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For April, we are highlighting Christopher Gottlob, CHB Supervisor in our Detroit, MI branch.  Christohper has a bachelor’s degree in supply chain management.  Christopher started working at JAS in 2017 as an intern.  In 2019, he moved into a brokerage position and found that he enjoyed doing customs entries more than moving freight.  Christopher took and passed the Licensed Customs Broker exam in 2020 during Covid, which gave him plenty of time for studying.  In 2022, Christopher became the CHB Supervisor in Detroit.  Christopher has been able to follow the HTS GRIs and cross reference with CBP rulings to help clients find more appropriate HTS codes and in some cases, that has led to lower duties, saving his client on duties!

Christopher is married to his wife Megan, and they have a 2 year old daughter and are expecting their second in July.  Christopher and his family have 2 cats, and a dog.  He loves to go Detroit Lions games as a season ticket holder, golfing and enjoying his cabin in north Michigan with family and friends.

Christopher is another great example that People Make the Difference!

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JAS Forwarding (USA) Inc. Compliance Project Manager, Scott Cassell in partnership with Sheryl Roberts, Director of Ocean Services, and Vivian Brunialti, Trade-Lane Director, presented at a client event in Miami, FL on March 27.  Ocean trends from Asia to the US and LATAM were discussed along with all the tariffs in the news.

Pictured left to right, Scott Cassell, Vivian Brunialti, and Sheryl Roberts

A California based importer have agreed to resolve allegations that they violated the False Claims Act.  The importer evaded customs duties on imports from PRC.  The importer faces paying $8.1 Million to settle the violations.

Click below to read more.

Dear Valued Client,

We wanted to take an opportunity to clarify that IEEPA Drug/border tariffs (20% effective March 4, 2025 for China), and (25% effective March 4 for Canada and Mexico) are still in effect.  IEEPA Drug/border tariffs are distinctly different than the new IEEPA Reciprocal tariffs announced yesterday.  

China

- IEEPA Reciprocal tariffs from China (34%) apply effective April 9.

- If section 232, steel, aluminum, derivatives, autmobiles, and auto parts is applicable, then section 232 (25%) tariff supersedes the IEEPA Reciprocal tariffs at 34%.

- Section 301 for China still applies .

- IEEPA Drug/border tariffs from China (20%) still applies.

Canada/Mexico

- Goods from Canada and Mexico are exempt from the IEEPA Drug/border tariffs if qualifying for USCMA.

- If goods are not qualifying for USMCA, then IEEPA Drug/border tariffs apply (25%).

- If the IEEPA Drug/border tariff is terminated or suspended, USMCA qualifying goods will be exempt from IEEPA Reciprocal tariffs and non-USMCA goods will be subject to a 12% IEEPA reciprocal tariff.

- No dates have been provided at this time.

Additional updates will follow once they are available.

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All of the comments in this advisory are subject to change and based on our current interpretation.  The President issued executive orders yesterday, April 2.  

Section 321/de minimis goods from China/Hong Kong will be elmininated.  All goods of China/Hong Kong which are shipped by any method other than the international postal network are ineligible for de minimus as of 12:01 am EDT May 5, 2025.  Entries must be made using formal or informal entry.

Goods shipping via international postal methods from China/Hong Kong will be subject to duty rates equal to either:

- 30% of the value as of May 2, 2025; or

- $25 per item (from May 2- May 31, 2025); or

- $50 per item from June 2, 2025.  

- These duties will be in lieu of most favored nation rates, IEEPA drug tariffs, and 301 tariffs.

Packages from Macau remain eligible for de minimis but there may be a recommendation to extend the prohibition to Macau within 90 days.

All other countries are exempt from this de minimis change until Commerce has established a system to collect the tariffs.

Additional updates will follow once they are available.

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All of the comments in this advisory are subject to change and based on our current interpretation.  The President issued executive orders yesterday, April 2.  The orders utilize International Economic Emergency Power Act (IEEPA) authority to impose a universal 10% tariff on all countries except some specific countries with greater rates.  Additionally, the list of products subject to section 232 tariffs on automobiles/auto parts has been released.  The Department of Commerce also added two new products to the section 232 derivative aluminum articles.

IEEPA reciprocal tariffs of 10% ad valorem will be added for all countries. These will be effective at 12:01 am EDT April 5, 2025.  Note that goods loaded onto a vessel at the port of lading in the final mode of transit prior to April 5, will not be subject to the IEEPA reciprocal tariffs.

IEEPA reciprocal tariffs with specifc rates (for countries listed in Annex I) will be effective at 12:01 am EDT on April 9, 2025.  Note that goods loaded onto a vessel at the port of lading in the final mode of transit prior to April 9, will not be subject to the IEEPA reciprocal country specific rate.  

There are published exceptions which define products that are excluded from the IEEPA reciprocal tariffs. Goods for personal use, donations, informational articles including publications, films and posters etc., under 50 USC 1702 are exempt.  

Steel, aluminum, and derivatives, automobiles and auto parts under existing section 232 tariffs are exempt from the IEEPA reciprocal tariffs (note all existing tariffs still apply). Additionally, goods listed in Annex II (linked below) of the order are exempt, which includes items such as copper, pharmaceuticals, semiconductors, lumber, certain critical minerals, and energy/energy products. We believe these items are going to be addressed separately.  The value of US content on any goods which have no less than 20% US value will be exempt from IEEPA reciprocal tariffs.

Section 232 for automobile and auto parts annex has been released.   Section 232 for automobile tariffs are effective 12:01 am EDT April 3, 2025 with 25% tariffs applicable.  Section 232 for auto parts tariffs are effective 12:01 am EDT May 3, 2025 with 25% tariffs applicable.  The full list of applicable HTS codes are linked below.

Goods from Canada and Mexico that currently qualify for USMCA are exempt from the IEEPA border tariffs.  However, upon termination/suspension of IEEPA border tariffs (25%), USMCA goods will be exempt from the IEEPA Reciprocal tariffs and non-USMCA goods will be subject to 12% IEEPA tariffs.  No dates have been provided at this time.

Finally, the Department of Commerce has added two items to the Aluminum Derivatives list which include aluminum cans (7612) and aluminum cans containing beer (2203).  These are effective 12:01 am EDT April 4, 2025 with 25% tariffs applicable.

Note that goods admitted to Foreign Trade Zones after 12:01 eastern on April 9 must be admitted in privileged foreign status.  It is noted that goods that are eligible for admission to an FTZ under domestic status will be exempt from the tariffs.

Update 4-7-2025- IEEPA reciprocal tariffs are eligible for drawback. Unlike in previous IEEPA action, there is no express prohibition of claiming duty drawback on these tariffs.  

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The President has announced broad reciprocal tariffs.  The reciprocal tariffs will vary by country. The tariffs reciprocal tariffs will depend on existing tariffs for US goods exported to those countries.

The President shared a chart showing various rates applied to US goods to countries and the reciprocal tariff that will be applied to goods from those countries.  Examples included China with overall tariff percentage of 67% on US goods, which the US will be applying a reciprocal tariff of 34%.  Other examples include Japan charging 46% on US goods and the US now applying a 24% reciprocal tariff.  JAS will post the full list once it is officially published.

Other deveopments today include a list of specific HTS codes for automobiles subject to the 25% tariff effective April 3.  Auto parts will be implemented on May 3.  

Finally, aluminum containers under 7612.90.10 and beer under 2203.00.00 have been added to the aluminum derivatives list.

Additional updates will follow once they are available.

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In an Executive Order published on March 24, 2025, the administration has announced 25% tariffs on countries that import oil from Venezuela.  The order states that “On or after April 2, 2025, a tariff of 25 % may be imposed on all goods imported into the United States from any country that imports Venezuelan oil...”  These duties will be supplemental to duties already imposed such as IEEPA, Section 232, Section 301 China tariffs, etc.

Additionally the President signed an executive order on March 26 applying Section 232 duties to automobiles, light trucks and auto parts (such as transmissions/powertrain parts, engines and engine parts etc.).  The rate of duty will be 25% and this will go into effect starting April 3.  It will not apply to USMCA parts until a process has been established to account for the non-US content of auto parts.  If additional parts are to be tariffed, there will be a Federal Register notice as soon as practicable after the Commerce Secretary’s decision, and the tariffs will be collected one day after that notice.

Finally in response to a question yesterday, the President indicated that Lumber Tariffs may come starting on April 2.

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Tariffs on Imports

Note this information is subject to change

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Canada

• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.

• 10% IEEPA tariff on potash not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.

• 10% IEEPA tariff on energy not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.

• IEEPA tariffs became effective March 4, 2025.

• March 7, 2025 the carve out for USMCA became effective.

• USMCA qualified goods can be entered without the additional IEEPA rate.

• There’s no mechanism to recover duties paid from March 4 through March 6 on USMCA goods.

• If eligible for USMCA based on USMCA rules of origin, then IEEPA tariff will not apply.

Mexico

• 25% IEEPA tariff on goods not meeting USMCA (U.S.-Mexico-Canada Agreement) rules of origin.

• IEEPA tariffs became effective March 4, 2025.

• March 7, 2025 the carve out for USMCA became effective.

• USMCA qualified goods can be entered without the additional IEEPA rate.

• There’s no mechanism to recover duties paid from March 4 through March 6 on USMCA goods.

• If eligible for USMCA based on USMCA rules of origin, then IEEPA tariff will not apply.

China

• IEEPA 20% tariff on all imports.

• Was initially 10% but was increased to 20% on March 4, 2025.

• Started on February 4, 2025.

• Goods on final leg destined to the US prior to February 1 and arriving before March 7, 2025 were eligible for an exemption on the IEEPA tariff.

• Existing Section 301 tariffs still in affect on top of IEEPA tariffs.

• Tariffs stack including IEEPA, 301 and 232 tariffs.

• Existing Section 301 exclusions are still in effect until their expiry date.

Section 232: Steel & Aluminum Tariffs

• All non-US steel and aluminum tariffs are 25% regardless of origin

• 25% tariffs expanded to include derivative products.

• No more exclusion process

• No Drawback allowed

• End of quota agreements with affected countries

• FTZ admissions must be in Privileged Foreign Status

• Listing of affected HTS codes and their corresponding chapter 99 program tariff can be found at the link below.

• Automobiles, aluminum containers and beer added to Section 232 25% tariffs

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International Emergency Economic Powers Act (IEEPA)

• Grants the U.S. President authority to regulate commerce in response to national emergencies.

• Used to impose economic sanctions, restrict trade, or freeze assets of individuals, companies, or governments.

• Aims to protect U.S. national security and foreign policy interests.

• No drawback allowed

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JAS Forwarding (USA) Inc. Compliance Team is pleased to announce that we will be hosting a webinar on all things tariffs on March 25, 2025, at 3PM Eastern time.

On the agenda, we will cover Canada tariffs, Mexico tariffs, China tariffs, Steel & Aluminum, reciprocal tariffs and much more.

Our own Laurie Arnold and Scott Cassell will discuss tariffs and answer questions. Check out our webinar flyer and the link to the registration page below.

Multiple media outlets are reporting that the President will increase tariffs on steel and aluminum from Canada from 25% to 50% in response to the electricity price increases announced by the Ontario government for electricity sold to the United States.  The President noted on a Truth Social post that the increase is effective starting tomorrow, March 12, 2025.

Read our full advisory by clicking below.

Customs and Border Protection has issued two CSMS messages, 64348288 and 64348411 providing guidance on handling of steel and aluminum derivatives including derivatives outside of chapters 73 and 76. The additional 25% duty will be applicable starting on March 12, 2025, for ALL steel and aluminum derivatives.

To read our full advisory, click on the link below.

Check out the link below to see our drawback webinar from March 4.

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The President has signed an amendment to the Executive Orders related to goods from Canada and Mexico.  This amendment addresses duties on Canadian and Mexican goods that are eligible for duty free entry under USMCA.

To read the full advisory, check out the link below.

An update has been provided regarding the steel and aluminum derivatives that are subject to the 25% additional tariff.  The additional tariffs for the derivatives listed in chapter 73 and 76 will go into effect on March 12, 2025.

To read the full advisory, check out the link below.

Multiple media outlets are reporting that the paused tariffs with Canada and Mexico will go into effect on March 4, 2025.  It has also been stated that the 10% additional tariffs on goods from China implemented in early February may be increased to 20% effective on March 4, 2025.

To read our advisory, check out the file below.

As the Administration continues to announce numerous new tariffs on various imported goods, it is crucial for importers to review their continuous bond sufficiency. With increased tariff rates and new product categories subject to additional duties, the potential for higher liabilities has significantly risen.

To read the full advisory check out the link below:

On February 11, 2025, the President issued a proclamation regarding the importation of steel and aluminum articles, increasing tariff rates to 25% from all countries. As part of that proclamation, it was announced that there would be expanded 25% tariffs to include key downstream products (derivatives) for both steel and aluminum. The Annex containing those products has been drafted and is expected to be officially published in the Federal Register on February 18, 2025.

Key Points:

• There are 167 new codes for steel downstream products (derivatives) subject to the 25% tariff referenced in this proclamation (covering 4 different chapters of the HTSUS).

• There are 123 new codes for aluminum downstream products (derivatives) subject to the 25% tariff referenced in this proclamation (covering 11 different chapters of the HTSUS).

To read the draft Federal Register, and access our Excel listing of HTS affected, click the links below:

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On February 13, 2025, during a news conference, the President directed agencies to investigate plans for reciprocal tariffs.  In attendance, Howard Lutnick, the Commerce Secretary nominee commented that the investigation will likely be completed by April 1 and that the President could act as soon as that investigation is complete.

Click below to read the full advisory.

In March 2019, JAS Forwarding Miami Branch was very pleased to have MSA Security on site for a live demo of their canine screening process.  The 3PK9 Security Program allows airlines and freight forwarders to utilize private sector canine teams as a primary screening method.  Essentially, reducing time and cost compared to other screening procedures.

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U.S. Customs and Border Protection (CBP) will pull around 750 officers off ports of entry and redeploy them to process record numbers of migrant families entering the United States at the Mexico border, the head of the agency said on Wednesday.

The agency is also redirecting service personnel and expanding food, transportation and medical contracts to meet migrants' humanitarian needs while maintaining border security, CBP Commissioner Kevin McAleenan said at a news conference in El Paso, Texas.

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"There will be impacts to traffic at the border. There will be a slowdown in the processing of trade," he said.

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G-TEC 2019

Date:  July 29-30, 2019

Location:  New Orleans, LA

The NCBFAA Educational Institute invites all global logistics professionals to its Fifth Annual Global Trade Educational Conference (G·TEC). This two-day event in beautiful New Orleans, LA will give customs brokers, freight forwarders, NVOCCs, OTI, service providers, importers, exporters and all global logistics professionals an opportunity to update themselves on industry developments and connect with colleagues new and old.

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​BIS Annual Update Conference 2019

Date:  July 9-11, 2019

Location:  Washington, DC

The Bureau of Industry and Security’s annual Update Export Control Policy Conference gives the exporting community the opportunity to learn first-hand from senior U.S. Government officials about current issues and trends in export control policies, regulations and practices. This major outreach activity draws business and government representatives from around the world to exchange ideas about export control issues. It provides attendees with the opportunity to interact with U.S. Government officials about programs and services offered by U.S. Government and industry exhibitors. It is one of the Department of Commerce’s most notable international trade events.

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Did the London Bridge Really Fall Down???  Not really… but its U.S. Customs Declaration was the World’s Largest Antique to Ever be Sold!

London Bridge wasn't exactly falling in the 1960s; however, it was sinking under the weight of modern traffic. When the capital city in England decided to build another to replace it, the 1831 bridge was put up for sale. The winning bid came from Robert P. McCulloch, American entrepreneur and chairman of McCulloch Oil Company.

McCulloch paid $2,460,000—plus shipping costs of around $240,000—to bring the bridge to the United States piece by piece. CBP declared the 137-year-old bridge to be an “antique” and therefore duty free.  It took three years to complete the bridge and remains one of Arizona’s most visited tourist attractions!

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2019 Census Webinar Series

Date:  April 2019 – June 2019

The U.S. Census Bureau will conduct a series of free data access webinars to all interested data users.  To learn about and to register for the webinars, please visit Census Academy at the link provided.  

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​SAVE THE DATE:  BIS Update Conference 2019

Date:  July 9-11, 2019

Location:  Washington, DC

The Bureau of Industry and Security (BIS) is preparing for the annual Update Conference on Export Controls and Policy in Washington, D.C.  This major outreach activity draws business and government representatives from around the world to learn and exchange ideas about export control issues.  It is one of the Department’s most notable international trade events.  

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​2019 G-TEC Conference

Date:  July 29 – 30, 2019

Location:  New Orleans, LA

The NCBFAA Educational Institute is proud to invite all global logistics professionals to the 5th Annual Global Trade Education Conference (G-TEC).  This two-day event in New Orleans, LA will give customs brokers, freight forwarders, NVOCCs, service providers, importers, exporters and all global logistics professionals an opportunity to update themselves on industry developments.  

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