By: Brian Walczyk, Compliance Manager, TradeInsights, LCB, CCS

This is a reminder that the first of two 90-day IEEPA Reciprocal pauses is rapidly approaching its end-date.

• July 9, 2025 (90 FR 15625): End of the 90-day pause on Annex I rate increases for specific countries, except for China. 
• Goods entered for consumption or withdrawn from warehouse for consumption on or after this date will have the original Annex I rates applied (11-50%). This is subject to change based on trade negotiations.

Concept: Entered for consumption is a pairing of the manifest arrival of the cargo at the port of entry, often by the carrier, and the presentation of the entry summary, prepared and submitted often by the broker. The date utilized by US CBP is the last occurring of the two. Therefore, a pre-filed entry will have its consumption date updated once the cargo actually arrives at the port of entry.

Question: How does entered for consumption interact with Immediate Transportation (IT) bonded cargo? Per 19 CFR 141.69(b), the applicable rate of duty will be set on the date in which the IT is issued “cut” for transportation to the port of entry, so long as the entry summary is presented ahead of the actual arrival at the port of entry.

We will continue to provide updates as they are made available ahead of this first 90-day pause end-date.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.