Charts on the Reciprocal and IEEPA and Other Tariffs
Carmichael has put together charts as an overview to explain the details on President Trump’s tariffs. It includes all the current additional duties assessed by this administration, the duty rates, and the effective dates. They include a chart of the countries and duty assessments for the 60 countries assessed with more than 10%, which have been postponed for 90 days. We hope that you find it to be a very helpful aid as you try to steer through the variety of tariffs and their requirements. These charts can be found at: http://www.carmnet.com/wp-content/uploads/2025/04/TRADE-REMEDY-TARIFF-CHARTS-1.pdf . Please contact us if you have any questions.
Exclusion for Items Already Sailed by April 5, 2025
There is an exemption from Reciprocal Tariffs for goods that were in transit by rates going except that goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on April 5, 2025, and entered for consumption or withdrawn from warehouse for consumption after 12:01 a.m. eastern daylight time on April 5, 2025, shall not be subject to such additional duty into effect on either April 5 or April 9. The shipments must be entered before May 27 to take advantage of the exemption. The language of the exemption states “except that goods loaded onto a vessel at the port of loading and in transit on the final mode of transit.”
There is an unanswered question on this statement. If the cargo, while in transit, changes to another vessel, will it still qualify for the exemption, or does the cargo have to stay on the original vessel. The statement refers to the final mode of transit, which would remain as ocean freight. U.S. Customs and Border Protection (CBP) has not confirmed if a transfer between vessels will invalidate the exemption. We believe that as long as cargo remains on an ocean mode of transit, the exemption shall apply, and this is our default position. If CBP issues instructions that the cargo must have stated on the same vessel, the additional duty will be required to be paid. If you make a business decision and want us to pay the reciprocal duty at time of entry for goods that have transferred vessels, please let us know.