Compliance Updates as of August 14, 2025

CSMS # 65894387: IEEPA Reciprocal Tariff Rate for China New 90-Day Pause

The White House has extended the pause on China’s Reciprocal tariff under IEEPA for another 90 days. This means:

  • China/Hong Kong/Macau goods remain at 10% until at least November 10, 2025.

  • The new individual Reciprocal rate (whatever that is negotiated to be) will take effect on November 10, 2025.

  • IEEPA-Fentanyl duties (20%) still apply in addition, as do any applicable other duties (Section 302 for example).

Full Executive Order: White House – Further Modifying Reciprocal Tariff Rates

Impact of the IEEPA-Reciprocal Rates on Gold Imports

Importers of Gold bullion should be aware of a new Customs Ruling N351466 (released July 31, 2025), which clarifies Customs preferred classification for certain gold bullion:

  • Customs advises not to use 7108.12.10 (Free) as originally considered.

  • Correct classification: 7108.13.5500 (Free under normal duty).

Why this matters:

  • 7108.12.10 is on the IEEPA Exemption List, meaning it avoids Reciprocal tariffs.

  • 7108.13.5500 is not exempt, so it is subject to IEEPA-Reciprocal tariffs based on Country of Origin.

Importers of gold bullion should review their classifications carefully to avoid unexpected duties.

25% Tariff on Indian-Origin Goods – Effective August 27, 2025

The White House has announced an additional 25% duty on certain products from India, starting August 27, 2025.

Key Details:

  • Stacking Rules: This 25% duty applies in addition to other duties. *This included the current 25% IEEPA-Reciprocal Individual Tariff for India that went into effect August 7, 2025.

  • Effective Date: Goods entered for consumption on or after August 27, 2025, will incur the extra 25% duty.

  • In-Transit Exemption: Shipments loaded before August 27 and entered by September 17, 2025, are exempt.

Exceptions:

  • Section 232 duties (steel, aluminum, copper) – no additional 25% if 232 applies.

  • Items excluded under IEEPA  Annex II authority remain excluded.

  • Foreign-Trade Zones: Goods admitted on or after August 27 must use privileged foreign status, and the 25% duty will apply when entered for consumption.

Official Executive Order: White House Announcement

For assistance and additional questions, please reach out to Janel Group's Compliance Team or a Janel Group Representative.

Sean McClung

Director of Trade Compliance

Jodi Blitz

Senior Compliance Analyst