On March 3, 2025, the White House issued an Executive Order to further address the synthetic opioid supply chain in China by increasing the current tariffs on all products of China (and Hong Kong) from 10% to 20%. China immediately responded by announcing that it will implement additional tariffs of up to 15% on key U.S. agricultural products.

Implementation of Tariffs

In order to implement the additional tariffs, on March 3, 2025, U.S. Customs and Border Protection (CBP) has issued draft Federal Register notice (to be published March 6, 2025), Implementation of Additional Duties on Products of the People’s Republic of China Pursuant to the President’s Executive Order 14195, Imposing Duties to Address the Synthetic Opioid Supply Chain in the People’s Republic of China. The same day, CBP published a message via the Cargo Systems Messaging Service (CSMS) providing further clarifications, including the following:

Effective Dates & Rates:

  • From February 4, 2025, to March 3, 2025, goods from China and Hong Kong are subject to an additional 10% duty under HTSUS classification 9903.01.20.
  • Starting on March 4, 2025, the additional duty rate increases to 20% under HTSUS classification 9903.01.24.

These duties apply in addition to all other applicable duties, taxes, fees, exactions and charges. CBP further notes that products of China that are eligible for temporary duty exemptions or reductions will be subject to the additional 20% ad valorem rate of duty.

Exclusions: Certain products are excluded from these additional duties, including donations for human suffering relief, informational materials, and goods in transit before February 1, 2025.

Chapter 98: Goods entered under HTSUS Chapter 98 provisions are generally exempt from these additional duties, except for specific subheadings related to repairs, alterations, or processing performed in China and Hong Kong.

FTZs: Products from China and Hong Kong admitted into U.S. foreign trade zones (FTZs) must be classified under “privileged foreign status” and will be subject to the applicable duties upon entry for consumption.

Drawback: No drawback is available for these additional duties.

De Minimis: The Section 321 de minimis exemption currently remains available for eligible articles.

For prior updates on these recent China tariffs, see Thompson Hine updates of February 5, 2025 and February 3, 2025.

China’s Retaliation

In reaction to the new tariffs imposed by the United States, China announced on March 4, 2025 that it will implement additional tariffs of up to 15% on imports of key U.S. agricultural products, including chicken, wheat, corn, cotton, soybeans, sorghum, pork, beef, aquatic products, fruits, vegetables and dairy products. The tariffs will take effect on March 10, 2025. Goods already in transit will be exempt until April 12, 2025. China also introduced other measures targeting the United States, which include: (1) halting lumber imports from the United States; (2) suspending permits of three U.S. companies for exporting soybeans to China; (3) expanding export controls on certain items in an effort to target a number of U.S. defense contractors, and (4) initiating a circumvention investigation on the existing antidumping duty order on imports of American fiber optic products.

Photo of David M. Schwartz David M. Schwartz

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping…

David is the leader of Thompson Hine’s International Trade practice group and a member of the firm’s International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

Photo of Dan Ujczo Dan Ujczo

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as…

Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as Buy America/Buy American, and anti-dumping/countervailing duty issues. He also advises clients on negotiating transportation agreements, managing trusted trader and related security programs, and addressing issues at ports-of-entry.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.

Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.