ARTICLE
11 September 2025

49. September 4, 2025 | U.S.-Japan Trade Agreement

TC
Thompson Coburn LLP

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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.
United States International Law

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. 

TRUMP ADMINISTRATION TRADE ALERT – IMPORTS
HEADLINE U.S.-Japan Trade Agreement
DATE September 4, 2025
AGENCY Trump Administration; Department of Commerce; United States Trade Representative; Department of Homeland Security; Customs and Border Protection (CBP); United States International Trade Commission
EFFECTIVE DATE August 7, 2025, 12:01 a.m. Eastern Time (retroactive)
BACKGROUND On April 2, 2025, the Trump Administration issued sweeping Reciprocal Tariff rates – with a baseline 10% tariff on all imports, effective April 5, and enhanced country-specific rates as specified in Annex I, effective April 9, which were then suspended until July 9. In Annex I to this order, Japan had a 24% Reciprocal Tariff rate.

On July 31, 2025, the Administration published revised Reciprocal rates to go into effect on August 7, 2025. Japan had a 15% Reciprocal Tariff rate.
DETAILS

On September 4, 2025, the Administration issued an Order "Implementing the United States-Japan Agreement," confirming the 15% tariff on "nearly all Japanese imports," with certain sector-specific treatment for products in the automobile, aerospace, pharmaceutical, and natural resource industries. The Government of Japan has agreed to invest $550 billion in the U.S. to generate jobs and domestic manufacturing.

The Order contains following provisions:


  • The 15% tariff rate for Japan now mimics that for the EU, where the ordinary column one HTS duty rate + the Reciprocal rate will equal 15%.
  • The Section 232 sector tariffs for Japan apply in the following way:
    • Civil aircraft subject to 0% steel, aluminum, copper, and Reciprocal rates. Importantly, the Secretary will determine what constitutes "products of Japan" for civil aircraft.
    • Automobiles & auto parts subject to the Japan 15% rate and not 25% automobile rate.
    • Pharmaceuticals & pharma ingredients (Section 232 action not yet published) subject to 0% Reciprocal rate.

While the tariff rate revisions are retroactive to "products of Japan" (a term that will be further defined by additional rules yet to be released by CBP) entered on or after August 7, 2025, CBP instructed "the trade community is not to file a Post Summary Correction or protest until CBP issues instructions on how those requests for refunds should be submitted."

BASIS International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (IEEPA), the National Emergencies Act (50 U.S.C. 1601 et seq.), section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862) (section 232), section 604 of the Trade Act of 1974, as amended (19 U.S.C. 2483), and section 301 of title 3, United States Code
HTS/
PRODUCTS
All, unless otherwise exempted by subsequent agreement or specified in agreement
COUNTRY Japan
CITE White House – Implementing The United States–Japan Agreement – The White House

Federal Register – Federal Register :: Implementing the United States-Japan Agreement

CBP – CSMS # 66146676 – INTERIM GUIDANCE: Retroactive Implementation of the United States-Japan Agreement

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.

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