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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On March 3, 2025, the White House issued an <a href="https://www.whitehouse.gov/presidential-actions/2025/03/further-amendment-to-duties-addressing-the-synthetic-opioid-supply-chain-in-the-peoples-republic-of-china/" target="_blank" rel="noreferrer noopener">Executive Order</a> to further address the synthetic opioid supply chain in China by increasing the current tariffs on all products of China (and Hong Kong) from 10% to 20%. China immediately responded by announcing that it will implement additional tariffs of up to 15% on key U.S. agricultural products.
<h2 class="wp-block-heading">Implementation of Tariffs</h2>
In order to implement the additional tariffs, on March 3, 2025, U.S. Customs and Border Protection (CBP) has issued draft Federal Register <a href="https://www.federalregister.gov/public-inspection/2025-03677/implementation-of-additional-duties-on-products-of-the-peoples-republic-of-china-pursuant-to-the" target="_blank" rel="noreferrer noopener">notice</a> (to be published March 6, 2025), Implementation of Additional Duties on Products of the People&rsquo;s Republic of China Pursuant to the President&rsquo;s Executive Order 14195, Imposing Duties to Address the Synthetic Opioid Supply Chain in the People&rsquo;s Republic of China. The same day, CBP <a href="https://content.govdelivery.com/bulletins/gd/USDHSCBP-3d52328?wgt_ref=USDHSCBP_WIDGET_2" target="_blank" rel="noreferrer noopener">published a message</a> via the Cargo Systems Messaging Service (CSMS) providing further clarifications, including the following:
Effective Dates &amp; Rates:
<ul class="wp-block-list">
<li>From February 4, 2025, to March 3, 2025, goods from China and Hong Kong are subject to an additional 10% duty under HTSUS classification 9903.01.20.</li>
<li>Starting on March 4, 2025, the additional duty rate increases to 20% under HTSUS classification 9903.01.24.</li>
</ul>
These duties apply in addition to all other applicable duties, taxes, fees, exactions and charges. CBP further notes that products of China that are eligible for temporary duty exemptions or reductions will be subject to the additional 20% ad valorem rate of duty.
Exclusions: Certain products are excluded from these additional duties, including donations for human suffering relief, informational materials, and goods in transit before February 1, 2025.
Chapter 98: Goods entered under HTSUS Chapter 98 provisions are generally exempt from these additional duties, except for specific subheadings related to repairs, alterations, or processing performed in China and Hong Kong.
FTZs: Products from China and Hong Kong admitted into U.S. foreign trade zones (FTZs) must be classified under &ldquo;privileged foreign status&rdquo; and will be subject to the applicable duties upon entry for consumption.
Drawback: No drawback is available for these additional duties.
De Minimis: The Section 321 de minimis exemption currently remains available for eligible articles.
For prior updates on these recent China tariffs, see Thompson Hine updates of <a href="https://www.thompsonhinesmartrade.com/2025/02/cbp-issues-notice-and-csms-messages-regarding-application-of-additional-duties-on-china-and-removal-of-de-miminis-exemption/">February 5, 2025</a> and <a href="https://www.thompsonhinesmartrade.com/2025/02/president-trump-initiates-tariffs-on-canada-mexico-and-china-under-the-ieepa-tariffs-on-mexico-and-canada-suspended-until-march-1-but-tariffs-on-china-start-february-4/">February 3, 2025</a>.
<h2 class="wp-block-heading">China&rsquo;s Retaliation</h2>
In reaction to the new tariffs imposed by the United States, China announced on March 4, 2025 that it will implement <a href="https://gss.mof.gov.cn/gzdt/zhengcefabu/202503/t20250304_3959228.htm" target="_blank" rel="noreferrer noopener">additional tariffs</a> of up to 15% on imports of key U.S. agricultural products, including chicken, wheat, corn, cotton, soybeans, sorghum, pork, beef, aquatic products, fruits, vegetables and dairy products. The tariffs will take effect on March 10, 2025. Goods already in transit will be exempt until April 12, 2025. China also introduced other measures targeting the United States, which include: (1) <a href="http://www.customs.gov.cn/customs/302249/2480148/6388574/index.html" target="_blank" rel="noreferrer noopener">halting lumber imports</a> from the United States; (2) <a href="http://www.customs.gov.cn/customs/302249/2480148/6388602/index.html" target="_blank" rel="noreferrer noopener">suspending permits</a> of three U.S. companies for exporting soybeans to China; (3) expanding <a href="https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_e1ea9512b1f84dc6b1a17f703fa4cf56.html" target="_blank" rel="noreferrer noopener">export controls on certain items</a> in an effort to target a number of U.S. defense contractors, and (4) initiating a circumvention <a href="https://www.mofcom.gov.cn/zwgk/zcfb/art/2025/art_d94b0155ebb547609e748b23a94b8139.html" target="_blank" rel="noreferrer noopener">investigation</a> on the existing antidumping duty order on imports of American fiber optic products.

Tariffs Against China and Hong Kong Increase to 20% on March 4, 2025

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