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U.S. Customs Grants In-Transit Exemption Until May 27; Issues Import Guidelines for 10% 'Reciprocal Tariff'
08 Apr 2025
U.S. Customs Grants In-Transit Exemption Until May 27; Issues Import Guidelines for 10% 'Reciprocal Tariff'
Starting from 12:01 AM (Eastern Time) on April 5, 2025, U.S. Customs and Border Protection (CBP) officially began collecting the 10% 'Reciprocal Tariff' on all imported goods from numerous countries. These duties are now effective at all U.S. seaports, airports, and bonded warehouses.
On April 4, 2025 (ET), CBP issued an announcement outlining the import guidance for this tariff, which takes effect on April 5. A separate set of guidance will be released for measures coming into force on April 9, 2025.
CBP also granted a grace period for in-transit goods. Shipments that were loaded and in final transport mode before 12:01 AM (ET) on April 5, 2025, and that arrive in the U.S. before May 27, 2025, are exempt from the 10% reciprocal tariff.
1. Chapter 99 Reporting Requirements
1.1. Effective April 5, 2025, filers must report at least one applicable Chapter 99 subheading from the Harmonized Tariff Schedule of the United States (HTSUS) that corresponds to the reciprocal tariff.
1.2. All import entries must declare either:
A Chapter 99 subheading under which the reciprocal tariff applies, or
An exemption code under Chapter 99, if applicable.
2. Applicable Duty Rate
2.1. Unless specifically exempt, all goods imported for consumption or withdrawn from bonded warehouses after 12:01 AM (ET) on April 5, 2025, are subject to an additional 10% ad valorem duty under HTSUS 9903.01.25.
2.2. This duty is in addition to all existing tariffs, taxes, and fees.
3. Exemptions
3.1. HTSUS 9903.01.26: Goods from Canada
Includes duty-free goods under the USMCA.
Also includes goods covered under Chapter 98 Subchapter XXIII and Chapter 99 Subchapter XXII.
3.2. HTSUS 9903.01.27: Goods from Mexico
Includes duty-free goods under the USMCA.
Also includes goods covered under Chapter 98 Subchapter XXIII and Chapter 99 Subchapter XXII.
3.3. HTSUS 9903.01.28: In-transit Goods
Must be loaded and in final transport mode prior to April 5, 2025.
Must arrive in the U.S. by May 27, 2025.
3.4. HTSUS 9903.01.29: Column 2 Country Products
Applies to products from Belarus, Cuba, North Korea, and Russia.
3.5. HTSUS 9903.01.30: Humanitarian Aid
Includes food, clothing, medicines, and similar relief goods.
3.6. HTSUS 9903.01.31: Informational Materials
Includes publications, films, posters, records, photos, microfilms, tapes, CDs, artwork, press releases, etc.
3.7. HTSUS 9903.01.32: Specific Goods Listed in Annex II
3.8. HTSUS 9903.01.33: Certain Steel and Aluminum Products
Includes steel and aluminum and their derivatives.
Also includes passenger vehicles and light trucks and their parts.
3.9. HTSUS 9903.01.34: Products Containing U.S. Components
Applies to goods where U.S.-origin content equals or exceeds 20% of total value.
Reciprocal tariff applies only to the non-U.S. portion.
4. Chapter 98 Rules
4.1. With the exception of 9802.00.80, 9802.00.40/.50/.60, properly declared Chapter 98 goods are exempt from the 10% reciprocal duty.
4.2. However, charges for repairs, modifications, etc., under certain subheadings are still subject to the tariff.
5. Foreign Trade Zone (FTZ) Rules
5.1. Effective April 9, 2025.
5.2. Goods must enter the FTZ under 'privileged foreign status,' unless exempt under 50 U.S.C. §1702(b).
5.3. When withdrawn for consumption, duties are assessed based on the HTSUS rate applicable at the time of zone admission.
6. Duty Drawbacks
6.1. Additional duties under the reciprocal tariff are eligible for drawback (refund) claims.
7. De Minimis Exemption
7.1. Unless otherwise specified in the April 2 Executive Order, the de minimis exemption under 19 U.S.C. §1321(a)(2)(C) remains in effect.
7.2. Applies to qualifying items under HTSUS 9903.01.25.
7.3. Includes eligible goods shipped to the U.S. via international postal networks.
8. Declaration Rules
8.1. For entry lines containing multiple HTSUS codes:
Each tariff must align with the correct HTSUS code.
The 10% reciprocal duty must be declared with HTSUS 9903.01.25.
Do not consolidate or combine duties across HTSUS codes or within the same entry line.
9. Special Reporting for Goods with U.S. Content (HTSUS 9903.01.34)
9.1. Filers must use two separate lines to accurately calculate duties:
Line 1 (U.S. content):
a) Declare the same HTSUS code from Chapters 1–97 as Line 2.
b) Use the same country of origin.
c) Declare HTSUS 9903.01.34.
d) Report the total value minus the non-U.S. component.
e) Report total quantity.
f) Declare all applicable duties.
Line 2 (non-U.S. content):
a) Use the same HTSUS code and origin.
b) Declare under HTSUS 9903.01.25.
c) Report only the non-U.S. component’s value.
d) Set quantity to zero.
e) Declare all applicable duties.
10. HTSUS Declaration Order
10.1. When declaring multiple HTSUS codes, follow this sequence:
Step 1: Chapter 98 codes (if applicable)
Step 2: Chapter 99 codes for additional duties
Step 3: Trade remedy measures, in this order:
a) Section 301
b) Fentanyl IEEPA
c) Reciprocal IEEPA
d) Section 232 or 201 tariffs
e) Section 232 or 201 quotas
Step 4: Other Chapter 99 codes for alternative duties
Step 5: Other Chapter 99 quota-related codes
Step 6: Chapters 1–97 for basic duty assessment
10.2. The product value must be declared under Chapters 1–97, unless otherwise directed under Chapter 98.
11. Additional Information
11.1. CBP will issue further guidance via CSMS (Cargo Systems Messaging Service).
11.2. Importers may request binding rulings on tariff classification, country of origin, etc.
11.3. Full details available at:
https://www.cbp.gov/document/publications/us-customs-and-border-protection-rulings-program
11.4. For declaration errors, contact your assigned CBP client representative or the ACE help desk.
11.5. For questions, email: [email protected].
Disclaimer: Blooming reserves the right of final explanation and
revision for all the information.