Reciprocal Tariffs Do Not Cover Products Already Covered by 232 Tariffs

Government Relations, Section 232, Trade and Tariffs

The White House has released more detailed information about the reciprocal tariff program. Here’s the update:

A reciprocal tariff of 10% will apply to imports which are entered on or after April 5, 2025.  However, reciprocal tariffs will not apply to goods which are loaded onto a vessel at the port of loading and in transit on the final mode of transit before April 5, 2025, and entered after April 5, 2025.

Effective on April 9, 2025, imports from countries with an individual reciprocal tariff rate (see Annex I for the list of these countries) will be subject to the country-specific reciprocal tariff rate.  However, the country-specific reciprocal tariffs will not apply to goods which are loaded onto a vessel at the port of loading and in transit on the final mode of transit before April 9, 2025, and entered after April 9, 2025.

The following groups of products are NOT subject to the reciprocal tariffs:

  •  Steel and aluminum products and their derivative products which are already subject to Section 232 tariffs.
  • Automobiles and automobile parts which are already subject to Section 232 tariffs.
  • Copper, pharmaceuticals, semiconductors, lumber products, energy and energy-related products, and certain critical minerals. See Annex II for complete listing.
  • Products that may become subject to Section 232 tariffs in the future.
  • Bullion
  • Certain products, such as postal or telephonic communications; donations intended to relieve human suffering; informational materials such as publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, and artworks; accompanied baggage of travelers.

While the special 25% tariffs are in effect on Canada and Mexico, the reciprocal tariffs announced today will not apply.  However, if the special 25% tariff is terminated or suspended, then products which do not qualify as originating under USMCA will be subject to a reciprocal tariff of 12%.

The reciprocal tariff rates will apply only to the non-U.S. content of an imported product, provided at least 20% of the value of the product originated in the United States.  “U.S. content” means the value of a product attributable to components produced entirely, or substantially transformed in, the United States.

You can read the full Executive Order here.

The White House Fact Sheet on Reciprocal Tariffs is here.

A searchable list of tariffs by country is here.

We will provide additional information as it becomes available.