Global tariffs impacting supply chains

U.S. Customs Enforcement Reform

On June 3, 2026, the U.S. administration issued an executive order to strengthen customs enforcement, with a focus on closing gaps related to undervaluation, misclassification, limited importer transparency, and other forms of non-compliance. The order directs U.S. Customs and Border Protection (CBP) and the Department of Homeland Security (DHS) to introduce a series of regulatory and policy changes over the coming months.

These changes will impact businesses importing goods into the United States, particularly those using a foreign importer of record (IOR). The order directs CBP to tighten requirements for importers, including higher bond levels, minimum domestic asset thresholds, and expanded data and ownership disclosures. It also restricts how foreign IORs can operate, including limitations on informal entry and introduces a “good standing” requirement tied to compliance history. Importers that do not meet these standards may be restricted from importing.

Increased scrutiny of importer eligibility, documentation, and supply chain data are expected. The order also calls for enhanced enforcement, including audits, stricter penalties, and faster seizure and disposal of goods that do not meet U.S. requirements. Penalty rules are expected to be tightened, including reduced flexibility to lower penalties and stricter treatment for repeat violations.

In addition, new disclosure and certification requirements are anticipated. Importers may be required to provide more detailed information about products, manufacturers, and production methods, and to certify compliance with regulations such as forced labor and sanctions laws. CBP may also require export documentation from origin countries to support import filings.

Implementation will be phased. Certain measures, including enhanced disclosure, enforcement updates, and transparency requirements, are expected within 90 days. Broader changes to importer eligibility and operating requirements, including those affecting foreign IORs, are expected within 180 days. DHS is also expected to propose additional legislative measures within 45 days.

At this stage, the executive order directs U.S. authorities to develop and implement new requirements over the coming months, with further regulatory guidance expected. Until additional details are issued, importers should continue to comply with existing U.S. customs regulations.We highly recommend that you review your current U.S. import model, particularly if you rely on a foreign IOR, informal entry processes, or have limited visibility into your supply chain data.

Maersk Trade & Customs Consulting Support

The best way to prepare is through a structured compliance readiness approach. Maersk’s Trade & Customs Consulting team can support you with compliance readiness assessments, importer structure reviews, identification of data and documentation gaps, and broader trade compliance advisory support. For tailored guidance, please contact your Maersk Trade & Customs Consulting representative.

Section 122 Tariffs: Court Decision and Appeal Status Update

On May 7, 2026, the U.S. Court of International Trade (CIT) issued a decision in State of Oregon et al. v. United States and Burlap and Barrel, Inc. et al. v. United States finding that the Administration exceeded its authority under Section 122 of the Trade Act of 1974 related to the February 2026 tariff action.

On May 12, the U.S. Government filed an appeal of the decision, and as a result, the legal status and enforceability of the Section 122 tariffs remain subject to ongoing judicial review. Additional court proceedings, including potential requests for a stay or other interim relief, may further affect how the ruling is applied.

At this time, there is no change to existing operational or duty payment requirements for impacted shipments. Importers should continue to comply with all applicable requirements while the appellate process progresses. Importers may wish to assess historical Section 122 duty exposure, recognizing that any potential refund or relief outcomes remain uncertain and contingent on the outcome of the appeal.

Maersk Trade & Customs Consulting Can Support

Maersk’s Trade & Customs Consulting team can support importers with duty exposure analysis, entry level reporting and reconciliation, refund opportunity assessments, protest strategy coordination, tariff impact reviews, and broader trade compliance advisory support. For additional guidance or support evaluating potential exposure and recovery opportunities, please contact your Maersk Trade & Customs Consulting representative.

This communication is provided for general informational purposes only and does not constitute legal advice. Importers should consult legal counsel regarding litigation strategy, protests, or specific legal rights related to tariff recovery actions.

Refunding Duties Collected under the International Emergency Economic Powers Act (IEEPA)

U.S. Customs and Border Protection (CBP) has announced a new automated process to manage refunds of duties collected under the International Emergency Economic Powers Act (IEEPA). Due to the high volume of refund requests, CBP will issue refunds in phases, using a new tool within its Automated Commercial Environment (ACE).

CBP is launching a new refund processing tool called Consolidated Administration and Processing of Entries (CAPE):

• Starting April 20, 2026, importers of record or the licensed customs broker who filed the entry may submit requests for eligible IEEPA duty refunds through CAPE.
• Refund requests must be submitted through the ACE Portal using a CAPE Declaration.

During Phase 1, CBP will accept CAPE Declarations for certain unliquidated entries and certain liquidated entries up to 80 days past their liquidation date. Entries with a liquidation status of suspended, extended, or under review may also be included. These entries will maintain their current status, with any validated refund issued at liquidation.

Once a CAPE Declaration is accepted, valid IEEPA refunds are generally expected to be issued within 60–90 days, unless additional compliance review is required. CAPE will consolidate refunds by liquidation (or reliquidation) date and importer of record (or a designee identified on a CBP Form 4811). Once processed, refunds will be issued electronically via Automated Clearing House (ACH) in accordance with applicable laws and any relevant court orders.

Importers are encouraged to prepare by confirming access to the ACE Portal, the Importer sub‑account, and completed ACH refund banking details, which are required before refunds can be issued. Importers and brokers may also begin compiling lists of entries where IEEPA duties were paid to support future CAPE submissions.

Key submission details

• A single CAPE Declaration may include up to 9,999 entries.
• Brokers may include entries filed for multiple importers in one submission.
• Once a CAPE Declaration is accepted, it cannot be amended.
• If additional eligible entries are identified later, a new CAPE Declaration must be submitted.
• Each entry may only be included once across all CAPE Declarations.

CBP has advised that additional entry types may be supported in future phases of CAPE, including reconciliation entries, drawback‑related entries, entries under protest, entries not filed in ACE, AD/CVD‑related entries pending liquidation, and entries for which liquidation is final. CBP will issue further guidance as these capabilities are developed.

How Maersk can support you

Maersk Customs Services is closely monitoring developments and as additional guidance becomes available, we will continue to provide updates. Our team is available to support customers with:

• Entry analysis and identification of potentially affected transactions
• Monitoring liquidation status and protest timelines
• Evaluating potential tariff refund exposure
• Preparing for the ACE refund submission process

Customers with questions regarding specific shipments, entries, or tariff exposure are encouraged to contact their local Maersk Customs Service team. Within the next week, Maersk will be hosting an educational customer webinar to cover more details around this process with registration being released soon to our customers.

The U.S. Government has issued a new presidential proclamation introducing significant changes to Section 232 tariffs on steel, aluminum, and copper, including certain derivative products. These changes represent a fundamental shift in how Section 232 duties are calculated, applied, and mitigated, with immediate implications for landed cost, sourcing decisions, and compliance requirements.

Duties now apply to the full customs value of covered products, rather than being limited to the value of the metal content. This change may result in a substantial increase in duty exposure, particularly for finished goods, assemblies, and multi-material products.

The revised tariff rates include:

• 50% tariff on most primary metal articles and certain derivative products
• 25% tariff on additional derivative products and certain copper goods

Preferential or reduced rates may apply in limited scenarios, including:

• 10% tariff for products made entirely from U.S.-origin metals
• Reduced rates for qualifying products originating from the United Kingdom
• Certain metal intensive industrial and infrastructure products may be eligible for temporary relief through 2027, subject to a 15% effective duty cap, dependent on classification and product eligibility.

Compliance and duty mitigation considerations

• Drawback limitations, now largely restricted to products from FTA or trade agreement partners where metals are smelted and cast in those countries
• Foreign Trade Zone (FTZ) requirements, which mandate admission of Section 232 goods under Privileged Foreign Status (PFS), fixing the duty rate at the time of admission
• Combined with full value tariff application, FTZs continue to provide duty deferral and MPF savings, but offer limited duty reduction benefits for Section 232 goods

What this means for your supply chain planning

• Increased landed costs due to full value tariff calculation
• Reduced effectiveness of traditional duty mitigation strategies
• Greater importance of sourcing strategy, country of origin, and product design
• Increased compliance requirements and documentation obligations

We recommend importers:

• Conduct a duty impact assessment under the revised rules
• Validate HTS classification and Section 232 applicability
• Review sourcing and origin strategies, including melt and pour traceability
• Reassess FTZ usage and expected benefits
• Evaluate drawback eligibility under the updated restrictions
• Monitor CBP implementation guidance and regulatory updates

The Maersk Trade Compliance and Consulting teams can assist with:

• Duty exposure modeling (full-value tariff analysis)
• Product scope and classification validation
• Supply chain restructuring and sourcing strategy
• FTZ feasibility reassessment under new rules
• Drawback eligibility and recovery analysis
• Ongoing regulatory monitoring and implementation support

Further details and regulatory updates will be made available as guidance is issued. To discuss how these changes may impact your business and identify potential mitigation strategies, please contact our Trade Compliance and Consulting team at compliance.mcsi.nam@maersk.com

New Section 232 Tariffs on Pharmaceuticals

The U.S. Government has issued a new proclamation under Section 232 introducing tariffs on patented pharmaceuticals and certain associated pharmaceutical ingredients, citing national security concerns related to reliance on foreign production. These tariffs represent an expansion of Section 232 to the life sciences sector with immediate implications for sourcing, pricing, and compliance. This action takes effect on July 31, 2026, for companies identified in Annex III, and on September 29, 2026, for all remaining companies.

The action applies to patented pharmaceuticals and associated pharmaceutical ingredients, including active pharmaceutical ingredients (APIs) and key starting materials. Generic pharmaceuticals and biosimilars are excluded at this time.

The tariff framework is tiered and may range from 0% to 100%, depending on product characteristics, country of origin, and whether the importer qualifies for specific agreements or onshoring incentives. Section 232 pharmaceutical tariffs are structured so that the total duty payable equals the applicable rate specified in the proclamation. Where a product may qualify under more than one tariff level or preference, the lowest applicable rate will apply.

What this means for your supply chain planning and our recommendations

• Identify impacted products under Annex I
• Determine whether products qualify as patented vs. generic
• Evaluate eligibility for:
• Reduced rates tied to approved onshoring plans
• Zero tariff categories for critical, specialty, or U.S. origin products
• Assess supply chain restructuring opportunities
• Review drawback applicability
• Monitor for CBP implementation guidance and Federal Register updates
• Assess Foreign Trade Zone (FTZ) implications, noting that covered products admitted to FTZs must enter under Privileged Foreign Status (PFS), with duty rates fixed at admission

The Maersk Trade Compliance and Consulting teams can assist with:

• Tariff exposure modeling and scenario analysis
• Product scope and classification validation
• Onshoring strategy and eligibility assessment
• Agreement readiness and documentation support
• Drawback analysis and recovery strategy
• Ongoing regulatory monitoring and implementation guidance

Further details and regulatory updates will be made available as guidance is issued. To discuss how these changes may impact your business and identify potential mitigation strategies, please contact our Trade Compliance and Consulting team at compliance.mcsi.nam@maersk.com

CBP Actions on IEEPA Refunds and Transition to ACH Refund Payments

U.S. Customs and Border Protection (CBP) recently provided an update to the U.S. Court of International Trade (CIT) regarding the implementation of refunds associated with tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

In a declaration submitted to the court, Brandon Lord, Executive Director of Trade Programs within CBP’s Office of Trade, explained that CBP’s existing systems cannot support immediate automated reimbursement of IEEPA-related duties. CBP indicated that it is developing new functionality within the Automated Commercial Environment (ACE) to facilitate the refund process and anticipates that this capability could be available within approximately 45 days, subject to court approval and final agency guidance.

Based on the information provided to the court, CBP anticipates that the refund process may operate as follows once the system enhancements are implemented:

• Importers submit a declaration in ACE identifying entries where IEEPA duties were paid
• ACE validates each entry and recalculates duties excluding the IEEPA tariffs, including applicable interest
• CBP reviews and verifies the submission
• ACE liquidates or reliquidates the affected entries as appropriate
• Refund amounts are aggregated by importer
• CBP certifies the refunds and the U.S. Department of the Treasury issues the payment electronically

Transition to Electronic Refund Payments (ACH)

Separately, CBP has implemented new procedures requiring most refunds to be issued electronically through Automated Clearing House (ACH) rather than by paper check. This change stems from the Electronic Refunds Interim Final Rule, published in the Federal Register on January 2, 2026. Under this rule, electronic refunds through ACE will become the standard method for issuing duty refunds, subject to limited exceptions.

In anticipation of CBP's refund process being implemented, and to ensure refunds can be processed without delay, importers should confirm that ACH refund authorization is active in the ACE Portal.

Key points to consider:

• ACH enrollment and verification are completed within the ACE Portal under the Importer Subaccount → ACH Refund Authorization tab
• Importers already receiving electronic refunds through ACH do not need to take additional action
• Common enrollment issues include routing numbers not configured for FedACH processing and address formatting inconsistencies for foreign entities
• If an EIN is already associated with an existing ACE account, importers may contact ACE.Support@cbp.dhs.gov for assistance with account access

How Maersk can support you

Maersk Customs Services is closely monitoring developments related to the CIT ruling and CBP’s implementation of the anticipated refund process. As additional guidance becomes available, we will continue to provide updates.

Our team is available to support customers with:

• Entry analysis and identification of potentially affected transactions
• Monitoring liquidation status and protest timelines
• Evaluating potential tariff refund exposure
• Peparing for the anticipated ACE refund submission process

Customers with questions regarding specific shipments, entries, or tariff exposure are encouraged to contact Maersk Customs Services at: compliance.mcsi.nam@maersk.com

CBP Actions on IEEPA Refunds and Transition to ACH Refund Payments

We would like to share an update on legal proceedings regarding the potential refund of tariffs previously imposed under the International Emergency Economic Powers Act (IEEPA).

On March 2, 2026, the U.S. Court of Appeals for the Federal Circuit ruled that the case challenging IEEPA tariffs should move forward and sent it to the U.S. Court of International Trade. The Court will now determine how potential refunds will be issued and what actions importers may need to take.

What this means for importers

This development represents an important procedural step toward potential refunds of IEEPA tariffs. However, the specific process, timing, and scope of any refunds have not yet been determined. It is not yet clear whether refunds will be applied automatically or whether importers will need to take specific action to preserve eligibility. Our guidance for customers

Given the evolving situation, we recommend importers:

• Continue monitoring entry liquidation timelines
• File protests where appropriate to preserve potential refund rights
• Consult with their customs broker or legal counsel regarding individual entries and exposure

How Maersk can help

We recognize that this evolving situation may create uncertainty for importers, and we appreciate your patience as the legal process continues. We will continue to monitor developments closely and provide updates as more clarity becomes available.

Our Maersk Customs Services remains available to support customers with compliance guidance, entry review, and tariff-related questions. For assistance, please contact compliance.mcsi.nam@maersk.com

Update on Legal Proceedings Related to Potential Refund on IEEPA Tariffs

U.S. Customs and Border Protection (CBP) has issued guidance implementing a temporary additional 10% import surcharge under Section 122 of the Trade Act of 1974, effective for qualifying goods entered on or after 12:01 a.m. EST on February 24, 2026.

What this means: Effective February 24, 2026:

• An additional 10% ad valorem duty applies to imported goods from all countries, unless specifically exempt
• This surcharge is currently scheduled to remain in effect through July 24, 2026
• The duty is applied under HTSUS heading 9903.03.01
• This surcharge applies in addition to other applicable duties, including MFN and Section 301 tariffs. Certain products already subject to Section 232 duties may be exempt from the Section 122 surcharge, depending on their HTS classification and applicable exemptions defined by CBP. Certain products and categories are exempt, including qualifying goods under USMCA, specific agricultural and industrial products, civil aircraft, informational materials, and other designated exemptions as defined by CBP.

Shipments previously eligible for de minimis treatment

CBP has also confirmed that the suspension of duty-free de minimis treatment remains in effect.

As a result:

• Shipments previously eligible for duty-free entry under the de minimis threshold must continue to be formally entered
• Applicable duties, including the new Section 122 surcharge, may apply
• Existing entry and duty collection processes remain in place

Impact on supply chains

• Cargo continues to move normally through CBP entry processing.
• Importers should expect updated duty calculations reflecting the additional surcharge where applicable.
• We are actively monitoring regulatory developments and working closely with CBP and our Customs Services teams to ensure continued compliance and minimize disruption.

How Maersk can help

Maersk Customs Services is available to support customers with compliance guidance, entry review, and tariff-related questions.

For assistance, please contact: compliance.mcsi.nam@maersk.com

We understand that evolving trade regulations create uncertainty, and we remain committed to helping our customers navigate these changes. We will continue to provide updates as additional guidance becomes available.

CBP Guidance on Termination of IEEPA Tariffs effective February 24, 2026

U.S. Customs and Border Protection (CBP) has issued formal guidance confirming that duties imposed under the International Emergency Economic Powers Act (IEEPA) are no longer in effect for qualifying entries.

Effective 12:00 a.m. Eastern Time on February 24, 2026, CBP will no longer assess or collect IEEPA duties on goods entered for consumption or withdrawn from warehouse for consumption on or after that time.

CBP has confirmed that:

• IEEPA tariff provisions have been deactivated in CBP’s Automated Commercial Environment (ACE)
• Entry summaries for qualifying shipments will reflect $0.00 in IEEPA duties
• This change applies only to IEEPA tariffs and does not affect other duties, including those imposed under Section 301, Section 232, or other applicable tariff programs

Entries prior to February 24, 2026

For goods entered for consumption or withdrawn from warehouse for consumption before February 24, 2026, IEEPA duties were in effect at the time of entry and were properly assessed in accordance with CBP regulations and guidance then in place.

At this time:

• CBP has not issued formal guidance regarding refunds or post-entry remedies for previously paid IEEPA duties
• Entries filed prior to February 24, 2026, remain subject to the duty treatment applicable at the time of entry

We are closely monitoring CBP communications and will provide updates as additional guidance becomes available. Our Customs Services teams are available to support customers with entry processing, compliance guidance, and tariff-related inquiries.

Customers with questions regarding specific shipments, entries, or tariff exposure are encouraged to contact Maersk Customs Services at: compliance.mcsi.nam@maersk.com

U.S. Supreme Court IEEPA Tariff Ruling

We are aware of the U.S. Supreme Court’s February 20, 2026, decision invalidating certain tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

At this time, U.S. Customs and Border Protection (CBP) has not yet issued formal operational guidance or updated its entry processing systems to reflect the ruling. As a result, current CBP programming and entry procedures may not yet fully align with the decision, and importers should continue complying with CBP requirements until official implementation guidance is provided.

We are actively monitoring CBP communications and working closely with our Customs Services teams to ensure continued compliance while minimizing disruption to customer cargo.

We will provide further updates as CBP issues formal guidance.

Customers with questions regarding specific shipments, entries, or tariff exposure are encouraged to contact Maersk Customs Services at: compliance.mcsi.nam@maersk.com

Recent U.S. Trade Policy, Tariff, and Customs Compliance Developments Affecting Importers

Several recent U.S. government actions and trade policy developments may affect your tariff exposure, customs compliance requirements, and sourcing strategies. Some changes are already in effect, while others are pending implementation. Reviewing your sourcing footprint and customs processes now can help you assess potential cost, compliance, and operational impacts.

USDA strengthens organic import certification enforcement

Effective February 13, 2026, organic imports must be supported by a valid, shipment-specific USDA National Organic Program (NOP) import certificate. Shipments without proper certification may be denied organic status or refused entry. You should confirm that your suppliers provide complete and accurate certification before shipment to avoid clearance delays or product reclassification.

Removal of additional 25% duty on imports from India

Effective February 7, 2026, the United States eliminated the additional 25% duty previously applied to Indian-origin goods. Standard duty rates under the applicable HTS classification continue to apply. If your business imports goods from India, you should review recent and pending entries to confirm correct tariff treatment and evaluate refund opportunities where excess duties were applied.

Reauthorization of AGOA and Haiti HOPE/HELP programs and refund eligibility

The African Growth and Opportunity Act (AGOA) and Haiti HOPE/HELP programs have been extended through December 31, 2026. Importers may again claim duty-free treatment for eligible goods and request refunds for qualifying duties paid between October 1, 2025, and February 3, 2026. The deadline to request refunds is August 2, 2026. You should review entries filed during the lapse period and coordinate with your customs broker to preserve refund eligibility.

New and pending reciprocal trade agreements may change tariff exposure

The United States has announced new trade agreements or frameworks with Taiwan, Argentina, India, Bangladesh, and North Macedonia. While most provisions are not yet implemented, these agreements may significantly change tariff rates, preferential treatment eligibility, and compliance requirements.

What this means for your supply chain planning

These developments may affect your duty costs, origin qualification requirements, and sourcing decisions. Depending on your supply chain structure, you may see opportunities for duty savings, exposure to new tariff floors, or increased compliance requirements.

You should review your current sourcing locations, validate country-of-origin determinations, and evaluate duty exposure across your product portfolio. Early modelling will help you adjust sourcing strategies, contract terms, and landed cost assumptions before implementation deadlines or regulatory enforcement increases.

Our Maersk’s Trade Services team can support tariff exposure modeling, entry reviews, origin validation, and compliance planning aligned with your supply chain structure.

If you would like assistance assessing your exposure or preparing for upcoming regulatory changes, please contact your Maersk representative or compliance.mcsi.nam@maersk.com.

We will continue to monitor developments and share updates that may affect your shipments and duty exposure.

Proposed Elimination of First Sale Customs Valuation Method

New legislation introduced in the U.S. Senate proposes eliminating the use of the “First Sale” customs valuation method and requiring importers to declare customs value based on the last sale prior to export to the United States. At this time, this is proposed legislation only. No changes have been enacted, and U.S. Customs and Border Protection (CBP) valuation procedures remain unchanged.

Under current customs valuation rules, eligible importers may use the First Sale method to declare value based on the initial sale in a multi-tier supply chain, provided specific documentation and compliance requirements are met. This method allows duty to be assessed based on the earlier transaction value, which may reduce duty exposure and improve the predictability of landed costs.

If enacted, the proposed legislation would require valuation based on the final sale to the U.S. importer. This could increase the declared customs value and result in higher duty liability, particularly for goods subject to Section 301 tariffs, “reciprocal” tariffs, or Section 232 duties.

What this means for your supply chain planning

There is no immediate change to customs valuation requirements. You may continue using First Sale valuation where your transactions qualify, and documentation requirements are met.

However, because this proposal could materially affect duty exposure if enacted, you may wish to review whether your current import valuation structure relies on First Sale and assess potential exposure under a Last Sale valuation scenario. Early evaluation will help you understand potential cost impact and prepare for future regulatory changes.

Maersk’s Trade Services team can support valuation reviews, duty exposure modeling, documentation assessments, and strategic planning aligned with your sourcing and customs compliance structure.

If you would like assistance assessing your exposure or preparing for potential regulatory changes, please contact your Maersk representative or compliance.mcsi.nam@maersk.com.

We will continue to monitor developments and share updates accordingly.

CBP Operations During February 2026 Lapse in Appropriations

U.S. Customs and Border Protection (CBP) has confirmed that trade operations continue during the lapse in appropriations affecting the Department of Homeland Security, effective February 13, 2026. Imports and exports continue to be processed at all U.S. ports of entry, and cargo clearance, entry filing, and release activity remain operational.

CBP has designated most personnel supporting trade operations as essential, including Import Specialists, Centers of Excellence and Expertise staff, National Account Managers, and trade compliance personnel. Electronic filing systems, including the Automated Commercial Environment (ACE), remain fully operational and continue to support entry submission, cargo release, and compliance reporting.

At this time, no disruption to routine cargo clearance or entry filing is anticipated. However, you may experience slower response times for non-urgent administrative matters, outreach activities, or discretionary casework. Core import processing and enforcement functions remain active.

What this means for your supply chain planning

You should continue filing entries, submitting required documentation, and managing compliance processes as normal. Ensure your import documentation remains complete and accurate to avoid unnecessary clearance delays. If issues arise, contact your customs broker or the relevant port of entry for resolution.

We continue to monitor CBP operations and government developments closely. We will provide updates if conditions change or if new guidance is issued that may affect your shipments.

If you have questions or need support, please contact your Maersk representative or compliance.mcsi.nam@maersk.com.

We will continue to monitor developments and share updates that may affect your shipments.

IEEPA & Section 232 Tariffs – Steps to Protect Potential Refund Rights

We are sharing an update on the International Emergency Economic Powers Act (IEEPA) and Section 232 tariffs, as well as the steps you can take now to preserve your potential refund rights. Ongoing cases at the U.S. Court of International Trade are challenging duties imposed under IEEPA and Section 232 (national security). A favorable ruling could allow refunds on covered entries.

Why This Matters

Once an entry liquidates and becomes final, U.S. Customs and Border Patrol (CBP) generally treats it as closed. If you don’t act before liquidation or file timely protests, you may lose the ability to pursue refunds even if litigation outcomes are favorable.

Recommended Steps for Importers

To ensure your business is positioned for potential refund opportunities, our Maersk Customs Trade Services team recommends taking the following actions now:

• Review ACE data to identify entries with IEEPA or Section 232 duties and confirm HTS classifications and duty lines.
• Track liquidation dates and prioritize entries filed in early 2025 and those nearing one year.
• Request extensions of liquidation before deadlines (CBP may grant up to three years at its discretion) and confirm approvals.
• File protests within 180 days of liquidation and request that CBP stay those protests pending resolution of the litigation.
• Keep clear records of filings, CBP responses, and timelines.

How We Can Support

Maersk Customs Trade Services can provide fee-based assistance to help manage this process, including:

• ACE data analysis to identify affected entries.
• Tracking and monitoring liquidation dates to avoid missed deadlines.
• Preparing and submitting requests for liquidation extensions to CBP, where appropriate, on relevant entries.

This advisory is for information only and does not constitute legal advice. For questions or to discuss tailored support, please contact compliance.mcsi.nam@maersk.com.

We will continue to monitor developments and share updates that may affect your shipments and duty exposure.

We want to make you aware of several recent trade developments announced by the United States government that may affect your supply chain and customs operations. These include new trade agreements with the European Union (EU), Japan, Indonesia, and the Philippines, as well as new Executive Orders that change how low-value shipments are treated, impose new tariffs on copper and Brazilian-origin goods, and introduce additional duties under the national emergency declared in April 2025.

We are monitoring developments closely and will continue to share updates as more details become available. Below is a summary of what has been confirmed and what you should consider in your planning:

U.S.-European Union

• The U.S. and European Union (EU) have agreed to a 15% tariff across most EU-origin goods.
• Zero tariffs now apply to aircraft and components, select chemicals, semiconductor equipment, and some agricultural and raw materials.
• Steel and aluminum tariffs will be gradually reduced. A quota system is being introduced.
• Read the full statement from the European Commission and the U.S. Fact Sheet on the EU Trade Agreement. No Executive Order has been issued. We will provide further guidance once it’s available.

U.S.-Japan

• The United States and Japan have finalized a trade agreement that introduces a 15% tariff on Japanese imports.
• The 15% rate also applies to automobiles and auto parts.
• Read the full Fact Sheet published by the White House here. No Executive Order has been issued.

U.S.-Indonesia

• Indonesian exports to the U.S. will be subject to a 19% tariff
• U.S. exports to Indonesia will enter duty-free.
• Read the full Fact Sheet published by the White House here. No Executive Order has been issued.

Suspension of De Minimis for All Countries, effective August 29, 2025.

• All imports, regardless of value or origin, will now be subject to applicable duties and tariffs.
• Shipments previously entered duty-free under Section 321 (de minimis threshold of $800) must now follow standard entry procedures.
• This includes full customs filings and compliance with all Partner Government Agency (PGA) requirements.
• Postal shipments will temporarily remain exempt from formal entry, but will be subject to flat or ad valorem duties based on the country of origin.
• Read the Executive Order here.

Brazil Tariff Action, effective August 1, 2025

• The U.S. government has declared a national emergency under the International Emergency Economic Powers Act (IEEPA)
• A 50% tariff will be imposed on select Brazilian-origin products starting August 1, 2025.
• Read the Executive Order here.

Tariff on Copper Imports, effective August 1, 2025

• A 50% ad valorem tariff will apply to certain semi-finished copper imports, including rods, wires, bars, sheets, tubes, connectors, and fittings classified under HTS Chapter 74.
• This applies to both wrought and unwrought copper products.
• Raw materials such as ores, concentrates, cathodes, anodes, and copper scrap are excluded.
• Read the Executive Order here.

Additional Tariffs Under “Reciprocal Tariff Framework”, effective August 7, 2025

New duties have been established under the national emergency declared in Executive Order 14257 (April 2025), which addresses systemic trade imbalances. This new Executive Order replaces prior rates for certain trading partners and introduces updated tariff structures by country and product.

Key updates:

• Goods from countries listed in Annex I (listed in Executive Order) will face updated ad valorem tariffs based on their current HTSUS duty rate.
• Goods from other countries not listed in Annex I will face a 10% additional duty.
• If CBP determines that goods were transshipped to evade duties, a 40% tariff will apply, along with penalties and no eligibility for mitigation.
• Read the Executive Order here.

Given the scope and speed of these changes, we strongly encourage all importers to:

• Review current low-value shipment practices and assess potential cost and compliance impacts.
• Evaluate tariff exposure across small parcel, e-commerce, and sample import channels.
• Conduct a classification, valuation, and origin audit to avoid inadvertent violations under the enhanced enforcement regime.
• Prepare for increased enforcement activity by ensuring robust recordkeeping and compliance procedures.

Our Trade and Tariff Studio and Compliance Advisory Team can support importers with:

• Entry process reconfiguration for low-value shipments
• Tariff and sourcing impact modeling
• Risk analysis for transshipped goods and country of origin tracing
• Import structure reconfiguration
• Origin, valuation, and compliance risk analysis
• CBP enforcement training, response preparation, and policy interpretation
• Contact us at chb.northamerica@maersk.com

For assistance regarding:

North America regulations, please contact us at: compliance.mcsi.nam@maersk.com.
Canada regulations, please contact us at: compliance.ca.mcsi.nam@maersk.com
China regulations, please contact us at: GTCCAPA@maersk.com.
EU regulations, please contact us at: consulting@lns.maersk.com.

We’ll continue to monitor these tariff-related changes and keep you informed as further guidance becomes available. Stay informed with the latest tariff changes and guidance at our Global Tariffs Resource Page.

Helping You Plan Ahead: Navigating Higher Volumes Through U.S. Gateways

Ocean volumes from China to the U.S. are on the rise following the May 12 tariff adjustment, and this is putting added pressure on U.S. West Coast terminals, particularly Los Angeles, Long Beach, and inland networks, as more cargo moves through key gateways in the weeks ahead.

As activity builds, terminals and inland ramps may experience periods of high utilization. This may impact appointment availability and equipment flow during peak hours. Terminals encourage off-peak appointment windows, including third shift and weekends, to help maintain fluid operations and reduce wait times. Your prior planning can help avoid demurrage or detention charges.

To help you plan effectively, we want to share the steps we are taking to support continuity and ensure the smooth movement of your cargo.

How We Are Supporting You

• Planned extra loader capacity to accommodate elevated demand and support equipment availability.
• Monitoring cargo dwell by customer and location and reaching out proactively to help avoid delays or additional costs.
• Coordinating with terminal operators and depot partners to maintain consistent gate operations and expand empty return options where needed.
• Partnering with chassis providers to align supply with market needs.
• Working closely with rail providers and equipment teams to manage railcar supply and reposition empties to key terminals.

What You Can Do

• Finalize documentation and customs clearance early to ensure timely cargo release.
• Schedule container pickups as soon as cargo becomes available. Avoid relying on same-day appointments, which may be unavailable under constrained conditions. Appointments are released 48 hours in advance. Please visit terminal pages for appointment details.
• Confirm chassis and driver availability early if you’re using your own trucker. If you prefer a managed solution, our Store-Door service provides end-to-end assistance for inland delivery, including drayage, chassis, and terminal appointments, to help reduce the risk of missed pickups or delays.
• Return empty containers promptly to reduce the risk of detention and congestion. Use off-peak appointment windows (third shift and weekends) to improve turnaround times and help keep terminals fluid.
• Where possible, consider extended gate hours at your facilities to enable usage of off-peak appointments at terminals.

We’re here to help you manage through these evolving market dynamics. If you’d like to review your inland planning or discuss upcoming shipments, please contact your Maersk representative.

New Tariff on Steel and Aluminum Imports

As part of our ongoing commitment to keep you informed of important trade developments, we’d like to provide an update on the recent Executive Order issued by the U.S. Administration, increasing tariffs on most imported steel and aluminum articles, including derivatives, from 25% to 50%. This change took effect on June 4, 2025, at 12:01 am EDT.

This is a continuation of the policy shift first announced in February. You should review your import activity to determine how these new rates and reporting requirements impact your current and future shipments.

What’s Changed

• Tariff Rate: Most steel and aluminum imports now face a 50% tariff, up from 25%.
• U.K. Origin Goods: Steel and aluminum goods from the United Kingdom remain at 25% due to the U.S.-U.K agreement.
• Content Reporting: You must declare the steel and aluminum content separately from the rest of the product. The non-metal portion may face additional duties under tariff rules.
• No Duty Drawback: There is no eligibility for duty refunds on affected products.
• FTZ Entries: Products admitted to a Foreign Trade Zone (FTZ) on or after June 4 must be entered under privileged foreign status and will be assessed the 50% tariff when removed for U.S. consumption.

Products Affected

U.S. CBP has published updated HTS codes for aluminum and steel products subject to the new tariff rate. These lists may not be exhaustive:

• Aluminum HTS codes – Effective June 4, 2025 (via CBP)
• Steel HTS codes – Effective June 4, 2025 (via CBP)

Compliance and Filing Guidelines

CBP has reinforced the enforcement on content declarations:

• Only the steel or aluminum portion of a good is subject to the 50% tariff.
• The remaining non-metal content may be subject to Executive Order 14257 (“Reciprocal Tariffs”) or other duties.
• Accurate content reporting is required. Noncompliance may result in penalties, suspended privileges, or legal action.

If you’re unsure whether a product is affected by multiple tariff actions or how to prioritize duty payments, contact us directly.

Recommended Actions

To manage risk and avoid delays, we recommend you:

1. Review current and upcoming shipments for classification, country of origin, and HTS codes.
2. Audit your content declaration practices for HTSUS Chapters 73 (steel) and 76 (aluminum).
3. Reassess sourcing strategy, especially for goods from the U.K. that may still qualify for the lower tariff rate.
4. Check FTZ entry procedures to ensure the correct status is applied.
5. Evaluate potential duty exposure on non-metal contents under the current tariff rules.

We’re Here to Help

Our Trade Services and Customs Consulting teams can help you with:

• Tariff impact assessments
• HTS classification reviews
• Sourcing strategy updates
• Entry filing and compliance audits
• Guidance on FTZ procedures and tariff stacking

For assistance regarding:

North America regulations, please contact us at: compliance.mcsi.nam@maersk.com.
China regulations, please contact us at: GTCCAPA@maersk.com.
EU regulations, please contact us at: consulting@lns.maersk.com.

We’ll continue to monitor these tariff changes and keep you informed as further guidance becomes available. Stay informed with the latest tariff changes and guidance at our Global Tariffs Resource Page.

Trade Update: New U.S.- China and U.S.- U.K. Agreements

As part of our ongoing commitment to keep you informed of important trade developments, we’d like to provide an update on two trade developments recently announced between the United States and China, and the United States and the United Kingdom. These developments may directly impact your supply chain operations, landed costs, and compliance planning.

U.S. – China

Effective May 14, 2025, the following tariffs will apply (as relevant to your goods):

• Section 301 Tariffs – Still in effect (7.5% or 25%, depending on classification)
• Section 232 Tariffs – Still in effect (25% on Steel, Aluminum, their derivatives, and Automobiles, if applicable)
• IEEPA Fentanyl National Emergency Tariff – 20%
• IEEPA Reciprocal Tariff – 10%

Additional note on Low-Value Shipments:

• The duty on low-value imports from China (including Hong Kong and Macau) has been reduced from 120% to 54%. The $100 duty per postal item remains in effect.

U.S. – UK Agreement

On May 8, 2025, the United States and the United Kingdom announced an economic agreement.

Key Highlights

• Tariff relief for UK steel and aluminum exports to the U.S. (reduced to 0%).
• UK automobile exports will face a 10% tariff on the first 100,000 vehicles annually; additional vehicles remain subject to the 25% rate.
• The UK will increase quotas for U.S. beef and eliminate tariffs on U.S. ethanol exports.
• The 10% tariff rate on most other UK import goods remains in place for now, with negotiations ongoing.

What This Means for your Business

These agreements could reduce landed costs for many importers and exporters. However, as some provisions are temporary or still under negotiation, businesses should stay proactive and adaptive.

We recommend:

• Reviewing your sourcing and tariff exposure, especially if importing into the U.S. from China, Hong Kong, Macau, or the UK.
• Updating landed cost models in light of new duty rates.
• Ensuring customs documentation and classifications (HTSUS codes) are accurate and up to date.
• Preparing for potential compliance updates tied to quota-based and product-specific tariff structures.

We’re Here to Help

These changes may have a direct impact on your supply chain. Maersk’s Trade Services team is prepared to support you with:

• Tariff impact analysis
• Customs compliance planning
• Supply chain risk reviews
• Invoice structure updates
• Strategic sourcing and market access evaluations

For assistance regarding:
North America regulations, please contact us at: compliance.mcsi.nam@maersk.com.
China regulations, please contact us at: GTCCAPA@maersk.com.
EU regulations, please contact us at: consulting@lns.maersk.com.

Stay informed with the latest tariff changes and guidance at our Global Tariffs Resource Page.

Tariff changes and introduction of webpage on tariffs

As the situation regarding tariffs is rapidly changing, we want to make sure you have the correct information gathered in one place, with easy access. Therefore, we have created a webpage where you can see official changes to tariffs, who at Maersk you can reach out to for guidance, and key sites we suggest for further information.

Please bookmark this page for your ease. We will continue to update it as changes are announced.

What is the current situation?

On April 10, 2025, the U.S. Customs and Border Protection released guidance on changes made to the previously announced tariffs, stating that imports from China, Hong Kong and Macau would immediately have an additional 125% ad valorem duty applied, on top of the existing 20%. Certain goods (see here) may be exempt.

It also stated there would be an immediate suspension of country-specific tariffs that had previously gone into effect on April 9, 2025. Mexico and Canada are excluded from this suspension, and the 25% tariff on goods imported from these countries that are not covered by the USMCA trade agreement will continue to apply.

On April 11, 2025, China’s Customs Tariff Commission of the State Council announced an adjustment to tariff measures on imports originating from the United States from 84% to 125%, with effect from April 12, 2025.

The European Commission released a statement on April 10, 2025 by President von der Leyen, wherein the President stated that in response to the U.S. suspension of previous country-specific tariffs, the EU countermeasures are put on hold for 90 days. She further stated that if negotiations are not satisfactory, countermeasures will kick in. European Commission preparatory work on potential further countermeasures continues.

What this means for your business:

These changes represent a shift in U.S. trade policy and China trade policy, and may impact your landed costs, customs clearance procedures, and overall supply chain planning. We recommend:

• Reviewing your current sourcing strategies, especially if you import from China, Hong Kong, Macau or the U.S.
  For now, countries within the EU are experiencing a base-tariff rate of 10%, so this should not cause further disruption.
• Assessing tariff exposure and updating landed cost models based on the new duty rates.
• Ensuring your customs documentation and classifications (HTSUS codes) are accurate and up to date.

We’re Here to Help

These changes may have an impact on your supply chain. Maersk’s Trade Services team can support you with:

• Tariff impact analysis
• Customs compliance planning
• Supply chain risk reviews
• Invoice structure updates

For assistance regarding:

North America regulations, please contact us at: compliance.mcsi.nam@maersk.com.
China regulations, please contact us at: GTCCAPA@maersk.com.
EU regulations, please contact us at: consulting@lns.maersk.com.

We will continue to monitor the situation and provide updates as more details emerge.

Tariff changes from the United States

We wrote you earlier to inform you of tariff increases announced by the United States, China and European Union. We are now reaching out to inform you of changes in this fast-moving environment.

The U.S. Customs and Border Protection has released a guidance on changes made to the earlier announced tariffs. Please see below:

1. Imports from China, Hong Kong, and Macau:
• New Duty Rate: An additional 125% ad valorem duty will apply to most goods originating from China, Hong Kong, and Macau, effective April 10, 2025.
• Exceptions: Certain goods may be excluded. Please refer to CBP CSMS #64680374
2. Imports from All Other Countries:
• New Duty Rate: A 10% ad valorem duty will be applied to goods from other countries, unless they are:
• Already covered under specific tariff headings (9903.01.26 to 9903.01.33),
• Exempt under heading 9903.01.34, or
• Products of China, Hong Kong, or Macau (which fall under the separate 125% rate).

Suspension of Previous Country-Specific Tariffs: The country-specific rates that went into effect on April 9, 2025, have now been suspended.

The U.S. tariffs on goods imported from Mexico and Canada are not a part of the above, and the 25% tariff on goods it imports from Mexico and Canada that are not covered under the region's USMCA trade pact remains in effect.

What This Means for Your Business

These changes represent a shift in U.S. trade policy and may impact your landed costs, customs clearance procedures, and overall supply chain planning. We recommend:

• Reviewing your current sourcing strategies, especially if you import from China, Hong Kong, or Macau.
• Assessing tariff exposure and updating landed cost models based on the new duty rates.
• Ensuring your customs documentation and classifications (HTSUS codes) are accurate and up to date.

We’re Here to Help

These changes may have an impact on your supply chain. Maersk’s Trade Services team can support you with:

• Tariff impact analysis
• Customs compliance planning
• Supply chain risk reviews
• Invoice structure updates

For assistance regarding:

North America regulations, please contact us at: compliance.mcsi.nam@maersk.com.
China regulations, please contact us at: GTCCAPA@maersk.com.
EU regulations, please contact us at: consulting@lns.maersk.com.

We will continue to monitor the situation and provide updates as more details emerge.

Tariff Increases from the United States, China and European Union

In line with the latest trade policy developments announced by the United States government, we want to inform you of tariff increases that may directly impact your supply chain. These changes went into effect April 9, 2025, at 12:01 a.m. EST, and affect exports from China to the US.

In response, the People’s Republic of China also announces increased tariffs on the US, set to go into effect from April 10, 2025, at 12:01 a.m. CST, affecting exports from the US to China.

Additionally, on April 9, 2025, the European Commission announced it would take, based on approval from its member states, its proposal to introduce trade countermeasures against the United States, impacting exports from the US to the EU.

Tariffs from the US (on China)

The US has implemented a new 50% tariff increase on a broad range of Chinese-origin goods under Section 301. This action adds to the existing tariff layers already in place including:

• A 34% Tariff established previously, to mirror duties imposed by China on US goods.
• A 20% IEEPA-based National Security Tariff on high-risk technology and critical equipment.
• Existing Section 301 Tariffs: Including 25% for tech-sector violations and 7.5% for broader consumer goods

As a result, many products may now be subject to multiple overlapping tariffs, increasing landed costs and complexity in customs processing.

Current Tariff Landscape for Chinese-Origin Goods (as of April 2025):

Some goods may now be subject to Section 301 (25%) + Additional Increase (34%) + New 50% + IEEPA (20%), depending on classification and scope—total effective duties could exceed 129%.

Tariffs from China (to the US)

The People's Republic of China have announced that April 10, 2025, from 12:01 CST, will implement additional tariff measures on imported goods originating in the United States. The relevant matters are as follows:

1. The additional tariff rate stipulated in the earlier announced tariff, Tariff Commission Announcement [2025] No. 4, will be adjusted from 34% to 84%.
2. Other matters shall be implemented in accordance with Document No. 4 of 2025 announced by the Tax Commission.

Tariffs from the EU (to the US)

As of April 9, 2025, the European Union Member States voted in favour of the European Commission's proposal to introduce trade countermeasures against the United States. The Commission's proposal was made in response to the March decision by the US to impose tariffs on imports of steel and aluminum from the EU.

The duties are based on a two-step approach:

First, the Commission will allow the suspension of existing 2018 and 2020 countermeasures against the US to lapse on April 1, 2025. These countermeasures target a range of US products.

Second, in response to new US tariffs affecting more than €18 billion of EU exports, the Commission is putting forward a package of new countermeasures on US exports. Once the Commission's internal procedures are concluded, and the implementing act published, countermeasures will enter into force. These countermeasures have yet to be expanded upon by the European Commission. Duties will start being collected as of April 15, 2025, unless otherwise stated. They will come into force by mid-April, following consultation of EU Member States and stakeholders.

We’re Here to Help

These changes may have an impact on your supply chain. Maersk’s Trade Services team can support you with:

• Tariff impact analysis
• Customs compliance planning
• Supply chain risk reviews
• Invoice structure updates

For assistance regarding:

US regulations, please contact us at: compliance.mcsi.nam@maersk.com.

China regulations, please contact us at: GTCCAPA@maersk.com.

EU regulations, please contact us at: consulting@lns.maersk.com.

We will continue to monitor the situation and provide updates as more details emerge. For the latest tariff-related updates, you can find all relevant information here.

Update on Global Tariffs from the United States of America

In line with global tariffs announced by the United States (US) government on 3 April 2025, we wanted to make sure you have further information for your business and supply chain moves. The announced trade policy changes will take effect in April and May 2025. These measures involve:

1. Broad tariffs on global imports to the US
2. The elimination of duty-free de minimis treatment for low-value exports from China and Hong Kong to the US

If your business exports finished goods, components, or parcels from affected countries to the US, these changes may impact landed costs, customs procedures, and supply chain planning. We suggest reviewing your import/export flows now, to prepare for potential disruptions and increased duty exposure.

1. New Reciprocal Tariffs – Effective April 5 & 9, 2025

   10% Baseline Tariff
   Effective: April 5, 2025, at 12:01 A.M EST
   Scope: Applies to nearly all exports from all countries to the US, unless excluded.

   Reciprocal Country-Specific Tariffs
   Effective: April 9, 2025, at 12:01 AM EST
   Scope: Higher tariffs (up to ~50%) on exports from selected countries. You can review country-specific tariff rates here and here.

   Exclusions from above tariffs The following categories are excluded from both phases:

   • Food, medicine, and humanitarian goods (per 50 USC 1702(b))
   • Steel, aluminum, autos, and auto parts already covered under Section 232
   • Strategic goods including copper, pharmaceuticals, semiconductors, lumber
   • Goods pending future Section 232 reviews
   • Precious metals (e.g., bullion)
   • Energy and critical minerals not available domestically

   Special Rules for Canada and Mexico Existing rules under previous International Emergency Economic Powers Act (USA) orders remain unchanged:

   • USMCA-compliant goods: 0% tariff
   • Non-USMCA goods: 25% tariff
   • Non-USMCA energy/potash: 10% tariff

   If these orders are lifted in the future, non-USMCA goods from Canada and Mexico (to US) would default to a 12% tariff.




2. End of De Minimis for China and Hong Kong – Effective May 2, 2025

   On April 2, 2025, a new Executive Order from the US eliminated Section 321 de minimis treatment for most low-value exports from China and Hong Kong to USA.

   What’s Changing:

   • Effective: May 2, 2025, at 12:01 a.m. EDT
   • Scope: All non-postal shipments valued at $800 or less from China and Hong Kong to US will now require full customs entry and will be subject to all applicable duties, including reciprocal tariffs.

   Postal Shipments:

   • From May 2, 2025: Flat duty of 30% or $25 per item (whichever is higher)
   • From June 2, 2025: Flat duty increases to $50 per item
   • US Customs and Border Protection may require formal entry for any postal shipment, regardless of value, coming to the USA

   Carrier Requirements:

   • File shipment-level data with US Customs and Border Protection
   • Hold a valid international carrier bond
   • Remit duties according to US Customs and Border Protection payment schedules

   Future Expansion:
   The Secretary of Commerce of the US will report in 90 days on the effectiveness of this measure and assess whether to extend similar restrictions to Macau. We will inform you of these changes.

Next steps for your business with companies based in the US

• Review your sourcing and shipping channels— you will need to be aware of your sourcing and shipping channel, especially for low-value shipments from China or Hong Kong
• Update your customs entry processes – ensure that you are adhering to US customs processes when shipping to the US and are compliant to avoid delays where possible. Likewise, ensure that you are compliant with other countries customs when shipping from the US to them.
• Reassess landed cost models by applying new reciprocal tariff rates to affected imports.
• Coordinate with your logistics providers and brokers to plan for new documentation, bonds, and payment procedures.
• Monitor for updates on a potential extension of de minimis restrictions to Macau.

We’re Here to Help

These changes may have an impact to your supply chain. Maersk’s Trade Services team can support you with:

• Tariff impact analysis
• Customs compliance planning
• Supply chain risk reviews
• Invoice structure updates

For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com.

Use MyCustoms to manage customs for your Maersk ocean shipments; online here.

We will continue to monitor the situation and provide updates as more details emerge. For the latest tariff-related updates, you can find all relevant information here.

Upcoming Reciprocal Tariffs on April 2, 2025

As you may be aware, the U.S. government intends to implement new reciprocal tariffs starting April 2, 2025. The affected goods span key industries such as automotive, electronics, agriculture, and consumer products. If you import from the impacted regions, these changes could affect costs, supply chain planning, and compliance requirements. Understanding these adjustments now will help you prepare for potential disruptions and cost increases.

Reciprocal tariffs and calculations:

The tariffs are slated to apply to goods imported from countries such as China, India, Mexico, Germany, Brazil, South Korea, Japan, France, Canada, Italy, Taiwan, the United Kingdom, Thailand, Vietnam, and Singapore.

The U.S. Treasury Secretary has stated that each impacted country will be assigned a single tariff rate based on its trade practices. This rate will account for not only existing tariff levels but also non-tariff barriers such as taxes, currency policies, and labor standards. The exact rates have not been fully disclosed, but they will play a key role in determining the duties imposed on imports from these countries. Businesses should monitor updates closely to understand how these tariffs will affect their specific goods.

Tariff stacking:

Secretary Bessent has not clarified whether tariff stacking - where multiple tariffs could be applied to the same goods, effectively increasing the duty rate- would apply in these scenarios. If that ends up happening, this could significantly increase duty rates on certain imports by layering reciprocal tariffs on top of existing trade restrictions. It remains unclear how these tariffs will interact with current U.S. duties.

Estimated tariff rates:

While final tariff rates are not yet confirmed, we have estimated potential reciprocal tariffs based on current trade data:

• China: 3.1%
• India: 11.5%
• Germany & France: 2.8%–3%
• Mexico: 6%
• Brazil & South Korea: 7%–10%
• Japan & the UK: 2.5%

These figures represent trade-weighted averages and may vary depending on specific trade policies.

Next steps and support: These tariff policies are still being finalized, and updates from U.S. Customs and other trade authorities may impact the final details. We encourage you to stay informed and review any new developments that could affect your supply chain.

Our team is available to help you assess the impact of these changes and explore strategies to manage costs, including tariff classification reviews, trade agreement utilization, and alternative sourcing or routing options. For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com. For inquiries related to Canadian regulations, reach out to compliance.ca.mcsi.nam@maersk.com.

We will continue to monitor the situation and provide updates as more details emerge. For the latest tariff-related updates, you can find all relevant information here.

Global Tariff Updates Impacting Steel, Aluminum, USMCA, Canada, China, and the EU

In our previous communication, we informed you about the February 10, 2025, Executive Order introducing new tariffs on aluminum and steel imports, effective March 12, 2025. We’re now sharing additional details on how these changes impact derivative products and the adjustments required for your commercial invoices to comply with U.S. Customs and Border Protection (CBP) regulations. Additionally, we want to provide the latest updates on tariff changes between the United States, Canada, Mexico, China, and the European Union (EU), which may affect your supply chain. Maersk Customs Services is here to help you navigate these developments and ensure your operations remain compliant and efficient.

Steel & Aluminum Tariffs

The 25% tariff on steel and aluminum imports took effect on March 12, 2025, at 12:01 a.m. Eastern Time.

Derivative products now impacted:

Aluminum Derivatives: Wire, cables, bumper stampings, body stampings, and other fabricated parts. For a complete list of affected products, click here.

Steel Derivatives: Nails, fasteners, vehicle parts, pipes, tubes, and construction materials. For a complete list of affected products, click here.

Foreign Trade Zones (FTZs) Affected: Goods admitted under “privileged foreign status” before March 12, 2025, remain subject to these tariffs.

New Reporting Requirements:

• For aluminum imports, importers must report:
• Primary country of smelt
• Secondary country of smelt
• Country of cast
• For steel imports, importers must report:
• Country where the steel was melted and poured

New Invoicing Requirements

To ensure proper tariff assessment and compliance, importers must adjust how products are listed on commercial invoices:

Wholly Steel or Aluminum Products

Products entirely made of steel or aluminum will remain on a single invoice line with the full value of the product assessed at the applicable tariff rate.

Derivative Products Containing Steel or Aluminum

• Must be separated on the commercial invoice into two distinct lines:
• One line for the steel or aluminum portion of the finished product.
• A separate line for the other materials (e.g., plastic, rubber, or other metal components).
• The additional duties will only apply to the value of the steel or aluminum content, not the entire finished product.

For reference, see this invoice example.

Next Steps

• Review Your Product Classifications to determine if your aluminum or steel derivatives fall under the affected tariff codes.
• Update Your Commercial Invoice Structure to properly list wholly steel/aluminum products and derivative products separately for accurate tariff application.
• Ensure Supplier Compliance by obtaining correct smelting, casting, and pouring origin details from manufacturers.
• Monitor CBP Announcements for further instructions via CBP’s Cargo Systems Messaging Service.

EU Countermeasures on U.S. Steel and Aluminum Tariffs

With the 25% on imports of steel, aluminum, and certain products containing steel and aluminum from the European Union (EU) and other trading partners, the EU has launched a series of countermeasures.

The EU’s response includes two key actions:

1. Reimposition of Suspended Countermeasures: On April 1, 2025, the EU will has announced the 2018 and 2020 rebalancing measures that were previously suspended. These measures will apply tariffs on a range of U.S. goods, including boats, bourbon, and motorbikes.
2. New Package of Additional Measures: The EU is also preparing a new package of countermeasures targeting approximately €18 billion worth of U.S. goods. These measures will complement the reimposed tariffs and are designed to ensure a proportionate response to the increased scope of U.S. tariffs. The EU is currently consulting with stakeholders to finalize the list of targeted products, which includes industrial goods (e.g., steel, aluminum, textiles, plastics) and agricultural products (e.g., poultry, beef, dairy, nuts).

The EU’s countermeasures are expected to take full effect by mid-April 2025, following consultations with EU Member States and stakeholders.

U.S. Tariff Update – USMCA Products from Canada & Mexico

The United States has removed tariffs on certain Canadian and Mexican imports under the United States-Mexico-Canada Agreement (USMCA) until April 2nd. This change benefits businesses importing qualifying goods from Canada and Mexico.

However, it is crucial to remember that not all products qualify for USMCA benefits simply because they originate or are manufactured in the U.S., Canada, or Mexico. Goods must still:

• Be sufficiently transformed according to USMCA rules
• Meet product-specific rules of origin outlined in the agreement

If you need assistance in verifying your products' eligibility under USMCA, our Maersk’s customs compliance team is available to help ensure compliance and maximize duty savings.

Canada’s Tariff Policy Update

Canada will maintain its Phase 1 tariff measures on select U.S. products effective March 4th but has paused the planned Phase 2 tariffs until April 2nd. This means that while certain U.S. goods remain subject to existing Canadian tariffs, no additional tariff rounds will be implemented on March 25th as originally announced.

We recommend reviewing your imports to assess the impact of these measures. Our team can provide tariff classification assistance and strategic guidance to mitigate cost implications.

China's Retaliatory Tariffs on Canada

In retaliation to Canada's tariffs on Chinese goods, China has announced that, effective March 20, 2025, it will impose:

• 100% tariffs on:
• Rapeseed oil
• Peas
• Oilcakes
• Annex 1 List of goods subject to additional 100% tariff.pdf
• 25% tariffs on:
• Aquatic fish/seafood products
• Pork
• Annex 2 List of goods subject to additional 25% tariff.pdf

These measures are in response to Canada's earlier tariffs on Chinese electric vehicles, steel, and aluminum products. Detailed information on China's tariff measures can be found in the official announcement by China's Ministry of Commerce.

We are here to help

Maersk Customs Services is committed to helping you navigate these evolving trade policies. Our Customs Compliance Team can assist with:

• USMCA Eligibility Reviews: Ensuring your products meet the rules of origin.
• Tariff Classification & Duty Analysis: Identifying cost-saving opportunities.
• Trade Compliance Strategy: Mitigating risks and optimizing supply chain efficiency.
• Tariff Classification: Ensuring accurate classification of your goods.
• Invoice Formatting: Adjusting commercial invoices to comply with new tariff requirements.
• Compliance Strategies: Developing tailored strategies to ensure adherence to evolving regulations.

We are here to support you with your logistics needs and will continue to provide customer advisories and updates as the situation develops.

For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com. For inquiries related to Canadian regulations, reach out to compliance.ca.mcsi.nam@maersk.com.

Navigating Tariff Changes Additional Duties Now in Effect for Imports from China, Hong Kong, Canada & Mexico

The US government has announced new and increased tariffs on imports from China, Hong Kong, Canada and Mexico through multiple Executive Orders. As your logistics partner, we want to keep you informed of these developments, help you navigate this changing landscape, and minimize disruption to your supply chain.

What is changing on March 4, 2025?

• 25% additional duty applies to most imports from Mexico (HTS 9903.01.01)
• Exemptions include humanitarian aid and informational materials (books, films, etc.)
• If you use Foreign Trade Zone (FTZ), you must enter goods as "Privileged Foreign Status" and will be subject to duties upon withdrawal.
• These duties cannot be refunded through drawback claims.

• 25% additional duty applies to most Canadian-origin goods (HTS 9903.01.10).
• 10% additional duty applies to Canadian energy products (HTS 9903.01.13), including crude oil, natural gas, and critical minerals.
• Exemptions include humanitarian aid and informational materials.
FTZ impact & no drawback – Same restrictions apply as with Mexico.

• Duty rate has doubled from 10% to 20% on most imports (HTS 9903.01.24).
• Exemptions include humanitarian aid and informational materials.
• If your goods were in transit before Feb 1, 2025, they may qualify for exemption if entered before March 7, 2025 (HTS 9903.01.23).
• FTZ impact & no drawback – Similar to Canada & Mexico, affected goods must enter FTZs under "Privileged Foreign Status."

For steel & aluminum import tariffs, please reference our previous communication.

These new duties are in addition to all other tariffs, including USMCA and existing trade remedies. US Customs and Border Protection (CBP) will reject entries that are non-compliant, including those without proper duty deposits. Importers must ensure accurate product classification and duty calculation to avoid penalties.

• Review your supply chain to Identify affected products and assess cost increases.
• Verify your HTS codes and duty amounts are reported correctly.
• Consider duty mitigation strategies through FTZs, alternative sourcing, or compliance planning.
• Prepare for proper compliance to avoid shipment delays, penalties, and financial risk.

• The Canadian Government will implement a 25% tariff, starting on March 4.
• The Chinese Government will implement tariffs for goods originating in the US, starting on March 10.
• The Mexican Government has not yet announced its retaliatory tariffs.

We are here to support you with your logistics needs and will continue to provide customer advisories and updates on reciprocal tariff announcements as the situation develops.

Our Global Trade and Customs Consulting (GTCC) service at Maersk is here to simplify the complexities of international trade and customs processes. With a global presence across North America, Europe, the Indian subcontinent, the Middle East, Asia, and Africa, Maersk GTCC can help your business manage the customs landscape, reduce risks, and identify opportunities for cost savings and improved efficiency.

For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com. For inquiries related to Canadian regulations, reach out to compliance.ca.mcsi.nam@maersk.com.

Navigating Tariff Changes: Steel and aluminum imports into the United States

Recent announcements regarding tariffs on steel and aluminum imports into the United States may impact your supply chain. As your logistics partner, we want to keep you informed of these developments and help you navigate this changing landscape.

Effective March 12, 2025, the following updates will apply:

1. Revision of Tariff Structure: All steel and aluminum imports, including derivative products, will be taxed at 25% with few exceptions. Previous duty modifications based on country-specific agreements are repealed. Steel and steel derivatives from Turkey will also incur a 25% tariff.

a. Click here for the full list of aluminum products
b. Click here for the full list of steel products

2. Elimination of Exemptions: Exemptions and quotas for countries including South Korea, Argentina, Australia, Brazil, Canada, Mexico, the EU, Japan, the UK, and Ukraine will be revoked. All steel imports from these countries will be subject to the 25% tariff.
3. Expanded coverage:

a. Steel Derivative Products: Products listed under heading 9903 in the HTSUS will incur a uniform 25% tariff, regardless of country of origin. However, steel derivatives processed in another country will not be subject to the tariff if the steel was originally "melted and poured" in the United States.
b. Aluminum Derivative Products: Products listed under heading 9903 in the HTSUS will also incur a uniform 25% tariff (increased from 10%). Aluminum derivatives processed in another country will not be subject to the tariff if the aluminum was originally "smelted and cast" in the United States.

4. Russia-specific tariff increases: Any aluminum article or derivative aluminum product containing Russian-origin primary aluminum is subject to a 200% tariff.
5. Prohibition of Drawback (Refunds): No refunds will be allowed on duties paid under this proclamation.

Please refer to the frequently asked questions about the new steel and aluminum import tariffs.

We are here to support you with your logistics needs and will continue to provide customer advisories and updates on reciprocal tariff announcements as the situation develops.

Our Global Trade and Customs Consulting (GTCC) service at Maersk is here to simplify the complexities of international trade and customs processes. With a global presence across North America, Europe, the Indian subcontinent, the Middle East, Asia, and Africa, Maersk GTCC can help your business effectively manage the customs landscape, reduce risks, and identify opportunities for cost savings and improved efficiency.

For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com.

Navigating Tariff Changes - Strategies for Mitigating Impact on Your Supply Chain

As we have previously communicated and as you are no doubt aware, there have been recent announcements and changes to tariffs and legislation. As your logistics partner, we aim to keep you informed of developments that could affect your supply chain, understanding that these changes may create uncertainty. We are committed to helping you navigate this evolving landscape.

Please refer to the frequently asked questions about the new import tariffs.

We encourage importers to stay informed, proactive, and prepared to navigate the evolving trade landscape of 2025.

Our Global Trade and Customs Consulting (GTCC) service aims to simplify the complexities of international trade and customs processes. Operating globally, with a presence in North America, Europe, the Indian subcontinent, the Middle East, Asia, and Africa, Maersk GTCC can help businesses manage the customs landscape effectively. This partnership can assist in reducing risks while identifying potential opportunities for cost savings and improved efficiency.

For assistance regarding US regulations, please contact us at: compliance.mcsi.nam@maersk.com. For inquiries related to Canadian regulations, reach out to compliance.ca.mcsi.nam@maersk.com.

To address these challenges, here are some strategies to help mitigate the impact of increased tariffs:

Tariff Mitigation Strategies

• Setting up ACH accounts: Automated Clearing House (ACH)
  • Direct electronic payment from your bank account to U.S. Customs.
  • Timely duty payments, reduced processing times, longer payment cycle
• Tariff engineering
  • Ensuring your goods are classified under the correct HTSUS (Harmonized Tariff Schedule of the United States) and Canadian HS Tariff provisions to benefit from lower duty rates.
    *Please note, any reclassification of goods will only impact the regular duty rate, additional duties applied to all tariff numbers will still be in effect.
• New sourcing
  • Rearrange the sourcing of raw materials, components, or finished goods to countries that are not subject to the new tariffs.
  • Shifting production to countries with favorable trade agreements with the U.S. and Canada or sourcing materials from alternative suppliers.
• Bonded warehouses and Temporary Import Bonds (TIB)
  • Bonded warehouses allow you to store goods without paying duties until they’re used or sold, deferring duty payments and providing significant cash flow benefits.
  • Temporary Import Bonds (TIB) are used for goods that are imported for a specific purpose and will be re-exported within a certain period. This allows you to avoid duties on goods that are not intended for long-term importation.

Advocacy for Tariff Reduction

Currently, no exemptions or exclusions are available, but it’s important to know the process in the event these circumstances change. If exemptions or exclusions become accessible, consider the following.

Getting involved with legislative bodies and regulatory agencies to influence trade policies and secure tariff reductions is crucial. Here’s how you can engage:

• Seeking Section 301 Exclusions by applying for exemptions from certain tariffs under the Trade Act of 1974.
• Advocating for renewal of expired exclusions to ensure continued relief for previously exempted products helps maintain competitive market conditions. Participate in public comment periods and provide detailed economic impact analyses to support your cases.

Bond Sufficiency

Maintaining adequate Customs bonds is essential to avoid delays in clearance.
How to calculate bond amounts:

• US: Based on anticipated import duties, taxes, and fees over a 12-month period.
• Canada: Based on 50% of your highest monthly outlay of duty, taxes and fees in the past 12-month period. Required amount of coverage can be found in your CARM portal.
• Regularly review and adjust your bond amounts to ensure they remain sufficient as trade volumes and duty rates change.
• Steps required to secure new import bonds if necessary
  • Work with surety companies to obtain bonds that meet U.S. & Canada Customs requirements
  • Submit the necessary documentation and ensure that bond amounts are updated in a timely manner to prevent supply chain disruptions.

Other Common Strategies

If you have been considering any of the following traditional duty saving tools, this may be a good time to evaluate if they fit your needs.

• First Sale Method – Triangle trade valuation basis using the earliest price paid on imported merchandise.
• Vessel Level Clearances – Save on Merchandise Processing Fees by combining multiple bills of lading on a single entry.
• High Level Risk Assessment - A holistic view of the supply chain and where risk can be identified and mitigated. Review past imports for potential duty overpayments and claim refunds where applicable.
• US Drawback – Recover 99% of eligible duties and fees. *Please note, additional duties from this round of tariffs are not subject to drawback recovery.
• Canada Duty Relief & Drawback Programs
• Duties Relief Program: Import goods without paying duties or surtaxes if they will be re-exported or used in manufacturing for export.
• Duty Drawback Program: Allows businesses to recover 100% of duties and surtaxes paid on imported goods that are later exported, either as-is or after processing.

We are here to support you with your logistics needs and will continue to provide customer advisories and updates as the situation develops.

Global tariffs impacting supply chains

Over the last period of time, there has been a significant uptake in changes to tariffs and legislation on a global plane. As your logistics partner, we endeavor to keep you informed of changes and how they may impact on your supply chain.

On February 1, 2025, the United States government announced the implementation of tariffs on all Canada-origin, Mexico-origin and China-origin goods entering the United States. These tariffs are being applied under the International Emergency Economic Powers Act (IEEPA).

The 10% tariff on all China-origin goods entering the U.S. took effect on February 4. Canada and Mexico imports tariff will be delayed one month. Currently, there is no expiry or revisitation date on the tariffs and no opportunity for tariff exemption. A fact sheet from the U.S. government can be found here.

We recognize that these changes may create uncertainty in supply chains, and we're dedicated to assisting you in managing these challenges. We offer Impact Analysis to assess how these potential tariffs could affect your business, as well as Trade Advisory Services under our Customs House Brokerage product that provide strategic sourcing and contingency planning advice.

Today, we’d like to provide clarity on frequently asked questions about the new import tariffs and outline the solutions available to you:

Lead Logistics

Maersk's Lead Logistics products offer robust support to our customers through our carrier-neutral 3PL service, enabling collaboration with shippers and vendors across the globe. Additionally, we provide a compliant Duty Deduction program that leverages a landmark binding ruling to reduce U.S. import duties by recognizing 29 allowable charges for deduction. This program is integrated with our Customs House Brokerage services, ensuring efficient and effective duty management.

Air Freight

Maersk Air Freight utilizes our own controlled freighter network and global strategic partners to deliver quick and efficient transportation of goods across the globe. We ensure safe and reliable service through a network of hubs and gateways, including operations throughout China and North America. We also provide CFS warehouse solutions at our hubs, allowing for the handling of import cargo pending Customs clearance.

Less than Container Load (LCL)

Our LCL services address your small shipments to and from any global location, adapting to your changing sourcing needs. Our services include consolidation and deconsolidation, allowing you to group smaller shipments and reduce transaction costs. You can also access instant online quotes and benefit from door-to-door services, simplifying your international shipping experience.

Intermodal

We are ready and available to support you in flexing up capacity through our drayage asset network or flex down capacity by providing storage solutions through depot services, both of which include national coverage.

Warehousing

We partner with our customs colleagues to assess various network options, ensuring the optimal supply chain solution for your business considering the recent announcements regarding 321 (De Minimis), potential tariffs, and the general need for added flexibility. We manage the flow of products to your inland and final destinations through our transload centers located in key import gateways, including Redlands, Houston, Vancouver, Seattle, Burlington, Savannah, and Chesapeake. We can also quickly activate short- and long-term warehouse solutions in our existing facilities in Redlands, Seattle, Savannah, and Burlington to help you transition fulfillment of orders back to the U.S. and reduce tariff impact.

Ground freight

Maersk Freight Brokerage collaborates with 58 bonded FTL dry van and reefer carriers to meet your cross-border transportation needs to and from Canada and Mexico. We also partner with four bonded standard LTL carriers for Canada and Mexico cross-border shipments. This enables us to provide the right coverage and capacity for your FTL and LTL transportation requirements.

E-Commerce Parcel Delivery

Maersk Parcel Delivery ensures seamless national coverage by leveraging a dynamic network of national and regional carriers. Our advanced technology selects the best available carrier and routing options, adapting in real time to maintain uninterrupted service—even in the face of market disruptions or carrier issues. With built-in flexibility, our solution continuously optimizes the delivery network to ensure the fastest and most reliable path for every parcel. It also quickly adjusts to evolving tax and trade policies keeping deliveries efficient.

For international inbound shipments, we facilitate smooth transitions from major airport gateways and brokers—such as JFK, ORD, and LAX—seamlessly integrating into our North American delivery network for timely, final-mile delivery.

For any questions or assistance, please reach out to your Maersk representative.