Section 232 IEEPA Reciprocal Tariffs Summary

Posted by on Friday, April 4, 2025 · Leave a Comment 

IEEPA Reciprocal Tariffs Summary

President Trump signed an Executive Order on April 2nd invoking Section 232 of IEEPA Authority. This Executive Order imposed a universal 10% tariff for imports of all countries except as noted below.

Selected countries will have a greater tariff than the baseline 10%.

All imports subject to the 10% duty will be assessed the duty effective 12:01 a.m. ET on Saturday 4/5/2025 (that’s 9:01 p.m. PT on Friday 4/4/2025).

Annex I lists countries that subject to a tariff greater than 10%. Imports from the countries listed in

Annex I countries are subject to the specified tariffs effective 12:01 a.m. ET Wednesday 4/9/2025 (that’s 9:01 p.m. PT on Tuesday 4/8/2025).

In both cases, goods that are loaded onto a vessel at the port of lading and in final mode of transit before the times stated will NOT be subject to the tariff.

 

Exceptions:

The additional duty will not apply to:

  • Goods exempted under 50 USC 1701
    • Goods for personal use
    • Donations of food, clothing, and medicine intended to relieve human suffering
    • Merely informational materials
  • Products subject to existing Section 232 tariffs
    • Steel and derivatives
    • Aluminum and derivatives
    • Autos and auto parts
  • The following products and any others listed in Annex II
    • Copper
    • Pharmaceuticals
    • Semiconductors
    • Lumber
    • Certain critical minerals
    • Energy and energy products
  • Products from countries subject to Column 2 rates
    • Cuba
    • North Korea
    • Russia
    • Belarus
  • Goods from Canada and Mexico covered under USMCA
    • Non-USMCA articles are still subject to the additional 25% duty
      • When then additional 25% duty is terminated or suspended, then such goods will be subject to a 12% IEEPA Reciprocal tariff
    • The value of US content of any goods provided that there is US content of no less than 20% of the value of the article
    • Section 321 de minimis goods of countries other than China.

If a country retaliates against US goods as a result of these tariffs, the President may increase or expand the scope of the tariffs.

If a country remedies the non-reciprocal trade agreements, the President may decrease or limit the scope of the tariffs.

SEC 232 – IEEPA Reciprocal Tariffs – Annex I

SEC 232 – IEEPA Reciprocal Tariffs – Annex II

 

Note:

The information above is borrowed heavily from an analysis performed by an NCBFAA Legislative Advisor of Sandler, Travis, & Rosenberg P.A.

 

As normal, the information is the best interpretation of the declaration available to us; however, this information is subject to change with very little notice. It may not be construed to be legally binding.

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