• July 31st modifying Recirpocal Tariff

    Question: I need clarification on a potential conflict in the July 31, 2025 Executive Order “Further Modifying the Reciprocal Tariff Rates”: Section 2(c) states that “the additional ad valorem rate of duty applicable to any good of the European Union” follows a 15% minimum combined rate structure Section 2(f) preserves “the terms of Executive Order […]

  • Labor for Steel/Alum/Copper Section 232 Derivative

    Question: RE: Section 232 I’ve seen one answer for this question using the beer and aluminum can as an example and I’m still needing to make sure I understand correctly.  For a Derivative item – let’s say it is a tool with metal qualifying parts and the rest is plastic – when removing the plastic […]

  • IEEPA Reciprocal 20% US content calculations

    Question: Has anyone attempted to mitigate the IEEPA reciprocal tariffs using the 20% US input exemption?  I am mainly interested in how to calculate the input of US cotton used in a textile flat good or apparel product, but would be interested in how members have made the calculation and how it was documented. Answer […]

  • 40% Transiphment Tariff Vietnam

    Question: Hi members, Any idea on the 40% transshipment tariff from Vietnam or are we all in the same boat on not understanding how this will be enforced?  Any guidance is welcomed! Answer 1: It is not clear, and appears it is somewhat discretionary.  What I have heard is there likely will an increased review […]

  • EU Reciprocal Tariff – Civil Aircraft & parts

    Question: EU reciprocal tariff is 15% but per the below, it seems that civil aircraft & parts are exempt per the “zero-for-zero” agreement. I cannot find anything in the Federal Register or CBP CSMS that shows this is correct. And, if correct. what is the exemption HTS code? A landmark EU–US trade agreement, finalized on July […]

  • Supplier Letter – Steel/Aluminum/Copper derivatives

    Question: Regarding the calculations for steel/aluminum/copper and the smelt/pour/cast etc. requirements: Is anyone willing to share the verbiage of the letter they’ve sent to their suppliers letting them know that you will need this additional level of information? Answer 1: Here is my suggestion: [Date] [Supplier Contact Name] [Supplier Company Name] [Supplier Address] Subject: Request […]

  • What is the difference between a tariff and a duty?

    Question: What is the difference between a tariff and a duty?   This sounds very rudimentary, however, there are conflicting definitions. Answer 1: There are nuances and historical differences (especially outside of US), but for all practical purposes, duty rate or duty amount 100% same meaning as tariff rate or amount. Answer 2: Tariff – a […]

  • Provisional Tariff Numbers

    Question: Hello! How are teams currently communicating which provisional tariff codes apply to entry lines with their Customs brokers? Are you relying on the broker to determine the appropriate codes and then reviewing them after the entry is filed? Alternatively, are there any best practices you can share for proactively communicating the correct codes for […]

  • Managing tariff proof while keeping customer price-blind

    Question: How are other companies managing tariff claims while keeping their customers price blind? It’s a business to gov’t scenario with fixed and firm contracts, so they have access to our BOMs, etc.  They could theoretically do the math. Are you just redacting a 7501 or proving it in a different fashion?  We’re trying to […]

  • Drawback

    Question: With the recent tariff actions imposed by President Trump, I am seeking strong opinions as to whether any or all of these various tariffs can be claimed in drawback. Asked by: Jim Wickstead – Jim.Wickstead@IGT.com Answer 1: Duty drawback is available for legacy use, (prior to this year) and for the April tariff announcements […]

  • Are changes or elaborations to reciprocal tariffs retroactive?

    Question: The vessel sailed from China before effective the date of reciprocal tariffs, and entry was filed claiming exemption.  Afterword, CBP elaborated to say that feeder vessels aren’t the same “mode of transit” as the mother vessel.   Our shipment changed vessels and sailed from Korea after the effective date of the China 125% reciprocal tariffs.  […]

  • Date of export to determine if reciprocal tariffs apply

    Question: We have been using the import date on the entry summary to determine if the Reciprocal tariff is applied or excluded. The date goods were loaded onto a vessel at the port of loading and in transit on the final mode.  The mode being ocean. The mode did not change. It began as ocean and […]