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
| THOMPSON COBURN TRADE ALERT – IMPORTS | |
|---|---|
| HEADLINE | Reciprocal Tariffs on China/HK/Macau Increased to 125% |
| 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. The specific tariff rate announced at that time for goods from China was 34%. On April 8, 2025, China's rate was raised to 84%, with additional increased duties on de minimis shipments from China. |
| DETAILS | Starting on April 10, 2025, the
enhanced reciprocal tariff rate for China (defined to include Hong
Kong and Macau), which was initially announced at 34%, has been
raised to 125%. This represents a 91% increase in the rate
applicable to Chinese origin goods, in addition to other tariffs
(unless exempted, see below). In-Transit Goods. Goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. EDT April 9 will not be subject to the respective additional tariffs so long as they are entered before May 27. Exemptions. No other aspect of the "reciprocal" tariff program exemptions changed as a result of the increased tariff on China. The following exemptions remain: " Steel or aluminum articles and derivatives subject to Section 232 duties; " Automobiles and automotive parts subject to recently imposed Section 232 duties; " Copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, energy and energy products, and other products (set forth in Annex II**); " Imports subject to column 2 rates of duties (goods from Cuba, North Korea, Russia, and Belarus); " Goods subject to future Section 232 actions; " Goods validly claiming exemption under Chapter 98 duty relief. China is not included in the recent 90-day pause on reciprocal tariffs. |
| BASIS | International Emergency Economic Powers Act of 1977 (IEEPA) |
| HTS/PRODUCTS | All products. 9903.01.63: Articles the product of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125%. |
| COUNTRY | 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.
