New End Date for Reciprocal Tariff ‘In-Transit’ Exemption

On May 30, 2025, U.S. Customs and Border Protection (CBP) released CSMS #65201773 – UPDATED GUIDANCE – International Emergency Economic Powers Act (IEEPA) Reciprocal In-Transit End Date Extension. The notice updates the end date of the in-transit exemption from May 28, 2025 to June 16, 2025. Customs entries filed prior to June 16, 2025 for shipments that were loaded and in-transit on the final mode of transport by vessel prior to April 5 are exempt from reciprocal tariffs. Shipments subject to higher reciprocal tariffs are subject to a lower 10% reciprocal tariffs if loaded and in-transit before April 9, 2025. Products of China loaded and in transit between April 9 and before April 10, 2025, are subject to the 10% reciprocal tariffs.

Product of Any Country, Loaded and In-Transit Before April 5, 2025

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prior to entry into the United States before 12:01 a.m. EDT on April 5, 2025, AND (2) are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025.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passage of time, CBP will permit heading 9903.01.28 to be declared only for goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 5, 2025, and before 12:01 a.m. EDT on June 16, 2025.

Product of Countries that have an Additional Country-Specific Rate, Loaded and In-Transit Between April 5, 2025 and April 9, 2025

Articles the product of the countries that have an additional country-specific rate of duty, identified in 9903.01.43 – 9903.01.76, that were (1) loaded onto a vessel at the port of loading and in-transit on the final mode of transport on or after 12:01 a.m. EDT April 5, 2025, and before 12:01 a.m. EDT April 9, 2025, and (2) are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. EDT on June 16, 2025, are subject to the 10% additional rate in lieu of the country-specific rate of duty.  Articles to which this in-transit scenario applies must be reported under 9903.01.25.

Products of China, Identified in 9903.01.63, Loaded and In-Transit Between April 9, 2025 and April 10, 2025

Articles the product of China, identified in 9903.01.63, that were (1) loaded onto a vessel at the port of loading and in transit on the final mode of transport on or after 12:01 a.m. EDT April 9, 2025, and before 12:01 a.m. EDT April 10, 2025, and (2) are entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. EDT on June 16, 2025, are subject to the 10% additional rate in lieu of the country-specific rate of duty.  Articles to which this in transit scenario applies must be reported under 9903.01.25.

Have Questions? Contact your local NNR Representative.

We will continue to monitor this tariff action and provide updates as they become available.