Update on Reciprocal Tariffs

GUIDANCE ON IMPLEMENTATION OF THE RECIPROCAL TARIFFS:   CBP has issued guidance on the new tariffs: CSMS # 64649265 - GUIDANCE – Reciprocal Tariffs, April 5, 2025 Effective Date.  Note, that shipments must be loaded, in transit on the final mode of transit before 5 April AND entered before May 27 to avoid the additional 10% duty.  See excerpt from the CBP message:

• 9903.01.28:   Articles the product of any country that were (1) loaded onto a vessel at the port of loading and in transit on the final mode of transport prior to entry into the United States before 12:01 a.m. EDT on April 5, 2025, AND (2) are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025.
• To prevent importers from abusing the exception for goods that were in transit before April 5, 2025 when it is no longer realistic due to the passage of time, CBP will permit heading 9903.01.28 to be declared only for goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on May 27, 2025.

We anticipate we will see similar guidance from CBP related to the HIGHER reciprocal tariffs that will hit on 9 April.

FULL TARIFF IMPACT ANALYSIS:  As noted in our previous alert regarding President Trump’s reciprocal tariffs, we have completed our tariff cost impact analysis on U.S. imports of PMMI members’ food processing and packaging machinery and estimate $1.4 B of additional tariff costs on $6.3 B worth of imports.  

Please note our tariff analysis includes one code: HS 8422.90.0640, PARTS OF HOUSEHOLD TYPE DISHWASHING MACHINES, which is subject to Section 232 and therefore currently exempt from reciprocal tariffs.