On April 8, 2025, President Donald Trump issued a new Executive Order (EO) to address China’s retaliatory 34 percent tariff it is scheduled to impose on all goods imported into China originating from the United States beginning on April 10, 2025. The President has stated that effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 9, 2025, the reciprocal tariff on imports from China shall increase from 34% to 84%. U.S. Customs and Border Protection (CBP) confirmed this tariff rate increase in a Cargo Systems Messaging Service later in the evening. See CSMS # 64687696.

As a result of this reciprocal tariff rate increase, and the previous tariff rate of 20% on all goods coming from China due to President Trump’s February EO to address the synthetic opioid supply chain in China (see Thompson Hine Update of March 3, 2025), the effective overall duty rate on imports from China will now be 104%.

Further, and to ensure that these duties are not circumvented, the EO also modifies an earlier order addressing the application of tariffs on goods entering the United States from China under the “de minimis” rule pursuant to Section 321 of the Tariff Act of 1930; an exemption allowing imports valued at $800 or less to enter the United States with minimal filing requirements and duty-free. Accordingly, the new April 8 EO dictates that all postal items sent to the United States from China and Hong Kong through the international post that qualify for the de minimis exemption will be now be subject to submitting duties to CBP in one of two manners:

  • An ad valorem duty of 90% of the value of the postal item; or,
  • A specific duty “per postal item containing goods” of $75 between May 2 through May 31, 2025, and $150 beginning June 1, 2025.

For additional background on the previous EOs, see Thompson Hine Updates of April 3, 2025 (de minimis)and April 3, 2025 (reciprocal tariffs).

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Dan Ujczo Dan Ujczo

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as…

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as Buy America/Buy American, and anti-dumping/countervailing duty issues. He also advises clients on negotiating transportation agreements, managing trusted trader and related security programs, and addressing issues at ports-of-entry.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.