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 | Trump Administration Clarifies Scope of "Semiconductor" Exclusion from Baseline and Reciprocal Tariffs |
| DATE | April 11, 2025 |
| AGENCY | Executive Branch; CBP Cargo Systems Messaging Service (CSMS) notice |
| EFFECTIVE DATE | April 5 2025, 12:01 a.m. Eastern Time |
| BACKGROUND | Executive Order 14257, issued April 2, 2025, and published in the Federal Register Notice, "Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits," 90 FR 15041 (Apr. 7, 2025), as amended by Executive Order 14259, issued on April 8, 2025, "Amendment to Reciprocal Tariffs and Updated Duties as Applied to Low-Value Imports from the People's Republic of China," and as further amended by the Executive Order dated April 9, 2025, "Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment" did not define "semiconductors" in listing the products in its exception from the baseline and reciprocal tariffs. |
| DETAILS | On April 11, the Trump Administration announced the Clarification of Exceptions Under Executive Order
14257 of April 2, 2025, as Amended – The White House, and
CBP issued corresponding CSMS notice CSMS # 64724565 – UPDATED GUIDANCE –
Reciprocal Tariff Exclusion for Specified Products; April 5, 2025
Effective Date. These actions clarify the products properly
classified in the headings and subheadings of the Harmonized Tariff
Schedule of the United States (HTSUS) and excepted from the
baseline and reciprocal tariffs. The clarification has retroactive effect for merchandise entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Daylight Time on April 5, 2025. For products classified in the below headings and subheadings, importers should report the secondary classification under heading 9903.01.32 to declare the exception from the reciprocal tariff provided in heading 9903.01.25, or in headings 9903.01.43 – 9903.01.62 or 9903.01.64 – 9903.01.76 on April 9, 2025, or in heading 9903.01.63 since April 9, 2025. According to the notice, importers of products covered by the below HTSUS provisions entered for consumption or withdrawn from warehouse for consumption on or after April 5, 2025, should take action to correct entries as necessary to reflect the exception under heading 9903.01.32, "as soon as possible within 10 days of the cargo's release from CBP custody." |
| BASIS | International Emergency Economic Powers Act (IEEPA), 50 U.S. Code § 1701 et seq. |
| HTS/ PRODUCTS |
9903.01.32:
|
| COUNTRY | All |
| CITE | Executive Order Clarification of Exceptions Under Executive Order
14257 of April 2, 2025, as Amended – The White
House, CSMS Notice CSMS # 64724565 – UPDATED GUIDANCE – Reciprocal Tariff Exclusion for Specified Products; April 5, 2025 Effective Date. |
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.
