On Friday September 5, 2025, the Trump Administration issued an executive order that amended the list of products that are currently exempt from IEEPA Reciprocal tariffs and also significantly modified the processes and procedures for updates to IEEPA Reciprocal Tariffs and Section 232 tariffs.
Key Changes and Modifications
- Annex II as announced on April 2, 2025, and modified on April 11, 2025, contained a list of HTS codes that were exempt from IEEPA reciprocal tariffs as the goods identified under those HTS codes were either subject to ongoing Section 232 investigations or were potentially part of future Section 232 investigations.
- Annex I of the September 5, 2025, Executive Order adds 40 new HTS codes which are no longer subject to IEEPA Reciprocal Tariffs. The products include critical minerals like nickel, tin, and thorium ores, chemicals, permanent magnets, and LEDs just to name a few.
- Exemptions for 8 HTS codes were removed from Annex II which means that they are no longer exempt from IEEPA Reciprocal tariffs. The products include aluminum hydroxide, crystals, resins, PET, and silicones.
Customs has issued reporting guidance as these tariffs go into effect at 12:01am on Monday September 8, 2025.
