Business Supports in response to Trade Tariffs

Not all goods are included. 

Annex II currently contains a list of relevant Harmonised Tariff Schedule (HTS) codes exempt from the recent US tariff announcements. On April 11, 2025, the White House issued the Clarification Memorandum, detailing additional HTS codes that are exempt from the reciprocal tariffs under previous Executive Orders. Please note that exemptions are subject to change as new announcements are made and Executive Orders are signed.

The new 10% tariffs are imposed in addition to the existing Most Favoured Nation (MFN) tariffs.

Goods that were loaded and in final transport mode before 12:01 AM (ET) on April 5, 2025, and that arrive in the U.S. before May 27, 2025, are exempt from the 10% reciprocal tariff.

The Harmonised Tariff Schedule (HTS) is a system to classify categories of products imported into the US. It sets out the tariff rates and statistical categories for all products imported into the US. HTS codes are 10- digit classification numbers which determine the tariff rates and duties applied to imported products. 

The US International Trade Commission offers an interactive training module to support exporters in gaining a basic understanding of the HTS, including guidance on how to read the tariff schedule.

Annex II currently contains a list of relevant HTS codes excluded from the recent US tariff announcements. Furthermore, on April 11, 2025, the White House issued the Clarification Memorandum that provides an additional list of HTS codes that are exempt from the reciprocal and baseline tariffs under previous Executive Orders. 

These codes relate to goods including smartphones, computers, monitors, and various other electronic components. Please visit this link for a full list of the associated HTS codes and further information.

If a product is deemed to be "made in China" and is shipped through Ireland, it will be subject to Chinese tariffs according to US rules of origin. Understanding your HTS codes is vital, as is understanding their rules of origin. It is important to distinguish where your product was technically made (i.e. The EU, China or elsewhere). 

If more than one country is involved, the country of origin is determined by where the last ‘substantial transformation’ occurred. This refers to the creation of a ‘new article with a different name, character and use.’

The de minimis exemption for Chinese products has been removed. The de minimis rule currently remains in place for non-Chinese US imports but there is an understanding that this may be removed in the future. 

New rates for de minimis postal shipments from China have been updated as follows and are effective May 2, 2025: 

• Ad valorem duty: 120 percent of the value of the postal item, 

  or 

• Specific duty: $100 per postal item. This will be increased to $200 per postal item on June 1, 2025.

Carriers will continue to determine monthly which duty they will impose, and that selection will apply to all shipments brought in by that carrier.

The country of origin is defined by US Customs and Boarder Protection as the ‘country of manufacture, production, or growth of the article.’ If more than one country is involved, the country where the last ‘substantial transformation’ occurred. 

This refers to the creation of a ‘new article with a different name, character and use’. For textiles and apparels for example, the second country is deemed to be the country of origin.

Currently tariffs only apply to physical products being imported or exported. However, we encourage all clients to engage closely with US customers, partners and suppliers as we do not know how services will be affected in the future.

This a dynamic and evolving situation, and Enterprise Ireland remains committed to supporting Irish-owned exporting companies as they navigate this shift in global trade, by providing resources, guidance, and strategic support to help client companies to mitigate the impact of tariffs. 

For detailed information on supports and how we can help you, please visit our ‘Business Supports in Response to Trade Tariffs’ webpage. 

We are also encouraging all clients to contact their dedicated Enterprise Ireland Client Advisor to discuss their situation and what options may be available to them. Contact us at ExportTariffs@enterprise-ireland.com.