New tariffs on goods originating outside North America, effective April 5, 2025

The government of the United States announced it will be imposing new tariffs to reciprocate against the higher tariff rates of its trading partners and what it deems to be unfair, non-monetary trade barriers.

Effective 12:01 a.m. ET on April 5, 2025, all imports coming into the U.S. from outside of North America will be subject to a standard 10% tariff. This tariff will be applied over and above existing Most-Favored Nation (MFN) tariff rates and any other applicable tariffs.

In addition, imports originating from a select list of approximately 60 countries will be tariffed at a higher rate, irrespective of product, effective 12:01 a.m. ET on April 9, 2025.

Impact on Canada and Mexico
Canada and Mexico will not be impacted by this latest tariff action as the U.S. government has already imposed tariffs of 25% on all goods originating in Canada and Mexico, save for energy products and potash, which are tariffed at 10%.

As such, the additional standard 10% tariff noted above will not be applied to goods originating in Canada and Mexico until such time that the current 25% tariff has been suspended or cancelled.

Calculation of duties
It is important to note that the aforementioned duties of 10% or more will be applied only to the non-U.S.-originating portions of the imported product, provided the U.S.-originating portion makes up 20% or more of the product’s total value.

This will be particularly important for importers with globally integrated supply chains that make use of a mix of U.S. and foreign production facilities to manufacture components of their goods.

Impact on low-value goods (excluding China)
The new tariffs of 10% or more will apply to all low-value shipments that fall within the de minimis threshold of $800. However, the application of these tariffs on low-value shipments will only take effect at a yet-undefined date in the future when the Department of Commerce has established an effective means of collecting duties on these items.

Impact on low-value goods originating in China and Hong Kong
Effective 12:01 a.m. ET on May 3, 2025, goods that fall within the $800 de minimis threshold that originate in China or Hong Kong, and that are transported into the U.S. via courier, will be subject to all applicable duties.

Low-value goods that enter the U.S. through postal service will be subject to a tariff rate of 30%, or a fee of $25 per package ($50 after June 1, 2025) in instances where the value of the product is not listed). In addition, U.S. Customs and Border Protection (CBP) may, at its discretion, require a formal customs entry for goods entering the U.S. from China or Hong Kong through the international postal network. In the event a formal entry is required, the good will be subject to the standard applicable duties, rather than the aforementioned 30% tariff rate or $25 package fee.

Exemptions
The newly introduced reciprocal tariffs will not be eligible for exemption or duty drawback. However, a small number of products have been exempted from these tariffs, including:
• Automobiles (which have a separate, universal tariff of 25% applied, effective 12:01 a.m. ET on April 3, 2025.
• Automobile parts (which will have a separate, universal tariff of 25% applied, effective 12:01 a.m. ET on May 3, 2025.
• Steel and aluminum products
• Steel and aluminum derivatives
• Other products, including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products

Impact on Customs bonds
The implementation of a 25% tariff may push importers’ duty outlay beyond the value of their current customs surety bond. It is important to understand the impact of these tariffs to your customs surety and be proactive in addressing any surety shortfall. For more information, please refer to the article ‘New tariffs may require importers to secure and/or increase customs surety bonds’.