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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 September 16, 2025, the Department of Commerce&rsquo;s International Trade Administration (ITA) released a Federal Register <a href="https://public-inspection.federalregister.gov/2025-17908.pdf">notice</a> announcing changes to the Harmonized Tariff Schedule of the United States (HTSUS) as to general tariffs on imports of Japanese goods in order to implement the United States-Japan Agreement (see <a href="https://www.govinfo.gov/content/pkg/FR-2025-09-09/pdf/2025-17389.pdf">Executive Order 14345</a>).&nbsp; Under the original framework agreement announced in July 2025, the United States would apply a baseline 25% tariff on nearly all imports from Japan entering the United States, including automobiles and auto parts, with separate sector-specific tariff treatment for steel and aluminum, copper, certain aerospace products, generic pharmaceuticals, generic pharmaceutical ingredients, and unavailable natural resources. The Agreement is intended to &ldquo;reduce the U.S. trade deficit, boost the economy of the United States, and address the consequences of the U.S. trade deficit,&rdquo; but initially there was confusion as to how specific tariffs may be applied under the Agreement and President Donald Trump later announced that most tariffs on Japan would be reduced to 15% due to Japan&rsquo;s commitment to invest in the United States.
With the ITA&rsquo;s announcement, the appropriate sections of the HTSUS are amended to reflect any additional ad valorem rate of duty applicable to imported Japanese products.&nbsp; The annex to the ITA notice provides specific and important details that must be closely reviewed.&nbsp; In summary, the notice announces several new Chapter 99 HTSUS subheadings:
<ul class="wp-block-list">
<li>New headings 9903.94.40, 9903.94.41, 9903.94.42 and 9903.94.43 are inserted to address the importation of passenger vehicles and light trucks that are the product of Japan.</li>
<li>Heading 9903.96.02 reflect changes to the importation of articles of civil aircraft (all aircraft other than military aircraft and unmanned aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components of Japan.</li>
<li>New headings 9903.02.72 and 9903.02.73 are inserted to reflect that certain goods from Japan will be imported with: (i) a flat 15% reciprocal tariff plus any &ldquo;Most-Favored Nation&rdquo; (MFN) tariff under subheading 9903.02.73; and (ii) goods with a MFN rate of higher than 15% will only pay the MFN rate under subheading 9903.02.72.</li>
</ul>

Trump Administration Announces Changes to Japan Tariffs

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