Tariff Resources Are Now Available

March 4, 2025 by 1 Comment

New tariffs are active and anyone engaged in importing goods needs to be aware of the new tariffs and how they may affect your business. This can be difficult because if you pull up the HTSUS today, it is not yet updated with these tariffs. We’ve summarized the upcoming tariffs imposing duties on goods from Canada, China (including Hong Kong) and Mexico.

The new tariffs went into effect on March 4 (today) at 12:01 am. They amount to a 25% tariff on products from Mexico or Canada, and a 20% tariff on products of China. The 20% tariff on Chinese products is a 10% increase from the tariff imposed a month ago, and is imposed in addition to the pre-existing 25% tariff on certain products (including most aircraft parts) that was imposed during the first Trump Administration (e.g. the additional China tariffs applied to most aircraft parts will be 45%).

TariffProductsDuty
9903.01.24Articles that are the product of
China and/or Hong Kong		20%
9903.01.01Articles that are the product of Mexico25%
9903.01.10Articles that are the products of Canada25%

There are some exceptions, but their applicability to the aviation industry will be tenuous. For Canada and Mexico, the exceptions include:

  • donations of articles intended to be used to relieve human suffering, such as food, clothing, and medicine
  • informational materials (like service bulletins)

The additional duties imposed by these tariffs generally will not apply if you are importing goods under a provision of chapter 98 of the HTSUS, except that some of the provisions most likely to be used by our community ARE subject to duty under the new tariffs. In particular goods entered under subheadings 9802.00.40, 9802.00.50, 9802.00.60, and 9802.00.80 are subject to the new tariffs.

The first three subheadings apply to goods sent abroad for repair or processing and then returned to the United States. The importer will need to pay a duty on the value of the repairs. For subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duties apply to the value of repairs, alterations, or processing performed in Canada, China (including Hong Kong), and Mexico. Note that subheading 9802.00.40 is for warranty repairs – the rules specify that the advancement in value will be subject to tariff even though the warranty repairs might be performed for free. Subheading 9802.00.60 is for processing of metal goods that are made in the U.S., exported for processing (e.g. a coating or plating or any other process), and then returned to the U.S. for further processing (the return is the import subject to a duty). In each case, the value of the repair or processing will be subject to the additional tariffs imposed on Canada, China and Mexico.

9802.00.80 is used when someone produces parts in the United States and then they are assembled abroad before being returned to the U.S. The dutiable value of the returned article is based on the value of the assembly minus the value of the individual parts from the U.S. This dutiable value will still be subject to the additional tariffs imposed on Canada, China and Mexico.

If you are importing aircraft parts from China, then check to see whether the additional 25% duty on certain products of China applies – it is under tariff code 9903.88.01.

You can click below to find the DRAFT Federal Register notices. These tariffs are expected to be published in the Federal Register on Thursday the 6th, but copies are currently available for public inspection:

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New China Tariffs to be Published

February 10, 2025 by Leave a comment

The new tariff on goods from China is being published on Wednesday, February 12, 2025. The way that they are drafted my impose a greater-than-expected customs duty on some products from China.

When you report tariff codes, you will report the 10-digit code that applies to the goods being imported, as well as the chapter 99 code that describes the additional tariff.

The new tariff code that applies to aircraft parts is 9903.01.20. The duty associated with this code is “The duty provided in the applicable subheading + 10%.” This is a fairly normal nomenclature for a category 99 tariff – it means you take the normal duty associated with the main subheading and add 10%; but it typically assumes that there is only one chapter 99 tariff that applies to your import.

For example, aircraft parts under heading 8807 are imported for zero duty, so the new duty when importing from China is zero + 10% or 10%. Steel lock washers imported under heading 7318 are subject to 5.8% duty, so if steel lock washers were imported from China the new duty would be 5.8% + 10% or a total of 15.8%.

This looks simple enough, but the problem is that the first Trump administration already imposed a 25% tariff on certain goods from China (9903.88.01) using very similar language. That earlier tariff applied a duty equal to “The duty provided in the applicable subheading + 25%.” Following the language of this provision means that you add the duty from the applicable subheading tariff to the additional duty for this tariff to get the final duty value. For heading 8807, and other classifications that have a zero duty rate, this means that the net duty is 25%. This duty must be paid in addition to the 10% duty described in the prior paragraph (net 35% duty).

The scope of the original 25% duty is limited to a (long) list of HTSUS headings, so make sure your import is actually covered by that list if you are considering applying this tariff code (many aircraft parts are covered).

If you examine a product with a non-zero duty under the directly-applicable tariff codes, you run into an interesting problem. You are paying double-duty! Look at the steel lock washers imported under heading 7318. They are subject to 5.8% duty, so if steel lock washers were imported from China the 9903.88.01 duty would be 5.8% + 25% or a total of 30.8%. The sum of the two duties (9903.01.20 and 9903.88.01) would be 46.6% because both of then incorporate the base duty that applies directly to the product.

I’m not sure that was the intended result. I suspect it was meant to be a total additional tariff of 35% plus the base tariff for the subheading that applies to the goods. But the way that the two tariffs are written you end up paying the duty associated with the product’s applicable subheading twice. It remains to be seen whether this will be corrected, or if the double-base-duty will be enforced.

Either way you will need to declare both tariffs (9903.01.20 and 9903.88.01) if you are importing affected goods from China. Despite the delayed publication in the Federal Register, the new China tariff applies to all goods imported on or after February 5 (last week).

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