De Minimis

On April 2, 2025, President Trump issued an Executive Order (“EO”) imposing a 10% universal tariff on imports from all countries (with certain exceptions described below) pursuant to the International Emergency Economic Powers Act of 1977 (“IEEPA”).  These tariffs will take effect at 12:01 a.m. eastern standard time on April 5, 2025.

The tariff rates

U.S. Customs and Border Protection (“CBP”) is preparing a regulatory change that would eliminate the $800 de minimis exemption for imports subject to Section 301 tariffs, according to a proposed rule submitted by CBP to the Office of Management and Budget (“OMB”) on September 2, 2020.  Reviews of the proposed rule by OMB and an interagency review are the final steps before the publication of a final rule in the Federal Register.