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Executive Order 14257: U.S. Reciprocal Tariffs

Full ananylsis of the 5 core elements trade professionals need to know about U.S. reciprocal tariffs under EO14257, as amended (incl. downloads + links)



The July 31, 2025, the EO, “Further Modifying the Reciprocal Tariff Rates” amended EO 1425, changing the rates of duty that apply to take account of the EU-US trade deal.


On September 5th 2025, the EO was further amended as outlines below.


Trade Deficits Threaten U.S. Security & Manufacturing

Executive Order 14257 critiques post-war trade policies for failing to create fair or reciprocal conditions. It cites tariff disparities, non-tariff barriers, and currency manipulation that disadvantage U.S. exports. The order highlights the decline in U.S. manufacturing and stresses the need to restore capacity in critical sectors like defense, technology, and pharmaceuticals. Manufacturing job losses are linked to broader economic and social challenges, posing a threat to national security and economic stability. The order provides the legal basis for reciprocal tariffs and trade measures to rebalance trade and revitalize U.S. industry and innovation,


Five Core Elements of Executive Order 14257, as amended


Following the first three core elements outlined in the initial Executive Order 14257, as amended, the update order "Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreement" clarified how the U.S. implements tariffs and trade/security agreements with foreign partners, leading to the fourth core element.


FIRST: Application of Additional Duties (Reciprocal Tariff Policy): 10% Additional Baseline Tariff

  1. A 10% additional baseline tariff will be applied on imports. Certain trading partners listed in Annex I will face further increases. These tariffs are applied on top of existing Most-Favored-Nation (MFN) rates.


Chapter 98 and IEEPA Reciprocal Duties Overview


  1. General Rule for Chapter 98 EntriesAdditional duties under the IEEPA Reciprocal Tariffs do not apply to goods properly entered under Chapter 98 provisions of the HTSUS, provided U.S. Customs and Border Protection (CBP) agrees the entry is appropriate.


  2. Exceptions – Certain Subchapters and SubheadingsAdditional duties do apply to goods entered under:

    • Subchapter XIX (9819) – Africa Growth and Opportunity Act (AGOA)

    • Subchapter XX (9820) – U.S.–Caribbean Basin Trade Partnership Act

    • Subchapter XXII (9822) – Various other Free Trade Agreements

    • Subheadings: 9802.00.40, 9802.00.50, 9802.00.60, and 9802.00.80


  3. Temporary Importation Under Bond (TIB) – Subchapter XIII (9813)

    • Goods entered under 9813 must report the dutiable IEEPA Reciprocal Chapter 99 number, along with the 9813 and 1–97 HTSUS numbers.

    • No IEEPA duties are due if the TIB filing is compliant.

    • Reporting the Chapter 99 number ensures proper bonding if the goods fail to meet 9813 requirements.


SECOND: Reciprocal Tariff Policy: Additional Higher Tariff Some trading partners listed in Annex I will be subject to higher tariffs. These are in addition to any other duties or fees already imposed. As per the July 31st, 2025 EO, goods are subject to the reciprocal tariffs under HTSUS classifications 9903.02.02 – 9903.02.71, as added by Annex II of the EO as per CBP's CSMS.

For goods from the European Union, the reciprocal tariff depends on the Column 1/General duty rate. If the Column 1 rate is 15 percent or higher, the reciprocal tariff is zero, and entries must be filed under heading 9903.02.19. If the Column 1 rate is below 15 percent, the sum of the Column 1 rate and the reciprocal tariff is 15 percent, with entries filed under heading 9903.02.20.For goods from the European Union, the reciprocal tariff depends on the Column 1/General duty rate. If the Column 1 rate is 15 percent or higher, the reciprocal tariff is zero, and entries must be filed under heading 9903.02.19. If the Column 1 rate is below 15 percent, the sum of the Column 1 rate and the reciprocal tariff is 15 percent, with entries filed under heading 9903.02.20.

The July 31, 2025, Executive Order modifying reciprocal tariff rates does not affect EO 14298 regarding China. Goods from China, including Hong Kong and Macau, remain subject to the 10 percent reciprocal tariff under heading 9903.01.25.

USMCA: Canada & Mexico

Goods originating under USMCA remain duty-free. Non-originating goods face IPEEA tariffs for drug trafficking (not reciprocal tariffs), outlined elsewhere


The current rates as per the July 2025 Order are :


  • Afghanistan – 15%

  • Algeria – 30%

  • Angola – 15%

  • Bangladesh – 20%

  • Bolivia – 15%

  • Bosnia and Herzegovina – 30%

  • Botswana – 15%

  • Brazil – 10%

  • Brunei – 25%

  • Cambodia – 19%

  • Cameroon – 15%

  • Chad – 15%

  • Costa Rica – 15%

  • Côte d’Ivoire – 15%

  • Democratic Republic of the Congo – 15%

  • Ecuador – 15%

  • Equatorial Guinea – 15%

  • European Union – Goods with Column 1 Duty Rate >15%: 0%

  • European Union – Goods with Column 1 Duty Rate <15%: 15% minus Column 1 Duty Rate

  • Falkland Islands – 10%

  • Fiji – 15%

  • Ghana – 15%

  • Guyana – 15%

  • Iceland – 15%

  • India – 25%

  • Indonesia – 19%

  • Iraq – 35%

  • Israel – 15%

  • Japan – 15%

  • Jordan – 15%

  • Kazakhstan – 25%

  • Laos – 40%

  • Lesotho – 15%

  • Libya – 30%

  • Liechtenstein – 15%

  • Madagascar – 15%

  • Malawi – 15%

  • Malaysia – 19%

  • Mauritius – 15%

  • Moldova – 25%

  • Mozambique – 15%

  • Myanmar (Burma) – 40%

  • Namibia – 15%

  • Nauru – 15%

  • New Zealand – 15%

  • Nicaragua – 18%

  • Nigeria – 15%

  • North Macedonia – 15%

  • Norway – 15%

  • Pakistan – 19%

  • Papua New Guinea – 15%

  • Philippines – 19%

  • Serbia – 35%

  • South Africa – 30%

  • South Korea – 15%

  • Sri Lanka – 20%

  • Switzerland – 39%

  • Syria – 41%

  • Taiwan – 20%

  • Thailand – 19%

  • Trinidad and Tobago – 15%

  • Tunisia – 25%

  • Turkey – 15%

  • Uganda – 15%

  • United Kingdom – 10%

  • Vanuatu – 15%

  • Venezuela – 15%

  • Vietnam – 20%

  • Zambia – 15%

  • Zimbabwe – 15%


THIRD: Exemptions to Reciprocal Tariffs. Annex II updates which goods might qualify for reduced or zero tariffs based on strategic, economic, and national security considerations. Includes goods not sufficiently produced in the U.S., certain agricultural products, aircraft, and non-patented pharmaceutical materials. The September 5th 2025 order modified this list and provides a framework for adjusting tariffs when foreign partners commit to meaningful trade and security agreements.


Download the 5 September 2025 list


U.S. CBP has clarified in CSMS guidance that the changes to Annex II took effect for goods entered for consumption or withdrawn from warehouse on September 8, 2025. Only products properly classified under the relevant HTSUS headings and subheadings listed in Annex II are exempt from the reciprocal tariff imposed by Executive Order 14257, as amended.


Importers must report the secondary classification under subheading 9903.01.32 for products listed in Annex II to claim the exemption from the tariffs under subheading 9903.01.25, or 9903.02.02 – 9903.02.71.


For pre-filed entries under 9903.01.32 entered on or after September 8, 2025 that include products added to or removed from Annex II, importers must correct entries to reflect the proper reciprocal tariff within ten days of the cargo’s release from CBP custody.


Current Secondary Exemptions Codes


HTSUS Code

Exemption Type / Description



9903.01.26

Products of Canada, including USMCA duty-free items. Secondary classification for 9903.01.10–9903.01.15 required to claim exemption.


9903.01.27

Products of Mexico, including USMCA duty-free items. Secondary classification for 9903.01.01–9903.01.05 required to claim exemption.

9903.01.29

Articles from Column 2 countries: Belarus, Cuba, North Korea, Russia.

9903.01.30

Humanitarian donations (food, clothing, medicine) unless President exempts.

9903.01.31

Informational materials, e.g., publications, films, posters, photos, microfilm, CDs, artworks, news feeds.

9903.01.32

Products listed in Annex II per U.S. note 2 to subchapter III of chapter 99. Only properly classified HTSUS headings qualify.

9903.01.33

Section 232 products: iron/steel, aluminum, copper, passenger vehicles, light trucks, and parts (subdivisions v(vi)–(xi) of U.S. note 2).

9903.01.34

Articles with ≥20% U.S. content. Tariff applies only to non-U.S. content.


FORTH: Framework Agreements: If a foreign partner signs a preliminary trade/security framework agreement, U.S. officials (Commerce and USTR) will evaluate if any tariff adjustments are appropriate. Adjustments may include reducing or suspending reciprocal tariffs or Section 232 tariffs. Examples include the U.S.–EU Framework Agreement, where reciprocal tariffs on certain EU products may drop to 0% and tariffs on EU autos could be reduced.


FIFTH: Transshipment and IEEPA Reciprocal Duties

As per CSMS guidance and EO of July 2025, Goods that CBP determines were transshipped to evade IEEPA Reciprocal duties are subject to an additional 40% ad valorem duty.

  • CBP will either:

    • Direct a correction of the entry or entry summary, replacing the IEEPA Reciprocal HTSUS number with 9903.02.01, or

    • Take action at liquidation to collect the 40% duty.


  • The 40% duty is in addition to:

    • Any fines or penalties

    • Other applicable duties, fees, taxes, or charges based on the goods’ country of origin


Download CBP's Guide on Illegal Transhipment


Read our blog:


New U.S. tariffs target “transshipped” goods—but what counts as transshipment? Here’s what every compliance professional must know


HTSUS Reporting Sequence for CBP 7501 Entry Summaries

As per CBP guidance the correct order is:


  1. Separate Duties by HTSUS Number

    • Each duty must be associated with its specific HTSUS number.

    • Do not combine duties across different HTSUS numbers on the same entry summary line.

    • For printed CBP Form 7501 or ACE transmissions, ensure each duty appears under the correct HTSUS heading.


  2. Special Case – U.S. Content ≥ 20% (Heading 9903.01.34)

    • Split the article onto two entry summary lines:

      • Line 1: U.S. content

      • Line 2: Non-U.S. content (used to calculate reciprocal tariff additional duty)


  3. Reporting Sequence for Multiple HTSUS Numbers

    1. Chapter 98 number (if applicable)

    2. Chapter 99 numbers for additional duties, in this order if applicable:

      • Section 301

      • IEEPA Fentanyl

      • IEEPA Reciprocal

      • Section 232 or 201 duties

      • Section 201 or 232 quota

    3. Chapter 99 numbers for replacement duties or other provisions (e.g., MTB)

    4. Chapter 99 numbers for other quotas (not covered in step 2)

    5. Chapter 1–97 number for the commodity tariff


  4. Entered Value Reporting

    • Report the commodity’s entered value under the Chapter 1–97 number

    • Exception: If Chapter 98 provisions require a different allocation of value



Links


Download the Executive Orders


Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff To Rectify Trade Practices That Contribute to Large and Persistent Annual United States Goods Trade Deficits):



EO: Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreement




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