General Administration of Customs of China Unveils Detailed Rules for 84% Additional Tariffs on US Imports:

General Administration of Customs of China Unveils Detailed Rules for 84% Additional Tariffs on US Imports: 

Key Points for Enterprises

On April 9, the General Administration of Customs (GAC) issued Announcement No. 58 of 2025, stipulating that starting from 12:01 hours on April 10, 2025, an 84% additional tariff will be imposed on all goods imported from the United States. The announcement includes detailed implementation rules to guide enterprises on practical operations, covering critical aspects such as import declaration, identification of in-transit goods, and processing trade management. Relevant enterprises should promptly review these rules and prepare for compliance.

I. Effective Date and Scope of the Additional Tariffs

The announcement clarifies that goods of US origin declared for import on or after 12:01 hours, April 10, 2025 will be subject to the 84% additional tariff on top of the current applicable tariff rates (the sum of Most-Favored-Nation (MFN) tariff rates/provisional tariff rates and previously implemented additional tariffs). This means the import cost of all US-origin goods will rise significantly from this time point. Enterprises should urgently assess supply chain cost impacts, adjust procurement plans, and refine pricing strategies.

II. Criteria and Procedures for "In-Transit Goods" Exemption from the Additional Tariff

To mitigate transitional impacts, the announcement defines "in-transit goods" eligible for tariff exemption:

Core Eligibility: Goods must have departed from their place of origin before 12:01 hours on April 10, 2025 and be declared for import by 24:00 hours on May 13, 2025.

Declaration Requirements:

The "Departure Date" in the customs declaration form must reflect the date of departure from the first overseas port of loading (earlier than the policy's effective date), with the remark "<In-Transit Goods for Additional Tariff Exemption>" noted in the comments section;

For special trade modes (e.g., domestic sales from customs-supervised zones, bonded areas, or processing trade), enterprises must upload transportation documentation (including origin, departure time, and route details);

Enterprises must submit a sworn statement during declaration, assuming legal liability for the authenticity and accuracy of the declared information and supporting materials.

Tax Refund Process: Enterprises that mistakenly paid the additional tariff before May 13 may apply for a refund (including interest) by providing valid transportation proof, supplemented by the required declaration and documentation.

III. New Regulations for Processing Trade Management: Bonded Policies Maintained, but Classified Supervision Required

For processing trade enterprises, bonded policies remain unchanged, but new dedicated account book management rules are introduced:

Domestic Sales of Bonded Goods: From April 10, when domestically selling finished products (including defective items, excluding by-products) processed from US-origin bonded materials—whether inside or outside customs-supervised zones—enterprises must declare all bonded materials used and may not engage in bonded circulation for such goods;

Manual/Account Labeling: When establishing or modifying processing trade manuals, enterprises must mark US-origin materials and finished products with "[M]" at the beginning of the manual's remarks section or commodity item names to separate them from goods of other origins for distinct management;

Logistics Account Restrictions: Logistics accounts involving US goods are prohibited from conducting simple processing operations that alter commodity codes or origins.

IV. Key Tips for Enterprises: Timeframes and Documentation Are Critical

Adhere to Declaration Deadlines: The "departure time" and "import declaration time" are central to the in-transit goods exemption. Enterprises should immediately review transportation documents (e.g., bills of lading, cargo manifests) to ensure departure precedes 12:01 hours on April 10 and declarations are completed by May 13;

Standardize Documentation: Transportation proof must comprehensively include origin, departure time, and route details to avoid exemption denials due to incomplete information;

Update Processing Trade Systems: Enterprises using US materials should promptly update manual labels in their systems to ensure clear classification of bonded materials and products, preventing future customs clearance issues;

Prepare for Regulatory Scrutiny: After policy implementation, customs may intensify reviews of in-transit goods. Retain complete logistics chain records (e.g., shipping documents, communication trails) for potential inspections.

Policy Impact and Industry Recommendations

This tariff measure is a significant response to evolving international trade dynamics, potentially increasing cost pressures in industries highly dependent on US imports, such as automotive, agricultural products, and electronics. Enterprises should evaluate supply chain resilience, adjust import schedules, and leverage the in-transit goods exemption to optimize clearance timing for arriving cargo.

(Information source: GAC Announcement No. 58 of 2025)