
On April 8, 2025 U.S. Customs and Border Protection (“CBP”) issued a Cargo Systems Messaging Service (“CSMS”) Message # 64680374which sets forthadditional guidance on the reporting of reciprocal tariffs set to take effect on April 9, 2025. This guidance is an update to CSMS # 64649265 previously issued on April 4, 2025.
The President issued Executive Order 14257, titled “Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits,” on April 2, 2025 and published in the Federal Register on April 7, 2025. See Husch Blackwell’s previous update here.
CBP’s April 8, 2025 CSMS guidance details the Chapter 99 headings to be used for the reporting of country-specific reciprocal tariffs listed in Annex I.
Effective April 5, 2025, products subject to the 10% baseline reciprocal tariffs are to be reported under HTSUS 9903.01.25.Effective April 9, 2025, the 10% reciprocal tariff will be replaced with country-specific rates for imported products from 83 specific countries, which must be reported under HTSUS 9903.01.43 through 9903.01.76. Provided below is a sample list of countries and reporting numbers. Importers should review the complete CSMS message linked above for countries not listed below:
- China – HTSUS 9903.01.63
- European Union (EU) – HTSUS 9903.01.50
- Japan and Malaysia- HTSUS 9903.01.53
- India – HTSUS 9903.01.55
- South Korea – HTSUS 9903.01.54
- Cambodia – HTSUS 9903.01.75
- Vietnam – HTSUS 9903.01.72
Articles exempt from the reciprocal tariffs, such as products of Canada and Mexico that qualify for USMCA treatment, are to be reported under HTSUS 9903.01.26 and 9903.01.27,respectively.
In-transit products are exempt from the reciprocal tariffs if (1) loaded onto a vessel at the port of loading and in transit on the final mode of transport prior to entry into the United States before 12:01 a.m. EDT on April 5, 2025, AND (2) are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on May 27, 2025. These products must be reported under HTSUS 9903.01.28. Note that products subject to country-specific rates loaded on a final mode of transport on or after April 5 but before April 9 will be subject to the 10% baseline rate rather than the country-specific rate.
Other exempt products such as those listed in Annex II of the EO or products subject to Section 232 tariffs such as steel and aluminum articles including derivative products, passenger vehicles, light trucks and parts thereof must be reported under HTSUS 9903.01.32 and 9903.01.33 respectively.
The CSMS confirms that for articles in which at least 20% of the value of the article is U.S. originating, the U.S. content will not be subject to the reciprocal tariff, which will still be assessed on the non-U.S. content. These articles are to be reported under HTSUS 9903.01.34.
In addition, on April 7, 2025, CBP updated its list of Frequently Asked Questions (FAQs) on Steel and Aluminum on its website. The updated FAQs are available here.
The Husch Blackwell Trade team continues to monitor developments and will provide additional updates as they arise.