By Robert L. Soza, Jr., Cameron A. Secord, and Sherry Mathews
Pursuant to Notices issued by Department of Homeland Security Secretary on Monday, March 3, 2025, United States Customs and Border Protection (“CBP”) will begin collecting a duty of 25% on most products of Mexico and Canada (“First CAMX Tariffs”) imported into the United States.
Here is what you need to know about the First CAMX Tariffs:
- Effective at 12:01 AM eastern standard time on March 4, 2025.
- Assessed regardless of the current free trade agreement between the U.S., Mexico and Canada (“USMCA”).
- Subject to additional rules that apply the 25% duty to goods entered into U.S. Foreign Trade Zones.
- Separate from any other applicable tariffs (tariffs on steel and aluminum expected to begin on March 12th and will be assessed in addition to the First CAMX Tariffs).
- Not eligible for duty drawback.
- There is no exclusion process.
There are very few limitations to the First CAMX Tariffs. Notable limitations of the First CAMX Tariffs include:
- De Minimis Imports – Individual shipments of Mexican or Canadian products valued at less than $800 USD are exempted from the CAMX Tariff.
- Maquiladora Arrangements – Jackson Walker believes careful study needs to be conducted to determine whether an importer will pay the 25% duty on the value of the assembled product less United States content OR merely the value of Mexican labor to assemble that product.
- Warranty and/or Service Repair Arrangements – Only the value of labor and/or service performed is subject to the 25% duty.
- Energy Imports from Canada – Several energy products of Canada (including crude oil, natural gas, generated electricity, and critical minerals) are subject to a 10% rate of duty instead of a 25 % rate of duty.
Clients importing goods from Mexico and Canada should review their supply chains and assess the impact of these additional duties. If you have questions about how the First CAMX Tariffs impact your business, contact Jackson Walker’s International Trade/National Security Team that is actively advising clients in the face of this changing trade environment.
The opinions expressed are those of the authors and do not necessarily reflect the views of the firm, its clients, or any of its or their respective affiliates. This article is for informational purposes only and does not constitute legal advice. For more information, please contact a member of the Trial & Appellate Litigation practice.
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