th. We will be working hard to capture other countries own reciprocal tariffs as they come out. Please watch the blog for announcements with regards to those changes and updates. Of note, the ITC published “Revision 6” on April 3rd, but that only covers the automobile tariffs ( 9903.94.01-04 ) not these latest reciprocal tariffs.