Guidance Announced on 90-Day Tariff Suspension

Late last night, CBP issued updated guidance on the implementation of the President’s tariff pause announced yesterday at 1:38pm. This guidance suspends all country-specific reciprocal tariffs for a 90-day period, reverting instead to a universal 10% ad valorem duty rate for all countries. Although this policy shift is now in effect, an Executive Order formalizing the suspension has not yet been issued. In sum, the CSMS message attached here addresses the following key points:

• Duty Rate Confirmation: The guidance confirms that the new universal additional ad valorem duty rate is 10% across all applicable countries.
• Suspension of Country-Specific Rates: The country-specific duty rates that became effective at 12:01 AM EDT on April 9, 2025, are now suspended. While the President’s public announcement came more than 13 hours after the rates took effect, the suspension appears to be retroactive, meaning there is no gap period for goods that entered during that timeframe. This is in contrast to the March implementation involving Mexican goods, where a gap between the effective date and suspension date resulted in a short window where higher duties were applied.
• Goods in Transit: CBP’s updated guidance maintains the prior “goods on the water” exception, as outlined in CSMS 64680374. Specifically, goods in transit on the final mode of transportation before April 5, 2025, and entered for consumption or withdrawn from warehouse by May 27, 2025, will not be subject to the 10% duty.
• Canada and Mexico Exceptions: Imports from Canada and Mexico remain subject to existing Executive Orders related to the border and fentanyl crises. However, goods that are USMCA-compliant and include the necessary documentation will continue to be exempt from tariffs under the current rules.

In response to Trump’s tariff pause, the EU has now announced a 90-day suspension on retaliatory tariffs, which were originally set to begin next Tuesday. European Commission President Ursula von der Leyen was quoted on X saying, "We want to give negotiations a chance…While finalising the adoption of the EU countermeasures that saw strong support from our Member States, we will put them on hold for 90 days."

This marks a positive step in the tariff rollercoaster, but we will continue to keep tabs on the situation and provide updates as they become available.