Tariff Resource Center

Last updated: May 27, 2025

This page serves as your central hub for understanding U.S. tariffs under Section 232 and the International Emergency Economic Powers Act (IEEPA). These trade remedies affect importers across multiple industries—especially those dealing in steel, aluminum, and goods from China, Mexico, and Canada. We’ve summarized key rules and provided useful examples to keep your logistics operations compliant and efficient.

Section 232 Tariffs: National Security-Based Duties

Section 232 tariffs are authorized under the Trade Expansion Act of 1962, allowing the U.S. government to impose duties on imports that threaten national security. These measures primarily target imports of steel and aluminum.

Key Points for Importers

  • Duties apply based on the country of origin and HTS classification.
  • Goods transshipped using immediate transportation (IT) entries are assessed tariffs at the port of first entry.
  • Goods entering U.S. foreign trade zones (FTZs) must be in privileged foreign status to comply with 19 CFR 146.41.
  • Temporary Import Bonds (TIBs) are allowed but must fully cover Section 232 duties.
  • Articles under HTS 9903.01.33 are excluded from reciprocal tariffs.

Exemptions & Exclusions

  • Products with valid exclusions are listed in the CBP Exclusion Database (updated weekly).
  • Section 321 low-value shipments are typically exempt unless subject to quota.
  • U.S.-origin content (20% or more) may be exempt under 9903.01.34 (split-line reporting required).

IEEPA Tariffs: Reciprocal Duties Under Executive Orders

Under the International Emergency Economic Powers Act (IEEPA), reciprocal tariffs are imposed to address significant trade imbalances and unfair trade practices—especially concerning imports from China, Hong Kong, and Macau.

IEEPA Duty Rules

  • IEEPA tariffs are in addition to normal Column 1 duties and other trade remedies like Section 301 or Section 232.
  • Country of origin must be accurately reported; U.S. territories are treated differently under General Note 3(a)(iv).
  • Exemptions exist for qualifying USMCA goods under HTS 9903.01.26 (Canada) and 9903.01.27 (Mexico).
  • Goods with at least 20% U.S. content must be split into two HTS lines to properly apply the exemption under 9903.01.34.

Reciprocal Tariff Transit Eligibility Table

Load Date on VesselEntry Date into U.S.HTS CodeTariff RateNotes
Before April 5, 2025On/after April 5, 2025 and before May 27, 20259903.01.28ExemptApplies if cargo was loaded on the final U.S.-bound vessel before cutoff
April 5–8, 2025Before May 27, 20259903.01.2510%Unless another exemption applies
April 9, 2025Before May 27, 20259903.01.2510%Only applies to goods from China, Hong Kong, or Macau
April 10–May 13, 2025Same day or later9903.01.63125%For China-origin goods unless excluded
May 14, 2025Same day or later9903.01.2510%Tariff rate resets

Common Mistakes to Avoid

  • Misreporting HTS codes under transloaded shipments (e.g., use of feeder vessels invalidates in-transit exemptions).
  • Failing to split entry lines for U.S. vs. non-U.S. content under 9903.01.34.
  • Applying the incorrect exception code (e.g., using 9903.01.28 for air freight).

Need Help?

Tariff rules can be complex. Zarach Logistics helps importers ensure compliant filings, obtain exclusions, and minimize duty exposure. Let us handle the technical side so you can focus on operations.

Get in Touch with Our Team

References & Updates