September ’25 at-a-glance … taxes, tariffs & trade

The latest tariff information, including that below, is available on the Taxes, Tariffs and Trade page of nafem.org. While NAFEM regularly updates this resource page, we recommend regular communication with your customs broker for up-to-the-minute tariff information relative to your business and its products.  

Effective: 

  • Aug. 19 – 407 additional derivative product codes were added at the 50% Section 232 tariff rate, according to the Federal Register notice.  
  • Aug. 29 – De Minimis tariff exemptions no longer apply, per Executive Order
  • Sept. 1 – According to a White House Announcement, tariffs equal to the higher of 15% or the U.S. Most Favored Nation tariff rate apply to imports from all 27 European Union countries. 
  • Through Nov. 10 – Current 10% reciprocal tariffs on China imports continue through Nov. 10 while discussions are ongoing. These tariffs are in addition to the 20% IEEPA-Fentanyl tariffs detailed in the White House Fact Sheet.  

Also, on Aug. 28, the U.S. Court of Appeals for the Federal Circuit struck down the IEEPA and reciprocal tariffs in a 7-4 decision. However, the tariffs remain in place as the Court sent the case back to the Court of 

International Trade to determine what is covered by the ruling. 

Customs and Border Protection (CBP) published a useful FAQ on the IEEPA tariffs.  

Proposed legislation would simplify tariff structure 

The recently introduced bipartisan Secure Trade Act (HR 4978) would codify a 10% baseline tariff on all imported goods. It also would revise HTS categories to create a 35% tariff on nonstrategic goods from China and a 100% tariff on strategic goods from the country. The proposal has been referred to the Committee on Ways and Means, and the committees on Financial Services, Foreign Affairs, and Energy and Commerce, 

Upcoming webinar on tariff enforcement 

NAFEM’s legal team at Barnes & Thornburg is hosting Trials and Tribulations: When Tariff Enforcement Gets Serious. NAFEM members are invited to join the webinar, Sept. 17 at 12 p.m. Eastern.