ARTICLE
29 September 2025

50. September 5, 2025 | Modification Of Reciprocal Tariffs

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Thompson Coburn LLP

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Trump Administration; Department of Commerce; United States Trade Representative; Department of Homeland Security...
Worldwide International Law
TRUMP ADMINISTRATION TRADE ALERT – IMPORTS
HEADLINE Modification of Reciprocal Tariffs
DATE September 5, 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 September 8, 2025, 12:01 a.m. Eastern Time
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.

On April 9, 2025, the enhanced country-specific Reciprocal Tariffs were suspended for 90 days until July 9 (except China), to allow for renegotiations of the new rates from the affected countries. Separately, on May 12, the Trump Administration also suspended its reciprocal tariffs on China for 90 days until August 12. On July 7, 2025, the Trump Administration issued an Executive Order extending the July 9 deadline for new reciprocal tariff rates until August 1, 2025.

On July 31, 2025, an Order enacted the Reciprocal Tariff rates effective August 7.
DETAILS On September 5, 2025, the Trump Administration issued an Executive Order further modifying Reciprocal Tariff rates.

ANNEX II:
Goods exempt from the Reciprocal tariffs under Annex II have been modified under Annex I, adding 39 HTS classifications and removing 8.

SECTION 232:
The Order states the President will "refrain from narrowing the scope of the reciprocal tariff or any relevant section 232 tariff before the conclusion of a final trade and security agreement."

AGREEMENTS:
The Order reiterates the implementation of free-trade agreements allowing for modified Reciprocal rates for certain countries and refunds of applicable.
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
COUNTRY All, unless under current or subsequent trade agreement
CITE White House – Modifying The Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreements – The White House

CBP – CSMS # 66151866 – UPDATE – Products Exempted from Reciprocal Tariffs

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