The past few weeks have brought a wave of tariff developments that continue to reshape the global trade landscape. To help you stay informed, we've summarized the latest actions and what they could mean for your business in the market update below.
Section 122 Tariffs
Section 122 tariffs, which had been in effect for 180 days, officially expired on July 24. As a result, the 10% global tariff on most imported goods has been eliminated, providing cost relief for many importers, although certain products and trade actions remain subject to separate tariff programs.
Section 301 Tariffs – Forced Labor (60 Countries)
Following the expiration of the Section 122 tariffs, the U.S. Trade Representative (USTR) finalized the new global Forced Labor Section 301 tariffs effective July 24. The finalized measures impose additional tariffs of 10% and 12.5% on covered imports. These duties are cumulative and stack on top of other existing tariff programs, including other Section 301 tariffs (such as those in effect on specific products manufactured in China). However, products already subject to Section 232 tariffs, as well as goods that qualify for USMCA preferential treatment, are exempt from this latest tariff action.
Review more information on those tariffs in our previous client alert HERE.
Review the Federal Register notice outlining all details, including exemptions, HERE.
Section 301 Tariffs – Brazil
The USTR also announced a new Section 301 tariff action targeting certain imports from Brazil. Effective July 22, the measure imposes a 25% tariff on products specifically identified in the Federal Register Annex rather than applying broadly to all Brazilian imports. Importers sourcing from Brazil should carefully review the covered product list and applicable exclusions to determine their exposure. Examples of impacted products include furniture, machinery, sugar, and footwear, while notable exclusions include coffee, beef, oranges, aircraft and aerospace components, and certain energy-related products.
These Brazil-specific tariffs are cumulative and stack in addition to other applicable duties. As a result, covered Brazilian products may now be subject to both the new 12.5% Forced Labor Section 301 tariff, effective July 24, and the 25% Brazil-specific Section 301 tariff, significantly increasing the total duty burden on qualifying imports.
Review the Federal Register notice outlining all details, including affected products and exemptions, HERE.
Section 232 Tariffs – Pharmaceuticals
Section 232 tariffs on pharmaceutical products, originally announced in April, began taking effect in July. The initial implementation occurred on July 31 for companies identified in Annex III of the Federal Register notice, with additional tariff actions scheduled to take effect on September 29 for other non-exempt companies.
The default tariff rate for covered pharmaceutical products, including patented drugs and key drug ingredients, is set at 100%. However, several specific agreements and exemptions apply. Companies that submitted qualifying onshoring plans earlier this year and received approval are eligible for a reduced 20% tariff rate, as outlined in Annex II of the Federal Register notice. Additional country-specific rates apply, including 15% for the European Union, Japan, South Korea, Switzerland, and Liechtenstein, and 10% for the United Kingdom.
Certain products, including generic and biosimilar drugs, are exempt from this tariff action. In addition, companies that combine approved onshoring agreements with Most Favored Nation (MFN) pricing provisions may qualify for a 0% tariff rate through January 2029.
Review the Federal Register notice outlining all details, including affected products and exemptions, HERE.
Section 232 Tariffs – Copper
While there has been no change to the tariff rate for copper products subject to Section 232 tariffs, additional country-of-origin reporting requirements are now required at time of entry. Importers must provide the primary country of smelt and country of cast at the time of U.S. Customs entry, along with all other standard entry data elements.
If the smelt and cast information is unavailable, importers may report “Other” (OTH); however, this option may result in a significantly higher tariff rate. This updated requirement aligns copper imports with the existing reporting process already in place for steel and aluminum products, creating a consistent approach across Section 232 metals reporting.
The new smelt and cast reporting requirements apply to copper products classified under HTSUS subheadings 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10. Importers of affected products should work closely with suppliers to ensure accurate origin documentation is available prior to shipment to avoid delays, compliance issues, or unexpected duty costs.
View full operational guidance distributed by US Customs via CSMS message HERE.
The Laufer Group team will continue to monitor these changes and provide updates on any significant developments.
Please contact your local customer service or sales representative for additional information and service options and continue to visit laufer.com for more market Insights.