On December 18, 2025, the Department of Commerce’s International Trade Administration (ITA) issued a notice that the United States was implementing certain tariff-related elements of the Framework for a United States-Switzerland-Liechtenstein Agreement on Fair, Balanced, and Reciprocal Trade. The framework for this agreement was announced in mid-November 2025 and covered various areas of negotiations addressing trade between the countries, including tariff and non-tariff trade barriers. See Thompson Hine Update of November 17, 2025, for additional details on the framework agreement.
Pursuant to the ITA notice, the Harmonized Tariff Schedule of the United States (HTSUS) has been amended to implement the elements of the framework agreement applying to tariffs. For Switzerland and Liechtenstein, the United States will apply the higher of either the U.S. most-favored-nation tariff rate or a tariff rate of 15%, consisting of the most-favored-nation tariff and a reciprocal tariff. The United States will also exempt from the reciprocal tariffs certain articles that are products of Switzerland or Liechtenstein, including certain agricultural goods, unavailable natural resources, aircraft and aircraft parts, and generic pharmaceuticals and their ingredients and chemical precursors. Annex I to the ITA notice provides a list of the HTSUS subheadings that are exempt from the reciprocal tariffs.
These modified tariffs will be applied retroactively to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EST on November 14, 2025. Any refunds of duties already collected will be processed pursuant to the applicable law and the standard procedures of Customs and Border Protection (CBP).
The ITA notes that these modified rates are subject to the parties successfully negotiating a full Agreement on Fair, Balanced and Reciprocal Trade by March 31, 2026. If that agreement is not finalized, these modified tariff rates will be reviewed and reconsidered, as appropriate.