CBP issued implementation guidance for the reciprocal tariff program covering 57 trading partners with country-specific ad valorem rates ranging from 10% to 46%. Duties are additive to existing MFN, Section 301, and Section 232 duties. Foreign Trade Zone status does not exempt goods from reciprocal duties, but drawback remains available for exports.
Who it affects
All importers of merchandise from covered countries, with the heaviest impact on Southeast Asian sourcing (Vietnam, Cambodia, Thailand) and EU imports.
What changed
New HTSUS Chapter 99 subheadings 9903.02.01 through 9903.02.57 assigned by country of origin.
In-transit merchandise loaded prior to February 1, 2026 exempt if entered by March 1, 2026 — bill of lading date controls.
USMCA-qualifying goods from Mexico and Canada exempt; non-qualifying goods subject to the applicable country rate.
Action required
Map current sourcing by country of origin to the new country-specific rates before the effective date.
For pending shipments, confirm bill of lading dates and expedite entry to preserve in-transit exemption where applicable.
Evaluate drawback and FTZ withdrawal timing — reciprocal duties compound with Section 301, so working-capital exposure can double for high-China-content goods.
Relevant HTS / regulation
9903.02.019903.02.57
Affected by this CSMS?
Have us audit your entries — we'll quantify the exposure or the recoverable refund in 10 business days.