Trade & Tariff Updates as of September 10, 2025
Updates to IEEPA-Reciprocal, Section 301, and Customs User Fees
Section 301 China Exclusion Extensions - CSMS # 66077997
On August 27, 2025, USTR (United States Trade Representative) extended through November 29, 2025:
164 product exclusions, and
14 equipment exclusions
This update applies to goods entered September 1 – Nov. 29, 2025.
For the full information, please see the Federal Register Notice (FRN).
CSMS # 66146676 – U.S.–Japan Agreement (Retroactive Implementation)
On September 4, 2025, the White House issued an Executive Order establishing a new IEEPA-Reciprocal baseline 15% tariff on nearly all Japanese imports, with special treatment possible for:
Autos and parts
Aerospace products
Generic pharmaceuticals
Certain natural resources are not produced in the U.S.
Key points:
Tariffs apply retroactively to entries made for consumption or withdrawn from the warehouse on/after Aug. 7, 2025.
Refunds will be issued under CBP procedures, but we are advised not to file PSCs or Protests until CBP issues refund instructions.
UPDATE – Products Exempted from Reciprocal Tariffs - (Annex II Exclusion Updates from CSMS # 66151866)
On September 5, 2025, an Executive Order and supporting Fact Sheet were released by the White House modifying the scope of the IEEPA-Reciprocal Annex II Exclusion tariff list.
Effective as of September 8, 2025.
Added to Exclusions (meaning no longer subject to Reciprocal duties): Bullion-related articles, certain critical minerals, and pharmaceutical products.
Removed from the exclusions (meaning now subject to reciprocal tariffs) several previously exempted products.
For the full new updated Annex II Exclusion List PDF (Effective September 8, 2025)
Reminder – Customs User Fees Increasing Effective October 1, 2025
As announced in 90 FR 34665 Federal Register Notice (FRN) released on July 23, 2025, Customs will adjust its user fees for inflation. See CSMS # 65741993.
Key Points
The Merchandise Processing Fee (MPF) rate of 0.3464% will NOT change.
The MPF minimum and maximum for formal entries (class code 499) WILL change.
The minimum will increase from $32.71 to $33.58
The maximum will increase from $634.62 to $651.50.
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