MEMO: IEEPA Reciprocal Tariffs

Memo from Pegasus Shipping Inc. CHB:

Dear Importers,

We would like to inform you that U.S. Customs and Border Protection (CBP) has recently issued further clarification regarding the departure date used to determine eligibility for the reciprocal tariff exemption under code 9903.01.28.

According to the latest update in CBP’s IEEPA Reciprocal Tariff FAQ (dated May 15), only the departure date of the mother vessel that is directly bound for the United States will be considered for the in-transit exemption.

This means that even if your cargo was loaded at origin prior to April 5, 2025, it may still be subject to reciprocal tariffs if it was transshipped through another port. In such cases, the departure date of the mother vessel—the final leg of transport to the U.S.—will be used to determine eligibility. If that loading and departure of the mother vessel occurred after April 5, the shipment does not qualify for the exemption and is subject to IEEPA reciprocal tariffs, according to CBP.

As a result of this late clarification, some previously filed entries claiming the IEEPA Tariff exemption under 9903.01.28 may now be deemed ineligible. In these instances, CBP may issue bills to the importers for the applicable IEEPA reciprocal tariff for shipments that fall under this scenario.

You can find the full details in the section and link provided below.

If you have any questions, please don’t hesitate to contact us.
https://www.cbp.gov/trade/programs-administration/...

Contact Pegasus Shipping Inc. for additional information:
New York: (212) 768-4646 Los Angeles: (818) 844-3510

Author

H. Yang
LCB