The White House published additional details about the Reciprocal Tariffs.
Annex I – Country Specific Reciprocal Tariff Rates
During Trump’s White House conference introducing the Reciprocal Tariffs, his chart showed only 50 or so countries with specific Reciprocal Tariff rates. Annex I is a longer and more comprehensive list. Please review this list closely.
Annex II – Products Exempted from the Reciprocal Tariff
The original executive order included an exemption for copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products. The exact HTS classifications for such articles is published in Annex II. Please review this list closely to see if your product may be exempted from the Reciprocal Tariff.
As a reminder, products subject to a Section 232 tariff are also exempted from the Reciprocal Tariff. One issue that remains to be clarified is how to apply this exemption to steel and aluminum derivative articles that are only partially made out of steel or aluminum. Specifically, should the non-steel/non-aluminum portion of such articles also be exempt from the Reciprocal Tariff? A few trade attorneys have asserted that the way the Executive Order is written, the entire product should be exempted as long as any portion of the product is subject to the Section 232 steel / aluminum tariff. Until CBP provides further guidance, importers who choose to exempt the entire product, including the non-steel and non-aluminum portion, from the Reciprocal Tariff do so at their own risk.
Annex III – Harmonized Tariff Classifications for the Reciprocal Tariffs
This annex is only for those in the importing community who want to dive into the details of HTS classifications. Suffice to say, there are over fifty different HTS classifications related to the Reciprocal Tariffs. Importers trying to read their Entry Summaries will now need to interpret three, four, or in some cases even five different classifications on each line.
Note again that the Reciprocal Tariffs start tomorrow on April 5, 2025. Shipments that are loaded on vessels that depart on or after 12:01AM eastern daylight time on April 5, 2025 will initially be subject to the 10% baseline Reciprocal Tariff. Shipments that depart on or after 12:01AM eastern daylight time on April 9, 2025, will be subject to the updated country by country Reciprocal Tariff found in Annex I.
