By: Arthur W. Bodek
The February 1, 2025 Executive Order imposing additional 10% ad valorem duties on products of China provided that duty-free de minimis treatment would no longer be available for such articles. Recognizing that existing systems do not permit the immediate implementation of such action, a follow-up Executive Order dated February 5, 2025 has been issued restoring the availability of de minimis treatment for otherwise eligible products of China until there is a “notification by the Secretary of Commerce to the President that adequate systems are in place to fully and expediently process and collect tariff revenue . . . for covered articles otherwise eligible for de minimis treatment.”
This Order does not reflect a change in policy and it is likely that duty free de minimis treatment for Chinese products will be discontinued some time in the near future.
Please do not hesitate to contact any of our attorneys with questions on the above or to discuss any other aspects of the threatened or implemented additional tariffs as well as potential strategies to mitigate their impact.
