Good afternoon and welcome. We are inviting you all today to join us for our U.S. Customs Market Update webinar. We appreciate you taking the time out of your schedule to jump online today. We have a lot of content to cover, so we are going to get started here in a moment just after we go over a few housekeeping items. Many of you who have joined us before are pretty familiar with how our webinars go, but just for those of you who may not have been on one of these events in the past, a quick introduction of myself: my name is Samantha Hurst. I am one of our managers for marketing and bids for the Americas Region of Expeditors, and I, along with a few of my colleagues, will be supporting in the background today.
If you have any questions or issues in terms of how the webinar is functioning, you're welcome to email me directly, and that email address will be on your confirmation email that you received after you registered for this event. As I mentioned, a few housekeeping items here today before I turn it over to our speakers. Some of this has changed up just a little bit. We're going to try things slightly different with our Q&A in an effort to try to help you guys all be able to absorb the content. You know, there's been a lot of changes over the last couple of weeks and even in the last week, so we want to make sure that everyone can really focus on the content.
We will open the Q&A as we get to about 20 minutes left of the webinar today, and we will make sure to let you know when that's occurring. We still encourage you to drop your questions into the Q&A box when we get to that session. Hopefully, many of your questions we will have already answered. That is our goal. We appreciate all of you who submitted questions during the registration process to help us know exactly what kind of details you're looking for. One of the questions that we do always get is, "How do I receive the slides and the recording?" I will let you know, as always, we will have a short feedback survey that will be emailed to you within two hours of today's event wrapping up.
Once you complete that survey, it will take you to a new link on a thank you landing page, and that link will be providing the presentation deck as well as the recording link. Finally, this QR code right here on the bottom right will take you to subscribe to any of our future event invites as well as market updates. I will briefly introduce our speakers. We have with us Ted Henderson, who's our Senior Advisor for Customs, and Brenda Smith, who's our Global Director for Government Outreach. Brenda, I believe you are going to kick us off with a quick disclaimer and our agenda, right?
I am. Thanks, Samantha, and greetings, everyone. Thanks so much for joining us. It has been a week, but we've got lots of good content to provide to you. With that, let's kick it off. The very first thing we want to say is we have done our level best to make sure that we have absorbed all of the details and can give you our best advice and our best interpretation of everything that's coming at us, but we are not lawyers. If you are looking for specific legal advice, please consult a lawyer. Otherwise, our operational teams can give you our best guidance on what we believe the government is requiring and what different countries around the world are looking at.
With that, the agenda for today's call, we're going to split it up, as we often do, into what's actually happened most recently. We're going to focus on the sectoral tariffs, particularly automotive and automotive parts. We're going to spend some time walking through the structure of the reciprocal tariffs that the President announced last week, and we're also going to focus a bit on the changes that are happening in the de minimis environment. We're then going to move on to the global response and particularly focus on the responses from Canada, the European Union, and China. Then we're going to talk a bit about what is on the horizon so that you can be prepared going forward. We're going to look at open investigations, the tariffs resulting from Venezuelan oil exports, and the potential expansion of the 232 scopes.
With that, I'm going to turn it over to Ted Henderson, and he's going to talk about what's happened recently.
All right. Thank you very kindly, Brenda, and once again, for all of us here at Expeditors echoing Samantha's opening comments, definitely appreciate you guys jumping on this discussion today and making time in a probably much more frantic day than it was even two days ago. Thank you again for jumping on with this. Let's start with a quick snapshot of the current U.S. tariff actions that are now in place. If you were with us about a month ago on one of these webinars, we talked about the America First Trade Policy order that was issued by President Trump, basically directing a number of government agencies to go out and do reports on certain key areas that might be pertinent to the government and the trade policy. We are seeing those reports were delivered, and the executive summary has been posted on whitehouse.gov.
We will direct that. We have a link to that at the closing. Beyond that, we have the list of tariff actions that are in place. We have the original IEEPA tariff actions related to fentanyl imports, immigration for China and Hong Kong in place, Canada and Mexico are in place. We have the relatively new sector tariffs, steel and aluminum, so the 12%, and we talked quite a bit about that in our last webinar as well. The new auto and upcoming auto parts tariffs that we'll talk a little bit about today. Of course, the reciprocal tariffs that are also put in place under IEEPA, the International Emergency Economic Powers Act. We will definitely be spending a lot of time on that today.
Real quickly, let's take a look at an update to the Section 232 FAQ that was posted by Customs and Border Protection a couple of weeks ago. It was really, really at that point in our last webinar, we were talking about how to deal with the steel and aluminum tariffs because that was about all of the major things we were trying to figure out at that time. CBP initially gave us some guidance, gave the trade some guidance, but they've updated that guidance. I want to call your attention to this number two bullet point where they've changed. CBP have changed their position on how to deal with aluminum when you do not know the country of smelt or the country of cast.
Originally, CBP told us that we were to use Russia as the country of origin, which means paying the 200% tariff for Russia aluminum and goods. They, CBP, have now changed their guidance on this. They've changed their position, and they allow the input of any country other than the U.S. The importer can update the declaration once they have the information on country of smelt and/or cast, whatever your situation is. If you are involved in this particular area or challenges with aluminum, please continue to pay attention. Watch for additional guidance on this. We know Customs will be issuing more guidance on how to deal with these areas where we're not sure of a country of melt, pour, cast, smelt, whatever, depending on steel or aluminum.
If you are engaged in importing products that are covered by the steel or aluminum 232 actions, please continue to pay attention. In fact, we're going to talk a little bit about some changes on aluminum derivatives that came up this last week. Let's take a look at recent trade actions that have happened really last week, and then will be coming in the very near future. We will be talking a little bit about the auto tariffs that came on for the 3rd of April. On the 4th of April, I want to call your attention to this. There was an update to the list of products on the Section 232 aluminum tariffs, and aluminum cans were added to that product, as well as beer in aluminum cans that were added.
Customs has now made it clear that beer and glass bottles is not subject to these tariffs. My point on this, again, like I'm saying, you need to pay attention if you are involved in the steel and aluminum derivative, any of these tariffs, quite frankly, because there are opportunities for parties to update the list of goods that are subject to the tariffs. In this case, we saw that aluminum cans were added on the 4th of April and are now covered by these tariffs. Please, again, pay attention to what's going on. Beyond that, we'll certainly talk about the reciprocal tariffs that are effective as of midnight this morning or 0:01 hours. In a little bit, we'll talk about the fact that de minimis is going to be removed, a new order on de minimis on the 2nd of May.
Certainly, auto parts are something that are out there in the future for us to pay attention. We've got some questions still on the 232 applicability for auto parts with U.S. content. We're waiting for the implementation actions on that as well. Speaking of autos, let's dig into this and really get into these sector tariffs on autos. Really, it was effective just less than a week ago, really, that we suddenly started to see the 25% tariff assessed on passenger vehicles and light trucks. There are certain exemptions to that tariff. If you are importing something that does not qualify as a true passenger vehicle or a light truck, but maybe hitting on an HTS number, there are exemptions if your imported goods do not meet the definition of a passenger vehicle or light truck.
There's also an exemption for older passenger vehicles and light trucks, anything that was manufactured 25 years ago or older. We're also going to see some things related to autos and passenger vehicles, light trucks that comply with the USMCA regulations. There is going to be ultimately an opportunity, I guess we'll call it an opportunity, where importers would only pay a 25% duty on the non-U.S. content and 0% on the U.S. content. That's going to be for auto parts and autos. There is some exemption for those if the Commerce Secretary approves that based on U.S. content. This is another one that the devil's in the details. You've got to dig in and take a look.
If you do have vehicles that are in compliance with the USMCA regulations and qualify for USMCA coverage, you really want to pay attention to this, certainly for autos, and then definitely upcoming for auto parts as that comes on. For the auto parts, again, similar concept. When I use auto parts, I'm saying parts for passenger vehicles, light trucks. That will be coming up no later than the 3rd of May. Pay attention for when this will come in. There are certain exemptions for goods that do not meet the criteria of parts for passenger vehicles or light trucks, even though they may be one of the HTS numbers named. This is something that you're going to want to make sure and pay attention to. I can tell you, as your Customs broker, we'll be reaching out for clarification in instances.
Please start working with your broker now, if that's us or whoever it is, to get ahead of that when it's coming in the next couple of weeks. Again, same thing. I talked about the USMCA qualifying goods. Same thing will apply for auto parts. Right now, there's going to be an exemption for USMCA qualifying auto parts until the Commerce Secretary announces that there is a process in place to exempt U.S. content. For now, we believe the exemption will be in place. Again, this isn't coming into effect for a couple more weeks. We have to wait and see an announcement from the Secretary of Commerce to see if there will be a similar concept of exempting U.S. content and an importer paying 25% on non-U.S. content. Again, this is for USMCA qualifying parts and products.
As we've seen across the board with Section 232 activity from this administration, FTZ products have to be admitted under privileged foreign status. Unfortunately, there isn't much benefit for FTZs in this scenario in the sense of avoiding the tariffs. Again, no drawback is available for these tariffs. That's auto in a quick nutshell. Again, we want to spend some time really focusing on reciprocal and the retaliatory actions from other countries. We'll dig into perhaps auto a little bit more. Definitely, as auto parts are coming on, we'll work on that with our next webinar coming up in a couple of weeks. Okay. Reciprocal. Simply stated, this is the big darn deal, especially today. Let's go through a couple of points here that we have up on these slides.
First, we already know there was a 10% universal tariff that was applied to all imports starting on the 5th of April. There were certain exemptions for things that were in transit, a few other things you can see on the right side of the screen. There is some good news, I guess, in the list of exemptions. Effective again, bright and early this morning, we saw the specific rates go into effect for 60-plus countries. We have a list of those countries. We'll talk about that in a second if you haven't seen it. Those specific rates range anywhere from 11% to now 84% with the adjusted rate on China. We'll take a quick look at that.
Basically, the tariffs are there to address under IEEPA, the International Emergency Economic Powers Act, the threat to national security and the economy caused by the large and persistent trade deficit with U.S. goods. That's the statement from the president. That's why these actions were taken. Again, there are lots of exemptions. If you are paying steel and aluminum tariffs, things along that line, auto part tariffs, you would not be subject to the reciprocal tariffs. There are a few things on Canada and Mexico you need to pay attention to. I have seen some discussion in the news this morning about Russia. Russia is already in a column two duty rate status. There is a question as to whether or not there will be some imposition of reciprocal tariffs on Russia outside of that column two activity or if the activity will just remain in that category.
That is something else we're watching as it goes based on, as we've seen, again, reactions from other countries and where things go. The key to remember about this is that these tariff rates certainly may increase for countries that choose to input their own retaliatory tariffs. We saw that example with the increase that went in that was announced yesterday. The China tariff went from 34% to 84%, so an additional 50% was added on to that. For China, with the two IEEPA tariffs that they are now subject to, you're looking at 104% for products from China. Obviously, the expectation is that the tariffs will also be reduced as the president, the administration engages in negotiations and conversations with other countries. Again, this is something you have to watch.
We've seen additional announcements for those of us who were up all night and early this morning paying attention to other countries and the EU and things that are going on. It would not be surprising to see that the U.S. might adjust some tariffs for some of these other countries or trade blocs, however it may set up. You definitely, like everything else, you need to really pay attention to where this is going. One good thing about this is drawback is available. That was specifically laid out that drawback is available for you if you are paying these tariffs and then you're importing goods and exporting them and eligible. That at least is a good part of this as it goes. Regardless of all of this, these tariffs are going to be a staggering financial hit to all importers.
When we looked at the impact to our customers, before the China tariffs were bumped up to 84%, we saw that for our top 100 U.S. importers, the impact would be over $100 million annually in additional duties. That is starting at the lower 100. As you moved your way up to 98 and 63 and whatever, that number kept growing. By the time you got into the top 10, the impact was in the billions annually. I know you guys are figuring this out too. You are not naive to this. I am traveling right now, and I was meeting with a couple of importers yesterday. It does not matter if you are a small, medium, or large importer, these tariffs are meaningful. We absolutely understand that. We do not know how long they will be in place per country.
The president's announced that certain countries have reached out to have negotiations, but we don't know how fast those negotiations will be. The president has also spoken about potentially engaging some law firms here in the U.S. to help maybe speed up the negotiations with certain countries because there are only so many people in the administration. We don't know if that will happen. I know I'm stating the obvious when I say, really, there's more uncertainty than clarity when it comes to these actions. We also know, and again, in our conversations with our customers and many of you on this webinar, we know that the uncertainty makes it impossible to do any strategic planning or initiate really any action to address the impact of the tariffs. As we've said before, we really do try not to speculate or make conjecture about what might happen during these webinars.
We're just trying to put the facts out in front of you. Again, unfortunately, those facts are incredibly and extremely challenging to you. If we are your Customs broker or logistics partner, however we get to work with you, we will do all we can to provide information on the impact of those tariffs and what's coming and the things that are in. Many times, we will offer information about statements that were made by the president in advance of an action. We'll do all we can. We can be a shoulder to cry on. We're facing the same uncertainty as you are as well with all the stresses that your Customs brokers, and us included, are facing as they're trying to clear your goods in an environment that really is quite simply 10x more complex than any of us have ever operated in.
Again, pay attention to what's going on, please. Watch for announcements from us. You can watch news announcements, but really make sure and base any decisions you make not just on something that was stated in the press or even something that was stated by the administration. Look for definitive executive orders issued or announcements coming from the White House, or look for Federal Register notices, guidance from Customs and Border Protection. Make sure if you are starting to make decisions, you're basing it on something that's definitively laid out for a period of time. We can take a look at the global impact of these tariffs. We've seen multiple graphical representations of how the tariffs are hitting countries around the world. We liked this one from Newsweek and decided to share it with you.
However, as of midnight last night, this graphic no longer looks the same. China now should be a very intense red on this graphic. We would not be surprised to see if there are some other color changes, if you will, some deepening in the red tones, if you will, for some of these other areas. Again, pay attention. We'll see what happens through the remainder of the week. Also, as I mentioned here on the next slide, we have a list of the reciprocal tariffs that are hitting countries around the globe. You can review these on your own. I'm not going to go from China to Congo. You can see that China is very much at the top of the class now with these specific IEEPA tariffs related, the reciprocal tariffs.
Again, like I said, keep in mind, and you guys know this, these tariffs are additive. The other tariffs that China is subject to, for example, the IEEPA fentanyl tariffs, those are 20%. That puts China at 104% right now, if you will, for the current lists that are in effect. Take a look at this. You can compare your current sourcing countries, maybe some other places you're thinking about. Also, this list can be dynamic. Watch it as it goes. Brenda talked a little bit about de minimis changes. We know by and large that de minimis imports into the U.S. are a very high volume, approximately about 4 million a day. It is based on this exemption that has existed since the Tariff Act of 1930 that allows for low-value goods to be exempted from traditional customs processes.
It was put there in place so that customs could avoid the expense and inconvenience of trying to deal with low-value goods, assess duties, and all that kind of activity. As this area has grown as a source of trade and it's overwhelming Customs and Border Protection and folks are trying to figure out what to do about it, we've talked about this in the past that de minimis goods sometimes are a gateway for counterfeit material or fentanyl precursor chemicals or whatever else. The administration, this is one of the targeted areas in the America First Trade Policy agenda, is de minimis. The administration is clearly going to, has tried once already to take action in this area.
If you recall, Trump's original order on the China IEEPA tariffs for fentanyl did state that no China or Hong Kong goods could be entered under the de minimis exemption. That ban was in effect for a few days. President Trump issued an amended order, which once again allowed for those goods to come in under the de minimis. If you recall, we mentioned at the time that this was a temporary suspension. We have a new order that will remove de minimis exemption for goods from China and Hong Kong effective the 2nd of March, or 2nd of May, I'm very sorry. 2 May, this will go into effect. The order is a little bit different than the previous one. This one talks about specific tariffs related to mail packages. That tariff got bumped last night as well. It was originally 30%.
It's now up to 90%. And the per item charges and the line item charges you're seeing, those also got bumped as part of the actions the administration took yesterday related to China. We definitely expect we're going to see more information on this topic. We have it planned for our next webinar. As you guys know this, we do these webinars every couple of weeks. We'll be definitely talking about de minimis in the next webinar because we'll be getting very close to the effective date of 2nd of May. Finally, I mentioned earlier that your Customs broker is facing a whole host of new challenges as we work to file accurate declarations. People ask about what does this mean for stacking tariffs and that sort of thing. What does that look like?
We have tried to kind of give you an idea of how things have changed over the last several months. Typically, when your Customs broker was making a declaration on your behalf, there might be one or two lines of information that we had to submit to the government per HTS good area. As you can see, that keeps growing. At this point, we are at a minimum reporting five, six, seven plus lines for goods now as these tariffs continue to stack or certain exemptions have to be reported and on down the line. We want you to understand that we are feeling some pain too, if nothing else. I do not mean to diminish anybody. We are all in this together. Understand that your Customs brokers are facing similar challenges, whether it is Expeditors or whoever else you are working with.
Everyone's trying to do the best they can right now. All I'm going to ask is if we can all kind of give each other some grace in this and try to work together through this situation as we move forward. With that, I'll turn it over to Brenda to start talking about some other fascinating things that have been going on.
Ed, thank you so much. You did a great job giving the overview. One of the other things that we wanted to give you some insights into is the information we've been gathering from our colleagues around the world. There certainly have been huge conversations, vibrations, reverberations, whatever you want to call it, from a lot of countries around the world, with some countries indicating that they would counter the U.S. actions with specific actions of their own and other countries indicating that they were more interested in negotiating a solution. At this point, the administration officials have said that over 70 countries have approached with requests for negotiation. President Trump has already designated the United States Trade Representative Jamieson Greer and the Secretary of Treasury Scott Bessent to lead negotiations with Japan.
They're also likely to address the reciprocal tariffs in discussions with India and the U.K. that are underway. Other countries such as Vietnam, Israel, and Argentina have offered tariff cuts and other incentives to reduce the reciprocal trade level. The Trump administration has indicated that they are looking for more than just lower duty rates. They are actually seeking both the resolution of the non-tariff barriers that are identified in the National Trade Estimate Report, as well as actions that will significantly reduce the trade deficit that's experienced by the U.S. It's not clear whether this administration will wait to see a lower deficit number or will accept the change before lowering the duty rates. In fact, yesterday, U.S.T.R. Greer testified before the Senate Finance Committee and noted that the negotiations with Canada and Mexico over USMCA took over two years.
USTR, as Ted noted, is a fairly small agency. They have fewer than 500 people on staff. While they can certainly draw on other government experts, that's a pretty small team to undertake 70 negotiations at one time. It is going to be a very big lift. We are watching with interest to see what kind of time we're talking about. The other area that we are watching pretty closely within Expeditors is the impact of these reciprocal tariffs and other countries' response impact on transportation. There is a lot of speculation about freight rates already, and we've seen some changes in that just over the last couple of days. The main impact that we're seeing is really the number of cancellations of bookings, sorry, that carriers are receiving.
They're coming in at a very rapid pace as we see our customers putting a pause on shipping into the United States as they try to figure out what to do. Let's do a little bit deeper dive into three of the countries that have been particularly active in coming up with a response. The first one is Canada. They were one of the first countries to implement a retaliation in response to the fentanyl duties that were back in the early days of the Trump administration. They have also felt the heat from the 232 duties on steel, aluminum, autos, and auto parts, though they did get some relief from the USMCA exclusions. I should call them exemptions. Canada is actually taking a fairly deliberative road towards their retaliatory actions and includes a public comment period in most of the proposed measures in their process.
Over the course of the last week, Canada has announced a 25% duty on vehicles imported from the U.S., though they are allowing the exclusion of the Mexican and Canadian content from the value when the surtax is calculated. The other thing to keep an eye on is the election that Canada will be experiencing at the end of April, which may give the government further support for a strong response. The next economy that we're looking at is the European Union. They have been fairly assertive in their response to both the 232 and the IEEPA tariffs, though they must coordinate amongst the 27 member states before they take action. They are a little slower off the mark. Their initial response was based on the actions and the products drafted several years ago after the first round of steel and aluminum duties were announced.
They were ultimately suspended while the negotiations on those two sectors took place. They have revised those actions, and the European officials voted this week to implement tariffs on $28 billion worth of industrial and agricultural goods coming from the United States. Many of these goods are iconic American products or are produced in politically sensitive districts. These duties will be phased in three stages, with most coming on May 16th, just a little over a month from now. We are not done in the European Union. The officials there are working to craft a response to both the automotive 232 tariffs as well as the 20% reciprocal tariff that is levied on them. Finally, the area, as Ted noted, that kept us all up at night last night is the actions taken on China and by China.
That is the big news yesterday and tonight after President Trump increased the reciprocal tariff on China from 34% to 84%. China then issued a further range of actions matching the 84% duty rate on all goods coming from the United States. This expanded not only the duty rate, but also the scope of the impacted goods and matched the United States' approach. These new duties from China are effective tomorrow with all the other conditions and provisions matching those announced last week. In addition, more companies were added to both the Export Control Entity List and the Unreliable Entity List.
Another thing that you might want to take a look at as you're trying to get more insight into China's response is the 51-page white paper that the Chinese government issued, which outlines their perspective on the U.S.-China relationship and may provide all of us with some clues as to the path forward between our two countries. What else should you be watching for? What is on the horizon? Before we get there, I would note that we are going to now open up the ability for you to ask questions. We hope you've gotten a lot of information from the content we've already provided. If you are looking for specific questions, please feel free to go ahead and submit those into the Q&A function, which we should see appear shortly.
Brenda, if I may intercede for a moment, I expect we will get a lot of questions about a Truth Social post from President Trump that just came out that speaks to two things. One, the tariffs to China will be increased to 125%. Two, there will be a 90-day pause on the reciprocal tariffs. It looks like they will revert back to 10%. It's not clear. What I want to tell everyone, please, we are going to have to wait until we see an official announcement, an executive order, or an announcement that will come through whitehouse.gov or additional information beyond that. Please, you can post questions to us, but we're reading the same thing you are right now.
I've told my colleagues we really shouldn't schedule these webinars because every time we do, we get a flurry of activity 12 hours prior and then during the webinar. If I can, just when you do, we're seeing the same thing you are in the sense of the post, but that's all we're seeing is the post. Thank you, Brenda. Sorry.
Ted, that's music to my ears. Hopefully, that'll turn the temperature down a bit. I know that we will all be briefing up and trying to figure out strategy going forward. Let's give you a few more things to think about as if you didn't already have enough. Let's take a look at some of the things that are already on the agenda. We also had news this week around the Venezuelan secondary tariffs, and we'd like to do a little bit of a deeper dive on that. We want to be sure that the semiconductor 301 investigation, as well as the copper investigation and the timber, we should have added that to our list, investigations are all underway. The other area that we want to be sure is on your radar screen are President Trump's comments on the pharmaceutical sector. It is an interesting time.
Clearly, as Ted just indicated with his late-breaking news, a very fluid time. The Venezuelan secondary tariffs are actually an interesting executive order. Again, we really encourage you, as the White House issues their legal documents, they're listed on the presidential actions page in whitehouse.gov. Read those documents. They can be very dry and very legalistic, but that's where the best information comes from. In the Venezuelan executive order, there's a couple of interesting characteristics that I would call out. First of all, this order, which potentially levies new duties on oil exported by Venezuela, leverages both IEEPA as well as Section 301 trade authorities in order to levy duties. It links to an emergency in the foreign policy space, not actually the trade space, which was laid out in two previous executive orders specifically focused on Venezuela.
It's also unique in that it is structured as a secondary tariff to be collected on goods from countries that import oil from Venezuela directly or through a third party. Finally, it is unique because the countries that will be subject to this duty will be indicated, and those decisions will be made by the Secretary of State. Turning off those duties will be made by the Secretary of Commerce. Currently, actually, if we could, I'm seeing the pending trade actions, Samantha. If we could move ahead to the, there we go. Currently, the countries that buy the most oil from Venezuela are China, interestingly, the United States is number two, Europe, and India. While no duties have been announced yet, they are likely in the long run to depend on the administration's diplomatic efforts and the goals related to Venezuela.
Our best advice is that you stay tuned. The next thing that we wanted to walk through with you are the open and recent investigations undertaken during the current Trump administration, the first Trump administration, and the Biden administration. We are seeing a number of actions in which the justification for those actions have been based on investigations that were taken over the last eight or nine years. The president has recommended or has referenced a number of sectors where he believes that the U.S. should have domestic production capacity, saying that it is critical not only to our economic security, but to our national security. That protection for these domestic industries is needed. Specifically, and the list grows every week, specifically steel, aluminum, copper, timber, semiconductor chips, logistics, shipbuilding, and pharmaceuticals.
All but pharmaceuticals have been covered by an investigation either under the 301 procedures or by the 232 procedures. The other area that I'm also watching, because we did have some exemptions under the reciprocal tariff, is the area of critical minerals. You'll notice on the 232 list that there was a completed investigation on vanadium. I don't know about you, but I don't know exactly what vanadium is. However, I do know that critical minerals are a pretty significant concern to this administration and the legislators on Capitol Hill. There's been a lot of conversation on this area, and it will be interesting to see what sort of trade measures are put in place while the United States develops its capacity around critical minerals. The last area that we wanted to focus on is another potential area for action.
We're all pretty familiar at this point with the steel, aluminum, and autos and auto part 232 actions. There is a provision in both executive orders for these sectors that allow for the expansion of the things covered by these 232 duties. Essentially, what the executive order has called for is a mechanism whereby domestic producers of steel and aluminum derivatives, as well as auto parts, where they can submit a request to the government to expand and apply the scope of the 232 action and apply the duties to additional auto parts or derivative products. That is a process that will be managed by the Department of Commerce.
They must make a determination within 60 days of receiving the request and then must issue a notice whereby the scope is expanded to include the specific things called for in the request if it meets the criteria laid out by the Department of Commerce. We are not done yet with steel, aluminum, or autos and auto parts. Again, our advice is to stay tuned. If this is your sector, watch it fairly closely. With that, we still have a bit of time left in our webinar. I'm going to turn it back over to Ted for our key takeaways. Then we're going to attempt to answer a few of your questions live.
All righty. I hope you're enjoying the webinar. As we are trying to put information out as things are breaking, some of the things we said literally 20 minutes ago have changed. We will put more information out and guidance as this goes. Really, we just go back to some of the key things that you might be doing, hopefully you're already doing, that might give you an opportunity to manage the duty value that you're paying to the United States for the tariffs. Make sure, if at all possible, if you have goods that might be subject to the qualification under USMCA or another free trade agreement, I would work very hard on trying to make sure those parts do indeed qualify so you can take advantage of some of the exemptions that are out there.
Last time we talked about first sale, our colleagues from Tradewin talked about that a little bit. That might be a program that works. The things I always go back to after well over three decades in this business, having started out at U.S. Customs and then a compliance manager for a high-tech importer and then being in a broker role, always focus on those trade compliance fundamentals, HTS classification, valuation, country of origin, things like that. This is a prime time where you really need to have a solid understanding because that might save you money. It might get you out of some of the tariffs and things like that if you definitively know your country of origin or you have a good understanding of your HTS. Try to put some effort into that if you have not already.
Definitely pay attention to your bonds that you are maintaining as an importer of record. All of the sureties out there are talking about their concerns about saturation levels that the duties that will be coming from all of these additional tariffs will basically make your bond insufficient. We expect that customs will be putting out bond insufficiency notices this week and next week. If customs evaluates that your bond is not sufficient, they will tell you, and you'll need to adjust. Try to get ahead of it and adjust now. Pay attention to that. If you're not aware of what the periodic monthly statement program is for paying duties to the government, then you work with us, talk to us, or whoever your broker is. You do not have to pay duties on a daily statement.
You can at least get some float by paying on a monthly statement if that works for you. It does not get you out of paying duties, but at least gives you a little bit of float internally. As I have said, it is very challenging with all the uncertainty that is going on. We just got a change minutes ago. It is very hard to do any long-range planning right now. It is virtually impossible. Maybe there are some short-term things you can do. I am on the road this week and met with a couple of importers just yesterday, and they have chosen to suspend imports for a while. They are going to work through their backstock, see how things go over the next month or so, and then maybe try to figure out a strategy on how things continue to develop.
I know this won't work for everyone, but it might be good just to hit the pause button if you can do it. Keep that in mind. Again, just a reminder, this is clearly a marathon. There'll be sprints. Actually, I don't know what it is with sprints and long runs and whatever. I should know this as a former cross-country runner. At any rate, this is a challenging run. Do the best you can to take care of your company and your customers and everywhere as it's going, but find time to take care of yourself. Take a water break, de-stress somehow. Do those kind of important things to take care of yourself because we've got a ways in front of us clearly on this. A couple of things that you might want to read, the additional information we put on the right-hand side.
I mentioned earlier about the executive summary that was published for the America First Trade Policy. We have a link here on it. You can also find it on whitehouse.gov. The other thing you might want to take a look at, and this is a big document, is the National Trade Estimate on Foreign Trade Barriers that was published last week. This gives you a view by country as to what the administration perceives are the specific tariff and non-tariff barriers that are impacting U.S. exporters. This gives you a view of how the administration is looking at other countries and what they're basing their actions on. I think this will influence the negotiations they have with the countries that want to talk to the U.S. about negotiating tariffs as this goes.
Next final thing is the accreditation that we offer you for participating in these webinars. If you're a licensed U.S. Customs broker, this is one of the continuing education credits, one hour that you can use to support your license. Also, if you're in the NCBFA Certified Customs Specialist program, this is also for that. I say this all the time. I'm pretty sure we're going to meet all 20 of your continuing education credits for the licensed broker triennial. We should get that done by this summer as opposed to two and a half years. Stay with us. We'll keep trying to get into this. With that, I will leave it to my colleagues to pose questions that we think we can try to address here besides the ones that you guys are frantically trying to respond to, typing very, very, very, very fast.
We got a lot of questions. Ted, in a minute, I'm going to ask you to do a little bit deeper dive on how exemptions work with respect to the reciprocal tariffs and how the stacking of tariffs actually works. If you can walk us through that in a minute. Before we get there, we have had a number of people ask about what takes precedence in the event of differences between the executive order or the Federal Register notice. I would suggest that that is a question for a good customs lawyer. However, it is, I think, useful to understand how these documents fit together. Typically, the White House develops the executive order, which gives the broad strokes, but also the specific legal references that are used in the development of specific trade action.
The Federal Register does the deeper dive and provides the specific information about the impact of that executive order. Very often, we will see guidance coming out from U.S. Customs and Border Protection about the operational implementation of the Federal Register and the executive order. In some cases, they're moving very fast. There have been known to be differences between those documents. A lot of times, those differences exist as the, sorry, the second or the next document in the chain works to clean up either a mistake or a lack of clarity. It is rare that you will see an executive order reissued because there is a problem. A lot of times, things will be cleaned up in the Federal Register notice. However, that is something for a customs attorney to address.
Our best advice is if you take a specific approach, you interpret one piece of legal documentation over another, document, document, document, that you may get questions after. What you want to be able to show is that you have taken a reasonable approach or a reasonable interpretation, and you have documented how you came to that interpretation and applied it. Ted, any further thoughts on that, or can we move to the stacking and exemptions question?
Go for it. I'm good. We'll let it rip.
Okay. All right. We've had a lot of questions from people about how items that are subject to 232 are exempt from the reciprocal tariffs. We've also had a lot of questions around how all of the tariffs that we see stack. I wonder if you could just either use an example or perhaps restating how those two things, the exemptions, fit together to produce a layered tariff at the end of the day.
All right. I will do my best. Thank you. There are a couple of things here. The reciprocal tariffs, when the announcement were issued, and Brenda's talked about the various components just now of there's the announcement from the president, and then the follow-on announcements that we see in the Federal Register notices, the annexes that are published, et cetera. The reciprocal tariffs were unusually, I think, explicit in the exemptions that were offered, if you will, in the sense that the idea that this was a typically when we're seeing tariffs being issued by the administration, announced by the administration, they're additive. One piles on top of the other.
As I've talked about the initial China IEEPA tariff related to the fentanyl, one of the first actions taken by the president, the administration, that started out as 10%, it became 20%.
That tariff adds on typically to anything and everything. The Most Favored Nation's basic rate that might apply to the goods, whether it's at zero or it might be 12% or 83% or whatever, that tariff then gets stacked with the IEEPA tariff for fentanyl. We see the reciprocal tariffs, which right now are 84%, but appear to be going up to 125%. That one gets stacked on top because there's no exemption listed for the fentanyl IEEPA tariffs. There's no comment about that. There is comment for Canada and Mexico IEEPA tariffs. This is the joy of this, is that you, as I've said, the classic phrase, the devil's in the details, you have to pick through and say, "All right. I know I've got to add the two IEEPA tariffs if my goods are coming from China." That's a given.
I have the first IEEPA tariff of 20%, the second one right now at 84%. But I was.
Hey, Ted.
Yes?
Hey, Ted. Sorry to interrupt, but I'm going to ask Samantha if she'll pull up the complexity grows slide.
Thank you. Thank you. That would be perfect. I should have thought of that as well. There we go. You're there. Perfect. You see what happens here. By the same token, previous to the implementation of the reciprocal tariffs, you might have indeed been subject to the China first IEEPA tariff and steel and aluminum. Now with the reciprocal tariffs, you're not subject to the reciprocal steel and aluminum. If we do look at how this lines up, and I do want to be clear, CBP gives specific guidance how we are to report these numbers and what sort of order and how we stack them up. That's when we talk about stacking, any of the tariffs that are additive that do not have any language about exemptions, they just keep piling one on top of the other.
However, if there are exemptions, we typically have to report that as well. That becomes a line item as well. Even though there is zero payment, we have to make it clear to the government that the goods are exempted under a certain provision, whatever that may be. Again, if you can take a look, and honestly, from an operational perspective, we have some very ugly examples of how this works on an individual line item for an import declaration. Some of you are familiar with the verbiage of a 7501, the entry summary document. You know this. We provide all of our information to customs electronically these days. It is an electronic representation of that document. Nonetheless, the items are stacked.
If there is no language otherwise in an announcement from the president and the follow-on information from the Federal Register notice, we have to add them on top of each other. Again, there are situations, and the reciprocal tariffs had an unusual amount of exemptions. This is one. Again, we can't cover this in 58 minutes of a discussion like this. You're going to have to work on a case-by-case basis. I know many of you are working with us, with your individual branches that you work with. Certainly, we hopefully can explain that more specifically to your product.
Ted, the one that we get a lot of questions, the exemption, is the in-transit exemption. We've got about 90 seconds left. Could you give us the quick overview of the in-transit exemption?
The in-transit exemptions, the things that I always point out to people, unless we get any guidance from we, the trade, customs, whoever, get any guidance from the administration of their intent when they publish an executive order, we have to go off the literal language that is in the order and in the implementing actions in the Federal Register. A lot of folks have a question about whether they can utilize the in-transit exception for air shipments. The language in the order and the follow-up FRN, the Federal Register notice, speaks to vessel. It talks about the vessel being the goods being loaded, et cetera, for final export to the U.S. I can't remember the exact verbiage. The key thing is vessel is defined in the regulations, 19 CFR 4.0(a) . It talks about what a vessel is. It is a watercraft.
In fact, it specifically states in that that aircraft are not vessels. All we have to go off of, unless we hear otherwise from customs or the president or whatever, is we have to use the literal language. We have to look at that. We also know that customs only has visibility to the mother vessel. They do not have visibility to feeder vessels. That is why I am thinking the language is in there that it is destined for export to the U.S., that final voyage. That is what customs looks at, is that AMS data on ships. That is the short answer on that. Can I wind up now, Brenda?
I think so. We're at the top of the hour.
All right. Real quick, I'd like to say one thing. I want to say you typically see two or three of us on these webinars. There are a lot of folks who are involved in doing these webinars and frantically answering questions. I just want to say thank you to my colleagues on this one, whether that's the folks who do the show, Brenda, me, Madeleine, Stephanie. Stephanie does a ton to make our slides presentable and not a big pile of verbiage. Thank you. I hope I get everyone, Kelsey, Cela, Jared, Sue, Adrian, Scott, Estella, Sable, our colleagues around the globe who are feeding us information all last night and into early this morning, Alex, Tony, Noel, Ziad, our North American colleagues, Dave, Arturo. I'm missing somebody. If I forgot you, I'm sorry.
Finally, our unofficial member of our team, Samantha, who does so much more than putting these webinars together for you and taking your registration and all that and getting the survey to you, she holds us all together and keeps us on track. Thank you to all my colleagues that I get to work with. With that, I'll pass you back to Samantha to send us home.
Let's say I'm going to take the Academy Awards hook and start pulling you off stage there, Ted. Thank you so much for we do have so many people working in the background, and we all appreciate anybody that wasn't mentioned. You know who you are. Thank you too to all of the customers and attendees who have joined us on all of these events. We do see that there are so many more questions that we wanted to try to get to and have not been able to today. We will work feverishly to get you connected, though, to other product experts as well as your typical Expeditors contacts to make sure that your questions do get answered. Again, real quick, you're still hanging on.
Don't forget, we will send a survey out to you all so that you can give us your feedback on today's event and also get access to the recording and materials. Thank you all for those two extra minutes. We hope you have a great day.
Thank you all. Take care.