
On May 15, 2025, U.S. Customs and Border Protection (“CBP”) published an FAQ stating that the “in-transit” exception for the reciprocal tariff duty rate does not apply to goods loaded onto a “feeder” vessel prior to April 5 (the IEEPA cutoff date under HTSUS 9903.01.28) or April 9 (the IEEPA cutoff date under HTSUS 9903.01.43