In an era marked by global unrest, regulatory complexities, and a shifting market landscape, companies must remain diligent in their trade compliance procedures and stay apprised of changes in the law.
TC Trade Alerts will serve as a central resource for identifying the policy changes, executive orders, and necessary information and context regarding government actions affecting international trade.
See below for more information on the last TC Trade Alerts. If you have any questions about how this affects your business, please don't hesitate to contact one of our attorneys.
Additional Resources
Trade Compliance Handbook | Checklists of Foreign Countries Subject to Sanctions | Our International Trade Practice
TRADE ALERT – IMPORTS | |
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HEADLINE | 90-Day Pause on Enhanced Reciprocal Tariffs, Except for China |
DATE | April 9, 2025 |
AGENCY | Trump Administration; Department of Commerce; United States Trade Representative; Customs and Border Protection |
EFFECTIVE DATE | 12:01 am EDT on April 10, 2025 |
BACKGROUND | On April 2, 2025, the Trump Administration announced a "baseline" 10% tariff on imports from all countries effective April 5, and enhanced "reciprocal" tariff rates for specific countries effective April 9. |
DETAILS | On April 9, 2025, the Trump Administration announced via social
media a 90-day "pause" on the country-specific reciprocal
tariffs, with the exception of China. Instead, these country tariff
rates fall to 10% in line with the other countries only subject to
the "baseline" tariff rate. This was confirmed in an
Executive Order published April 10, 2025. The Executive Order specifically states that the pause is effective until 12:01 a.m. EDT July 9, 2025. The Cargo Systems Messaging Service guidance implementing this change only noted that the country-specific reciprocal tariffs "are suspended" and did not provide an expiration date for the suspension. |
BASIS | International Emergency Economic Powers Act of 1977 (IEEPA) |
HTS/PRODUCTS | All products. " 9903.01.25: Articles the product of any country, except for products described in headings 9903.01.26-9903.01.33, and except as provided for in heading 9903.01.34, and except for articles the product of China, including products of Hong Kong and Macau, will be assessed an additional ad valorem duty rate of 10%. |
COUNTRY | All countries, except for China/HK/Macau |
CITE | Modifying Reciprocal Tariff Rates to Reflect
Trading Partner Retaliation and Alignment – The White
House CSMS # 64701128 – UPDATED GUIDANCE – Reciprocal Tariffs – Increase in Rate for China and Reversion of Other Country-Specific Rates, Effective April 10, 2025 |
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.