US Tariff Toolkit

Q: When are the tariffs coming into effect?

A: Tariff timeline:

12th March 2025: – 25% import duties on UK and global steel, aluminium and derivative products entering the US. Applies to wide range of products from furniture, construction, tableware, nuts, screws.

2nd April 2025: reciprocal tariffs announced

3rd April 2025: 25% additional import duties on UK and global automotive vehicles entering the US. This is on top of previous duties of 2.5% making total duties on new cars 27.5%

5th April 2025: 10%  import duties on affected products took effect – Global Baseline rate)

9th April 2025: US reciprocal tariffs on 50 countries above 10% global baseline rate came into effect. Additional 50% duties applied to China.

10th April 2025: Reciprocal additional tariff of 84% on goods of Chinese origin announced.

10th April 2025: Reciprocal additional tariff of 125% on goods of Chinese origin announced (to replace earlier 84%)

10th April 2025: Country specific rates above the global baseline rate of 10%, that became effective on the 9th April are suspended excluding China.

Future dates (expected):

15th April 2025:  EU first set of retaliatory tariffs take effect.

17th April 2025: Decision from US trade Representative Office on shipping landing charges. Potentially charges of $1.5m per landing for shipping lines at US ports which have China made boats in their fleets or on order. We are hosting a session with Kuehne and Nagel to discuss these issues on <insert info> 

3rd May 2025: 25% duties to apply to automotive parts imported for use in US-made vehicles (estimated $460bn of cars and car parts covered by new duties) – engines, lithium batteries, tyres, shock absorbers, computers etc.

22nd November 2025: deadline for report of copper tariffs to go to president.

Q: What is the new tariff applied to?

A: The new 10% tariff is applied to the whole range of commodity codes, except steel, aluminium and derivative products thereof, and automotive vehicles and parts which are subject to sectoral tariffs.

Q: Is anything exempt from the new tariff rate?

A: Yes. Currently semiconductors, lumber, copper, energy, critical minerals are exempt from the new tariffs. However, we are expecting sectoral tariffs to be applied in due course. (more information to follow when available).

Copper is also exempt while there is an ongoing report being created into copper markets. This report is expected on the 22 November 2025, and following this report we expect to see tariffs applied.

Steel & Aluminium are exempt from the 10% as they have their own tariff.

The aluminium quota has been removed.

Q: Will there be further changes?

A: Yes, there is ongoing analysis on tariff differentials per country trading with the US. Additional duties are expected from the 9 April 2025. (more information to follow when available).

The tariffs imposed on the 2 April 2025 are also subject to change. We will keep members informed of any changes.

Q: Are these tariffs cumulative or ‘stacked’?

A: The UK is not subject to tariff stacking. Products will either be subject to the 10% tariff or a sectoral tariff, not both. Please be aware that China is subject to cumulative tariffs or ‘stacking’ for goods of Chinese origin. This means that the 125% announced will be added on top of the pre applied 20%. 145% is the tariff wall to Chinese goods. (125% introduced on 10th April).

Q: Where can I find information on commodity codes and their associated tariffs?

A: Following the announcements on the 2 April 2025 the executive order will be being translated into a legal text which will be available on the federal register. It is important this is referred to. (To be shared when this becomes available).

Q: Does the de minimis rule still apply?

A: Yes, the de minimis rule still applies for UK shipments. However, the de minimis rule has been shut down for China which means lower value parcels are now subject to duties regardless of their value.

Q: How can I support my customers in the USA prove that the goods they are receiving from my company are of UK origin and only subject to the 10% tariff.

A: As far as we are aware the U.S. Customs and Border Protection (CBP) agency does not recognise Certificates of Origin issued by UK Chambers as proof of origin for goods entering the USA. Chambers are able to issues a UK Certificate of Origin, along with an added statement, even with this added statement we do not expect CBP to accept UK Certificates of Origin as proof of origin, but it may help.

However, the origin of the goods must be determined using the non-preferential rules of origin published by U.S. Customs and Border Protection (CBP) agency found here.

For substantial transformation please see the examples provided here by the CBP.

NEW – Q: Which tariff will be applied to goods being removed from customs warehousing or goods in transit after announcements have been made?

A: Customs Warehouse- Good being withdrawn from customs warehousing to enter into free circulation will be subject to the tariffs in effect at the time of their withdrawal.

Goods in transit: Goods ‘on the water’ will be subject to the tariff in effect at the time of them leaving their export country. Additional information will be requested from US Customs to confirm the date of shipment.

NEW – Q: My goods are mixed origin, or comprise of imported components assembled in the UK how will their origin be identified by US Customs? How do I know if they have undergone substantial transformation?

A: US Customs and Border protection (CBP) will apply the non-preferential rules of origin to determine the correct country of origin and, in turn, the applicable tariff rate.

To qualify as goods being of UK origin the product must satisfy the substantial transformation test. This test has been developed through CBP rulings and US court decisions and determines whether the processing or assembly in the UK results in a new and different article of commerce – with a distinct name, character, or use – compared to the original imported materials and components.

Substantial transformation typically required that the manufacturing process adds significant value and results in a fundamental change to the products form, function or essential character. Simple packaging, dilution or minor assembly operations do not qualify as substantial transformation.

Assembly can amount to substantial transformation, depending on the nature and complexity of the process. A key CBP decision from 2016 (HQ H287548) clarified this multi-factor approach, emphasising that no single factor is determinative but rather the totality of circumstances must support a finding of substantial transformation.

1. Review contracts with suppliers and customers in the USA. It maybe a good time to review your contracts and in particular which incoterms you are trading under. Understanding your responsibilities in relation to your incoterms on sales contracts will help you understand the potential impacts on your business. NECC can provide support and training, on understanding incoterms and advice relating to responsibilities.

2. Check product classifications. Having correctly classified products ensures that your goods are subject to the correct tariffs. Not understanding or assuming they are correct is not a defence against tariffs. NECC can help by providing audits and bespoke consultancy on tariff classification.

3. Diversify your trade portfolio. If the new tariffs create a barrier to trade for your business, you could consider other markets. Take advantage of free trade agreements and the UK’s participation in the CPTPP which offers 99% tariff free trade to 11 countries, with two further countries still to ratify. NECC has access to the BCC’s global network of 75 chambers and would be happy to facilitate introductions to international members.

4. If you or a supplier trading with the USA is in financial distress or require access to working capital, reach out to NECC who will facilitate introductions to UK Export Finance who will be able to discuss potential lines of credit with you. BCC is also encouraging the British Business Bank to be ready with new support options.

5. Understand your processes and procedures. Being aware of your processes and procedures is particularly important if you intend to claim UK origin on your goods to subject them to the lower tariff. Ensuring adequate processing has taken place to goods imported to the UK to justify the classification is essential. NECC can help with audits and processing reviews to ensure correct origin is being claimed. We also provide UK certificates of origin for goods should your customer request one.