Recent Trade & Compliance Updates as of August 27, 2025

US-EU Trade Framework

The U.S. and EU have agreed to a new Framework on Reciprocal, Fair, and Balanced Trade aimed at reducing tariffs and strengthening supply chains.

Key Highlights:

EU Tariff Cuts:
Tariffs eliminated on all U.S. industrial goods
Expanded access for U.S. seafood & agriculture (lobster, tree nuts, dairy, pork, etc.)
U.S. Tariff Rules:
Most EU goods → Higher of MFN (Most Favored Nation tariff rate) or 15%
Effective Sept. 1: Only MFN applies for EU cork, aircraft/parts, generic pharma
Section 232 Adjustments:
Pharma, semiconductors, lumber → Capped at 15%
Autos/parts → MFN ≥15%: No 232 tariff; MFN <15%: Combined to reach 15%
Supply Chain & Security:
Joint action on investment screening, export controls, and anti-evasion efforts

Brazil IEEPA Update (Executive Order – July 30, 2025)

What Changed

New Additional Duty: 40% additional duty on imports of goods that are products of Brazil, effective for entries on or after 12:01 a.m. EDT, August 6, 2025 under HTSUS (CBP Notice).
Stacking Applies: This 40% duty adds to existing reciprocal tariff (~10%), bringing the total additional duty to 50%.
Exclusion: Does not apply to goods already under Section 232 tariffs (e.g., certain steel, aluminum, autos).

Key Exemptions

In-Transit Shipments: Goods loaded in Brazil and in transit before August 6, 2025, and entered by October 5, 2025.
Humanitarian Donations: Food, clothing, medicine.
Informational Materials: Books, films, etc.
Annex I Products: Examples: Brazil nuts, orange juice, certain energy and paper products, pig iron, wood pulp, silicon metal.
Civil Aircraft & Parts.
Section 232 Goods: Steel, aluminum, autos, copper products.

Other Notes for Importers

Foreign Trade Zones: Brazilian goods admitted on or after August 6 must enter as privileged foreign status; duties apply when entering U.S. commerce (CBP Notice).
Duty Drawback: Refunds on these duties are allowed under standard drawback rules.

India IEEPA Update (August 27, 2025)

Federal Register Notice | White House EO

What Changed

New Additional Duty: 25% duty on imports of Indian products (linked to Russian oil supply concerns), effective 12:01 a.m. EDT, August 27, 2025, under (Federal Register).
Stacks with Other Duties: Applies in addition to existing tariffs, except Section 232 duties.

Key Exemptions

In-Transit Shipments: Goods loaded before August 27, 2025, and entered by September 17, 2025.
Annex II Products: Covered under reciprocal tariff rules.
Section 232 Goods: Iron/steel, aluminum, autos, copper products.
Humanitarian Donations.
Informational Materials.

Other Notes for Importers

Foreign Trade Zones: Indian goods admitted on or after August 27 must enter as privileged foreign status; duties apply when entering U.S. commerce (Federal Register Notice).

CBP Update: Stricter Cargo Description Rules

CBP is implementing an auto-rejection system for vague or incomplete cargo descriptions, shipper names, and consignee names in ACE.

Key Points for Importers & Carriers:

Effective Now in Testing (ACE CERT). Live deployment to ACE Production on Sept. 27, 2025, and applies to all modes: Air, Ocean, Rail, and Truck manifests.
Entries with insufficient or generic descriptions (e.g., “parts,” “freight”) will be automatically rejected. This can cause delays, possible penalties, and supply chain disruptions.
Bill of Lading details must be complete and accurate—carriers and anyone filing data must ensure precise descriptions and correct shipper/consignee info.
Update your processes with carriers and vendors now to avoid rejections after September 27.

Questions? Contact your CBP Client Rep or email CREM@cbp.dhs.gov.

Reminder: 40% Transshipment Penalty

Applies: To shipments routed through third countries to evade tariffs on/after Aug. 7, 2025. This will be advised by Customs to the Broker.
Exemption: Goods loaded before Aug. 7 and entered by Oct. 5 (meeting in-transit criteria)
Rate: 40% penalty in addition to normal HTS duties
No mitigation/remission allowed under 19 U.S.C. § 1592
Action: Keep strong origin, production, and transit records to prove legitimate routing

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

Director of Trade Compliance

Senior Compliance Analyst