On April 9, 2025, President Donald Trump issued an Executive Order (EO) announcing that he was pausing the country-specific reciprocal tariffs and, instead, leaving in place for 90 days the baseline 10% tariffs on all countries that was implemented on April 5, 2025. The President, however, noted that this pause would not apply to imports of goods from China and, effective on April 10, 2025, such goods would be subject to an additional ad valorem duty rate of 125%. The suspension of the higher country-specific duty rates will remain in effect until July 9, 2025.

U.S. Customs and Border Protection (CBP) later confirmed these actions in a Cargo Systems Messaging Service (CSMS) announcement. CSMS # 64701128 states that:

  • The country-specific rates that became effective on April 9, 2025 are suspended.
  • Imported products of any country, except for China, including products of Hong Kong and Macau, other than those that fall within the identified exceptions included in CSMS # 64680374, entered for consumption, or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on April 10, 2025, are subject to the following Harmonized Tariff Schedule of the United States (HTSUS) classification and additional ad valorem duty rate:
    • 9903.01.25: Articles the product of any country, except for products described in headings 9903.01.26-9903.01.33, and except as provided for in heading 9903.01.34, and except for articles the product of China, including products of Hong Kong and Macau, will be assessed an additional ad valorem duty rate of 10%.
  • Imported products of China, including products of Hong Kong and Macau, other than those that fall within the identified exceptions included in CSMS # 64680374, entered for consumption, or withdrawn from warehouse for consumption on or after 12:01 a.m. ET on April 10, 2025, are subject to the following HTSUS classification and additional ad valorem duty rate:
    • 9903.01.63: Articles the product of China, including products of Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125%.

The President also again revised upward the additional duty rates that will apply to de minimis shipments of products from China. Accordingly, the April 9, 2025 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 120% of the value of the postal item; or,
  • A specific duty “per postal item containing goods” of $100 between May 2 through May 31, 2025, and $200 beginning June 1, 2025.

For additional background and detail on these tariffs, see Thompson Hine Updates of April 3, 2025, April 8, 2025 and April 9, 2025.

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 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 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 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.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

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.