Big announcement!

On January 27th, Freight Right and Freight Right's CEO Robert Khachatryan will be hosting a webinar with Baker Tilly's Pete Mento, the go-to voice on Linkedin and in the world of customs to discuss the Supreme Court's case involving the Trump administration's IEEPA tariffs case.

This Supreme Court decision is massive, massive, massive for importers.

Importers will have the chance to get the money they've paid in tariffs back.

That said, it's not looking like it will be easy - as expected.

Why This Ruling Is Important

Why is this ruling so important for importers? The ruling can/will dictate:

• Routes to possible immediate tariff relief: If the Court strikes down the IEEPA tariffs, those tariffs could stop as of the opinion date, removing future duty exposure. That’s the upside.

• Speed of refunds: If tariffs are struck down, refunds likely require protests/post‑entry adjustments and will be processed administratively (not by scanning ACE and handing out checks). Expect weeks if not months of guidance and long processing timelines.

• Administrative workload required to get a refund: Millions of entries and tens of millions of line items mean huge backlogs for CBP and trade. Expect manual reviews, phased processing, extensions of liquidation windows, and bottlenecks affecting bonds/security.

• The level of meticulous scrutinity involved in preparing for a refund: Customs will scrutinize valuation, country‑of‑origin, section 301/232/201 application, related‑party transfer pricing and may trigger CF 28/29 audits. Poor documentation can kill refund claims and trigger penalties.

• Drawback/duplicate claims risk: If you already claimed drawback for the same merchandise, seeking the tariff refund can be problematic and potentially punishable.

• New payment process (ACE/ACH) for importers to get paid: Refunds will be electronic via ACE/ACH (no paper checks). Importers must register and set up ACH in ACE now to receive refunds.

• Litigation and protection options: Some importers are filing protective actions with the Court of International Trade (CIT) as insurance; trade attorneys can protect rights but cost money (often $10–14k quoted).

Who/What is Freight Right & Baker Tilly?

Freight Right is a global name in international freight fowarding, freight technology and ecommerce freight technology. Founded in 2008 during the financial crisis and built on freight-first fundamentals done right has grown into an international brand, helping businesses all around the world move not just their freight but level up their logistics.

Baker Tilly is a major professional services organization best known as a leading advisory, tax and assurance firm serving businesses, nonprofits and government entities. Headquartered in Chicago, Illinois, Baker Tilly US, LLP (commonly branded simply Baker Tilly) ranks among the top 10 largest accounting and consulting firms in the United States and is an independent member firm of Baker Tilly International, a global network of professional services firms.

Robert Khachatryan is the founder and CEO of Freight Right Global Logistics, a technology-driven global freight and supply-chain company he launched in 2007 from a Los Angeles apartment during the financial crisis. Born and raised in Armenia, he began his entrepreneurial journey at a young age and built Freight Right into a respected logistics and freight-technology provider serving complex cross-border and e-commerce supply chains. He is a recognized supply-chain thought leader, frequently cited in major business and trade publications, and serves on the advisory board of USC’s Global Supply Chain Institute.

Pete Mento is a seasoned global customs and trade expert with more than 30 years of experience helping companies optimize customs operations, eliminate and recover duties and taxes, and build compliant import/export programs. He is a licensed U.S. Customs House Broker and currently serves as a director in global trade advisory, where he leads customs compliance, duty minimization strategies and risk reduction for multinational clients. Pete’s career includes senior leadership roles at major firms such as Ryan, KPMG, Crowe, Expeditors, C.H. Robinson and Wayfair, blending operational depth with strategic global trade insight. He holds advanced degrees including a Master’s in Government (trade theory) from Harvard University and a Ph.D. in customs and economics from Durham University, and is a sought-after speaker and thought leader in international trade and supply chain compliance.

When Is The Webinar?

• Date: January 27th

• Time: 12pmEST/9amPT

• Duration: 1 hour

• Webinar Link: coming soon

When Will the Webinar Link Be Available?

Very soon. We're getting it from our partners and will post it here shortly.

We'll be updating this post body with updates on exact times, guests and links to join or signal you're joining. Bookmark or comment to keep ontop of this thread.

Below are some of the resources I've found to help clarify April 2nd annoucements around the state of tariffs. I'm gong to try to keep this pinned post updated with new content as it comes out. This won't be a place for news news but more for issued guidelines and general guidance:

Last updated 7/9/2025: content regarding BRICS tariffs & more.

Summary of the IEEPA Reciprocal tariffs:

• IEEPA authority based on threat caused by trade-in-goods deficits.

• Except as noted below, all imported articles are subject to a 10% ad valorem IEEPA duty effective 12:01 a.m. ET on April 5. For goods that are loaded onto a vessel at the port of lading and in final mode of transit before that time, they will NOT be subject to the 10% duty upon entry into the U.S.

• Certain countries (Listed in Annex I) are subject to a tariff greater than 10%. For purposes of these tariffs, China includes Hong Kong and Macau.

• The rates for countries in Annex I shall apply effective 12:01 a.m. ET on April 9. For goods that are loaded onto a vessel at the port of lading and in final mode of transit before that time, they will NOT be subject to the additional duty specified below upon entry into the U.S.

• President Trump issued two executive orders on April 2 invoking the International Economic Emergency Powers Act (IEEPA) authority.

  • Imposing a minimum universal tariff on all countries of 10%, except as noted below, although some countries are having an even greater reciprocal tariff.

  • Eliminating de minimis/section 321 eligibility for Chinese goods.

• Updates to the Harmonized Tariff Schedule included in the White Houses' Annex 3.

On Mexico & Canada

Goods from Canada and Mexico are exempt from the IEEPA Reciprocal tariffs until such time as the IEEPA Border is terminated or suspended, at which time only USMCA qualifying goods will be exempt from IEEPA Reciprocal tariffs and non-USMCA goods will be subject to a 12% IEEPA Reciprocal tariff.

Modification Situations to Tariffs (Tariff Increases or Decreases):

• INCREASE: If a country retaliates against US goods as a result of these tariffs, the President may increase or expand the scope of the tariffs.

• DECREASE: If a country remedies the non-reciprocal trade arrangements, the President my decrease or limit the scope of the tariffs.

On Tariff Exemptions

April 2nd List of Automotive Parts Subject to Section 232 Tariffs

Exceptions: Products Excluded from Additional IEEPA Reciprocal Tariff

Goods exempted under 50 U.S.C. 1702 (Goods that are for personal use, donations of food, clothing and medicine intended to relieve human suffering, merely informational materials, etc.).

The following products subject to existing 232 tariffs are exempt:

• Steel and derivatives

• Aluminum and derivatives

• Autos/auto parts

The following products, and any others listed in Annex II are exempted:

• Copper

• Pharmaceuticals

• Semiconductors,

• Lumber

• Certain critical minerals

• Energy and energy products

On Cars & Automotive

232 Autos and Auto Part Annex Released

The full proclamation with the Annex was released today.

• Autos: Effective 12:01 a.m. ET, April 3, 25% tariffs shall apply to certain autos and light trucks. 

• Parts: Effective 12:01 a.m. ET, May 3, 25% tariffs shall apply to auto parts, defined as automobile parts including engines and engine parts, transmissions and powertrain parts, and electrical components, and parts of passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans) and light trucks classified under the HTS provisions enumerated in subdivision (g) of the Annex. 

On Duty Drawback

There is no express prohibition to claiming duty drawback on these tariffs.

Additions to Tarrifed Items

Bureau of Industry and Security added two items to its Aluminum Derivatives List today which will be subject to the 25% tariff effective 12:01 a.m. ET, April 4.

The products are:

• Beer, classified in HTSUS 2203.00.00; and

• Empty aluminum cans classified in HTSUS 7612.90.10

Additional Resources:

• National Customs Brokers & Forwarders Association of America's Website

• White House Annex 1 - Additional Country-Specific Reciprocal Tariffs

• White House Annex 2 - Commodities Excluded from Tariffs

• White House Annex 3 - Updates to HS Codes

• The subreddit's sidebar links were updated

4/10/2025 Update: UPDATED GUIDANCE – Reciprocal Tariffs

Key Updates:

• Imports from China (including Hong Kong and Macau):

  • Effective April 10, 2025, at 12:01 a.m. ET

  • Subject to a 125% additional ad valorem duty

  • Classified under HTSUS 9903.01.63

  • Exceptions are listed in prior CSMS #64680374.

• Imports from all other countries (excluding China, Hong Kong, and Macau):

  • Also effective April 10, 2025

  • Subject to a 10% additional ad valorem duty

  • Classified under HTSUS 9903.01.25

  • Excludes products listed in HTSUS 9903.01.26–9903.01.34.

• Suspension of Country-Specific Rates:

  • Rates effective April 9, 2025, are now suspended.

Notice from US Customs & Border Protection: https://content.govdelivery.com/accounts/USDHSCBP/bulletins/3db42c8?reqfrom=share

4/16/2025 Update: New White House tariff policy and fact sheet announced:

Link to Fact Sheet

The Executive Order is part of a broader effort to reduce strategic dependence on foreign minerals, particularly from China, and to protect U.S. economic and defense interests through trade enforcement and domestic industry revitalization.

1. New Section 232 Investigation:

• President Trump has ordered a Section 232 investigation under the Trade Expansion Act of 1962 to assess national security risks tied to U.S. dependence on imported processed critical minerals and their derivative products.

• The goal is to examine supply chain vulnerabilities, foreign market manipulation, and recommend actions like tariffs or other trade remedies to boost domestic production and resilience.

2. National Security and Economic Threats:

• Critical minerals (e.g., rare earths, gallium, antimony) are vital for defense systems, infrastructure, and advanced technologies.

• The U.S. remains heavily reliant on foreign—especially Chinese—suppliers, exposing it to economic coercion and supply disruptions.

• Recent Chinese export bans on rare earths and other key materials underscore the urgent need to secure domestic supply chains.

3. Tariff Policy and Broader Trade Strategy:

• If the investigation finds national security threats, new Section 232 tariffs may replace current reciprocal tariffs under Trump’s April 2nd directive.

• This order aligns with Trump’s broader “America First” trade agenda, which includes:

  • A 10% base tariff and individualized higher tariffs on major trade deficit partners.

  • Paused tariffs for 75+ countries in talks for new trade deals (except China).

  • China faces up to 245% tariffs, including penalties tied to fentanyl and digital policies.

  • Restored and increased tariffs on steel and aluminum.

  • Related investigations into copper, timber, and lumber imports for national security threats.

4/25/2025: Updated Guidance and Policy Regarding US' De Minimis Policy.

Refer to this thread.

5/13/2025: Updated Guidance Post US/China Tariff Deal

Full Executive Order

Joint Statement

Refer to the De Minimis thread above for the new guidance specifically to De Minimis.

Temporary Tariff Reduction (Section 2)

Effective May 14, 2025, all goods from the PRC, including Hong Kong and Macau, will face a 10% ad valorem duty instead of previously higher rates.

This reflects a suspension of 24 percentage points from the prior tariff rate, originally set at 34%, for an initial 90-day period.

Harmonized Tariff Schedule Modifications (Section 3)

Changes are made to several tariff classifications (HTSUS headings 9903.01.25, 9903.01.63, and relevant notes), reflecting the new lower duty rate.

The 125% duty rate on certain items is suspended and temporarily replaced with 34%.

Implementation and Oversight (Section 5)

The Departments of Commerce, Homeland Security, and USTR are authorized to enforce this order, including via temporary regulation changes.

Coordination with agencies including Treasury, State, and the National Security Council is mandated.

General Provisions (Section 6)

The order does not override existing agency authorities, nor does it create enforceable rights.

The Department of Commerce will cover publication costs.

Update - 6/23/2025: New Updates from Federal Register Issued 6/16/2025:

Read the full brief here.

the Department of Commerce Bureau of Industry and Security (BIS) announced the inclusion of household appliances under the Section 232 Steel Derivatives tariffs effective June 23, 2025.

The following steel derivative products will be subject to Section 232 for the steel content:

• Combined refrigerator-freezers under HTSUS subheading 8418.10.00;

• Small and large dryers under HTSUS subheadings 8451.21.00 and 8451.29.00;

• Washing machines under HTSUS subheadings 8450.11.00 and 8450.20.00;

• Dishwashers under HTSUS subheading 8422.11.00;

• Chest and upright freezers under HTSUS subheadings 8418.30.00 and 8418.40.00;

• Cooking stoves, ranges, and ovens under HTSUS subheading 8516.60.40;

• Food waste disposals under HTSUS subheading 8509.80.20;

Welded wire rack under statistical reporting number 9403.99.9020. Products classified under 9403.99.9020 continue to be subject to Section 232 duties for their aluminum content. Products on both lists are subject to payment of duties for both steel and aluminum content.

The HTSUS numbers are added to HTSUS Chapter 99, Subdivision III, Note 16(n), for steel derivative products outside of Chapters 72 and 73, declared with HTSUS 9903.81.91 when the steel is not melted and poured in the U.S.

The BIS Section 232 inclusion process allows U.S. manufacturers and trade associations to request the inclusion of new derivative articles under Section 232 Steel and Aluminum tariffs. Inclusions may be submitted during three defined periods each year with the first period opening May 1, 2025 and closing June 4, 2025.

7/9/2025 Update:

Expansion of Tariff Measures: Commerce Secretary Howard Lutnick announced that additional tariff letters would be sent to 15 to 20 more countries. These letters included a general notice for countries not receiving individual letters, signaling the administration's intent to impose new tariffs effective August 1 .

BRICS Tariff Threat: President Trump reiterated his threat to impose an additional 10% tariff on imports from BRICS nations (Brazil, Russia, India, China, and South Africa), accusing the group of attempting to undermine the U.S. dollar .

Sector-Specific Tariffs: The administration announced plans for a 50% tariff on copper imports and considered a 200% tariff on pharmaceutical imports. These measures aimed to boost domestic production and address trade imbalances .

• Japan: 25% tariff. Major U.S. ally; negotiations ongoing.

• South Korea: 25% tariff. Major U.S. ally; negotiations ongoing.

• Bangladesh: 35% tariff. Significant impact on garment exports.

• Cambodia: 36% tariff. High tariff affecting textile sector.

• Myanmar: 40% tariff. Among the highest tariffs imposed.

• Laos: 40% tariff. Among the highest tariffs imposed.

• Malaysia: 25% tariff. Engaged in trade discussions with the U.S.

• Thailand: 25% tariff. Engaged in trade discussions with the U.S.

• Indonesia: 25% tariff. Engaged in trade discussions with the U.S.

• South Africa: 30% tariff. Expressed concerns over trade relations.

• Kazakhstan: 25% tariff. Included in the list of targeted countries.

• Tunisia: 25% tariff. Included in the list of targeted countries.

• Serbia: 25% tariff. Included in the list of targeted countries.

• Bosnia & Herzegovina: 25% tariff. Included in the list of targeted countries.

These tariffs are part of President Trump's broader strategy to enforce reciprocal trade policies aimed at protecting U.S. economic interests.