Tariff Changes for Japanese Products Start Sept 16

15 September 2025 07 MINS. Read USA

On September 16, 2025, the U.S. Department of Commerce announced changes to the Harmonized Tariff Schedule of the United States (HTSUS) related to the U.S.-Japan Agreement, followed by the release of CSMS #66242844 – Updated Guidance – Implementation of the United States-Japan Agreement and Modification of Duties on Imports from Japan.

New HTSUS numbers have been added for the new reciprocal rate, aerospace products that fall under the WTO Agreement on Trade in Civil Aircraft, and Section 232 Automobile and Automobile Parts that are a product of Japan. The changes are effective September 16, 2025.

Details

Reciprocal Tariffs

Duty Rates

The reciprocal tariff for products of Japan is dependent on the Column 1 ad valorem or ad valorem equivalent duty rate applicable to the products.

For a product of Japan with a Column 1 duty rate greater than or equal to 15 percent, the additional reciprocal tariff is zero (0). Use HTSUS heading 9903.02.72.
For a product of Japan with a Column 1 duty rate less than 15 percent, the sum of the Column 1 and the reciprocal tariff rate is 15 percent. Use HTSUS heading 9903.02.73.
Products that have a specific or compound duty rates: The ad valorem equivalent rate of duty of such good shall be determined by dividing the amount of duty payable under column 1 – General by the customs value of the good.
- Example: If a good were subject to a specific duty of 50 cents per kilogram, and one kilogram of the good were entered with a customs value of $10, then the ad valorem equivalent rate of duty would be obtained by dividing 50 cents by $10, yielding 5 percent.

Effective Date

The tariffs shall apply retroactively to products of Japan entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. Eastern Daylight Time on August 7, 2025.
Filers can update previously filed entries to apply the newly issued HTSUS numbers after they are deployed on September 16, 2025.
For products covered by these new HTSUS provisions that are entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern daylight time on August 7, 2025, filers should take action to correct entries as necessary to reflect the modified duty rate applicable under headings 9903.02.72 or 9903.02.73, as soon as possible within 10 days of the cargo’s release from CBP custody and prior to estimated duties being deposited to avoid needing refunds.

Refund Requests

For unliquidated entries for which estimated duties have already been deposited, importers may request a refund upon liquidation by filing a post summary correction. For liquidated entries, importers may request a refund by filing a protest pursuant to 19 U.S.C. 1514.

Civil Aircraft

Products of Japan that fall under the World Trade Organization (WTO) Agreement on Trade in Civil Aircraft, except for unmanned aircraft, are no longer be subject to the tariffs imposed by the following Presidential actions, effective September 16, 2025.

Tariffs That No Longer Apply

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), as amended;
Proclamation 9704 of March 18, 2018 (Adjusting Imports of Aluminum Into the United States), as amended;
Proclamation 9705 of March 8, 2018 (Adjusting Imports of Steel Into the United States), as amended;
Proclamation 10962 of July 30, 2025 (Adjusting Imports of Copper Into the United States), as amended.

Additional HTSUS

For such civil aircraft articles that are no longer subject to these additional tariffs, use heading 9903.96.02.
- 9903.96.02: Effective with respect to products entered or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time September 16, 2025, articles of civil aircraft (all aircraft other than military aircraft and unmanned aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components that are products of Japan, that otherwise meet the criteria of General Note 6 of HTSUS (Articles Eligible for Duty-Free Treatment Pursuant to the Agreement on Trade in Civil Aircraft), but regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub column.

Automobiles and Automobile Parts

Executive Order 14345 and Commerce’s notice implementing EO 14345, as posted for public inspection on September 15, 2025 and scheduled for publication in the Federal Register on September 16, 2025, modify the Section 232 duties on passenger vehicles and light trucks (automobiles) and automobile parts that are products of Japan and entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern daylight time on September 16, 2025.

The Section 232 tariff on automobiles and automobile parts that are products of Japan is based on the ad valorem Column 1 duty rate applicable to the products. Currently, all automobiles and automobile parts that are encompassed by HTSUS headings 9903.94.40, 9903.94.41, 9903.94.42, and 9903.94.43 have only ad valorem Column 1 duty rates, so ad valorem conversion is not required.

Automobiles

For an automobile that is a product of Japan with a Column 1 duty rate greater than or equal to 15 percent ad valorem, the additional Section 232 duty rate is zero (0). Use heading 9903.94.40.
For an automobile that is a product of Japan with a Column 1 duty rate less than 15 percent ad valorem, the combined Column 1 and additional Section 232 duty rate is 15 percent ad valorem. Use heading 9903.94.41.

Automobile Parts

For an automobile part that is a product of Japan with a Column 1 duty rate greater than or equal to 15 percent ad valorem, the additional Section 232 duty rate is zero (0). Use heading 9903.94.42.
For an automobile part that is a product of Japan with a Column 1 duty rate less than 15 percent ad valorem, the combined Column 1 and additional Section 232 duty rate is 15 percent ad valorem. Use heading 9903.94.43.

Products Subject to Section 232

All products of Japan that are subject to Section 232 actions will continue to be exempt from Reciprocal tariffs. These Section 232 actions include:

Proclamation 9704 of March 18, 2018, (Adjusting Imports of Aluminum Into the United States), as amended;
Proclamation 9705 of March 8, 2018, (Adjusting Imports of Steel Into the United States), as amended;
Proclamation 10962 of July 30, 2025, (Adjusting Imports of Copper Into the United States), as amended;
Proclamation 10908 of March 26, 2025 (Adjusting Imports of Automobiles and Automobile Parts Into the United States), as amended.

Filers should continue to file using HTSUS heading 9903.01.33 for products that are exempt from Reciprocal tariffs because they are subject to Section 232 actions.

The automobiles and automobile parts subject to the duties described above are subject to the stacking provisions of Executive Order 14289, “Addressing Certain Tariffs on Imported Articles,” 90 FR 18907 (May 2, 2025), as modified by Proclamation 10947, “Adjusting Imports of Aluminum and Steel into the United States,” 90 FR 24199 (June 3, 2025).

For purposes of applying the above provisions, automobiles and automobile parts that are products of Japan subject to the zero (0) percent Section 232 duty under headings 9903.94.40 and 9903.94.42 are not considered to be subject to Section 232 automobile and automobile parts duties.

Exemptions from Reciprocal Tariffs

The other exemptions provided for under Reciprocal tariffs, (9903.01.25, 9903.01.30-9903.01.33, and 9903.01.34), continue to apply to products of Japan.