U.S. Orders 90-Day Reciprocal Tariff Pause and Continues Tariff Pressure on China

On April 9, 2025, the White House ordered a 90-day pause for all country-specific reciprocal tariffs with an immediately effective rate of 10% on products of all countries other than China. As of this writing, the White House has increased the reciprocal tariffs on Chinese-made goods to 125%.

Effective April 9, 2025, the combined tariff rate for products from China is now 145%, plus product-specific duty rates. Shipments of products that were on the water as of April 5, 2025, will not be subject to these increases.  Low-value shipments under $800 will not be subject to these increases before May 2, 2025.

After May 2, 2025, all shipments from China, regardless of value, will be subject to a minimum duty payment. Shipments through the postal system valued at less than $800 will be assessed 90% of the declared value or $75, at the election of the shipper. Shipments valued at less than $800 through all other transit options will be assessed the then-current duty rate. Shippers are expected to use the same collection methodology for all shipments.

After June 3, 2025, shipments through the postal system valued at less than $800 will be assessed 90% of the declared value or $150, at the election of the shipper. All shipments by the shipper shall be assessed using the same collection methodology.

These changes do not impact current tariff rates for steel, aluminum, and certain products containing steel or aluminum, automobiles and automotive parts, potash, copper, pharmaceuticals, semiconductors, lumber, bullion, energy, critical minerals not available in the United States, and national defense needs.  Imported products containing at least 20% U.S. parts or materials may be claim a partial exemption and pay the reciprocal tariff on only the non-U.S. value portion. 

In the United States, tariffs are collected by CBP from the importer of record, which is the party that owns or has purchased the products being imported.  The importer of record is responsible for properly declaring the value, classification, and country of origin of entered products, as well as paying duties, taxes, and other fees.

Honigman’s Regulatory & Executive Order Task Force is closely monitoring developments and offering guidance to help businesses navigate these changes. Please reach out to Angela Gamalski, Chauncey Mayfield, or another member of the Regulatory Practice Group or Commercial Transactions Practice Group with any questions or for further assistance in navigating these changes.