A newly issued executive order has clarified that certain U.S. import tariffs imposed this year will not apply cumulatively to the same goods—reducing the risk of overlapping duties on select categories of imports.
Tariff Application Clarified
Under the revised structure, when imported goods fall under more than one of the listed tariff categories, a priority system will determine which duty applies. Key updates include:
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Imports subject to national security tariffs on automobiles and auto parts will not also face additional tariffs related to other enforcement acts targeting regional partners or materials such as steel and aluminum.
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Imports affected by regional enforcement tariffs will not be subject to separate national security tariffs on steel, aluminum, or related articles.
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Imports subject to steel or aluminum tariffs may still be dually classified under both categories if the conditions for each are independently met.
This clarification applies retroactively to shipments entered on or after March 4, meaning that eligible importers may seek refunds under current U.S. Customs and Border Protection procedures. Any necessary updates to the Harmonized Tariff Schedule will be implemented by May 16 at 12:01 a.m. EDT.
Tariffs Still Cumulative in Other Cases
The order also confirms that for goods subject to one of the tariffs mentioned above in addition to other trade remedies, such as most-favored-nation duties, Section 301 tariffs, or anti-dumping/countervailing duties, all applicable tariffs will still apply.
These changes aim to streamline tariff enforcement while reducing the unintended burden of compounded duties on the same goods. Businesses engaged in cross-border trade are encouraged to review their classifications and determine potential refund eligibility for impacted shipments.
