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

On Monday, September 15, the U.S. & Japan trade deal had certain tariff-related elements published in the Federal Register. This Federal Register Notice was to the trade community on implementation, and shortly followed by a CSMS message.

Retroactive to August 7, goods from Japan with a MFN rate of lower than 15% may be entered with a combined MFN + Reciprocal rate of a total 15% (the inclusive rate, not to exceed 15%). Goods with a MFN of 15% or greater will be entered with a Reciprocal rate of 0%.

Starting September 16 civil aircraft and civil aircraft parts listed in the Annex of the notice will be exempt from Sec 232 steel, aluminum, and copper, as well as reciprocal tariffs.

Further, passenger vehicles, light trucks, and their automotive parts will also have a maximum 15% inclusive (MFN + reciprocal) rate. If the MFN is greater than 15% the reciprocal will be 0%.

• General Goods:
• 9903.02.72; goods with MFN greater than or equal to 15%
• 9903.02.73; goods with MFN less than 15%
• Civil Aircraft:
• 9903.96.02; civil aircraft & parts
• Autos:
• 9903.94.40; passenger vehicles and light trucks with MFN greater than or equal to 15%
• 9903.94.41; passenger vehicles and light trucks with MFN less than 15%
• Auto Parts:
• 9903.94.42; parts of passenger vehicles and light trucks with MFN greater than or equal to 15%
• 9903.94.43; parts of passenger vehicles and light trucks with MFN less than 15%

Regarding the retroactivity the CSMS message states:

“[F]ilers can update their previously filed entries to apply the newly issued HTSUS numbers after they are deployed on September 16, 2025. For products covered by these new HTSUS provisions that are entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern daylight time on August 7, 2025, filers should take action to correct entries as necessary to reflect the modified duty rate applicable under headings 9903.02.72 or 9903.02.73, as soon as possible within 10 days of the cargo’s release from CBP custody and prior to estimated duties being deposited to avoid needing refunds. For unliquidated entries for which estimated duties have already been deposited, importers may request a refund upon liquidation by filing a post summary correction. For liquidated entries, importers may request a refund by filing a protest pursuant to 19 U.S.C. 1514.”

We will continue to monitor this situation and issue updates as needed.

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.