Reciprocal Tariffs & Trade Agreement Framework
To Our Valued Partners,
On September 5, 2025, President Trump signed an Executive Order updating U.S. reciprocal tariff policy. This action amends Annex II (exemptions) and creates a new Annex III list of potential tariff reductions under future trade and security deals. It also expands the list of HTS codes subject to reciprocal tariffs in Annex I, which becomes effective September 8, 2025. (Annex III to Executive Order 14346 of September 5, 2025)
This update affects a wide range of materials, including metals, chemicals, pharmaceutical ingredients, and electrical components, with significant cost implications for U.S. importers, manufacturers, and distributors.
🚨 Newly Tariffed Goods – Annex I (Effective September 8, 2025)
These 39 HTS codes were newly added to the reciprocal tariff list. U.S. importers must apply the corresponding Section 9903 tariff subheading when declaring these items after the effective date.
✅ Still Exempt from Reciprocal Tariffs (Added Back to Annex II)
These 8 HTS codes were reinstated as exempt and remain duty-free under the reciprocal tariff program
📌 Filing Note: Importers must declare HTSUS 9903.01.32 to claim the exemption for any of the above products.
🗂️ Annex III – PTAAP (Future Tariff Adjustments)
A new Annex III list identifies product categories that could qualify for reduced or zero tariffs only if a formal trade and security agreement is signed with the U.S.
📦 Example categories (not tied to specific HTS codes yet):
Aircraft and aircraft parts
Generic pharmaceuticals and ingredients
Critical raw materials not available in the U.S.
Agricultural products not grown in sufficient supply domestically
⚠️ Note: These tariff reductions are not automatic; they require new agreements with aligned trade partners.
⚙️ Oversight & Filing Compliance
U.S. Department of Commerce and USTR will oversee implementation.
CBP is responsible for enforcement and refunds, where applicable.
Additional guidance will be issued via CSMS bulletins as agreements evolve.
📅 Effective Date: All Annex II changes apply to goods entered for consumption on or after September 8, 2025.
📌 Entry Corrections: Pre-filed entries must be corrected within 10 days of release from CBP custody.
📥 Resources & Links
✅ Have questions about these changes?
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