How to handle US-China tariffs and the end of de minimis

• After meeting with President Xi Jinping of China on October 30, 2025, President Trump told reporters that he expects to sign a trade agreement with China “pretty soon.” Trump also said he’ll lower the tariff on China by 10%.

• The reciprocal tariff on Chinese imports was on track to jump by 10% on November 10, 2025. That increase seems to be off the table, but we won’t know for sure until the White House publishes official guidance.

• The U.S. ended the de minimis exemption for products originating in China and Hong Kong effective May 2, 2025. The U.S. suspended de minimis for all countries on August 29, 2025.

As of November 3, 2025, imports from China are subject to the following U.S. tariffs:

• A 10% International Emergency Economic Powers Act (IEEPA) reciprocal tariff (down from 125%)

• A 20% IEEPA fentanyl tariff 

• Various Section 301 tariffs first implemented in 2018 (7.5% to 100%)

The 20% IEEPA fentanyl tariff will drop to 10% effective November 10, 2025, per a White House fact sheet.

As the tariffs are stackable, total tariffs for select products can exceed 100%. Like other countries, China is also subject to product-specific tariffs, such as the 50% tariff on steel and aluminum, and copper (Section 232 tariffs).

On November 1, 2025, the White House published a fact sheet on the trade deal with China. It states that the U.S. will:

• Lower the fentanyl tariff on China by 10% effective November 10, 2025.
• Maintain its suspension of heightened IEEPA reciprocal tariffs on Chinese imports until November 10, 2026; the current 10% reciprocal tariff will remain in effect.
• Extend the expiration of certain Section 301 tariff exclusions (set to expire on November 29, 2025) until November 10, 2026.

On October 30, 2025, the U.S. and China reached a strategic stalemate during trade talks in South Korea. Beijing will reportedly suspend restrictions on rare earth exports, and Washington will reportedly lower the fentanyl tariff from 20% to 10%. Both countries have also reportedly agreed to suspend their new port fees on each other’s ships. 

On October 14, 2025, the U.S. implemented new port fees on certain Chinese-built vessels and vessels with Chinese owners or operators, and China imposed new port fees on U.S.-owned vessels.

On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit ruled that IEEPA does not authorize the president to impose the tariffs as he has done. The administration appealed, and the Supreme Court of the United States will hear oral arguments on November 5, 2025.

On August 11, 2025, the White House suspended a tariff increase that was set to hit Chinese imports on August 12. Products of China, Hong Kong, and Macau remain subject to a 10% reciprocal tariff until November 10, 2025, along with the 20% tariff established earlier this year under IEEPA, plus other applicable U.S. tariffs 

On June 10, 2025, the U.S. Court of Appeals for the Federal Circuit extended the temporary stay issued May 29. 

On May 28, 2025, the IEEPA tariffs were challenged. The U.S. Court of International Trade blocked the IEEPA tariffs on May 28, and the U.S. Court of Appeals for the Federal Circuit stayed the injunction the following day. 

On May 14, 2025, reciprocal tariffs on China were temporarily lowered. President Trump suspended the reciprocal tariffs for 90 days, until August 12, but retained a 10% baseline tariff, plus the 20% IEEPA fentanyl tariff, Section 301 tariffs, and Section 232 tariffs. Total tariffs on select products dropped from 245% to 130%. For most products, the tariff is around 55%.

On May 2, 2025, de minimis ended for China. Low-value imports produced in China and Hong became subject to all applicable tariffs on May 2.

On April 11, 2025, the White House announced exceptions to the reciprocal tariffs. Per the CBP guidance, reciprocal tariffs do not apply to select merchandise entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on April 5, 2025.

Affected products include electronics such as computers, semiconductors, and smartphones (the guidance includes a list of affected Harmonized Tariff Schedule of the United States, or HTSUS, codes). Importers may request a refund of duty paid before this exclusion was provided.

On April 9, 2025, President Trump raised the tariff on China. Per his executive order, a 125% duty replaces the 84% duty previously announced and also applies to products of Hong Kong and Macau. The 125% tariff took effect at 12:01 a.m. on April 10, 2025.

The grand total for most products of China reached than 145%, though as a White House fact sheet explained, China faced “up to a 245% tariff on imports to the United States.” For example, a 245% tariff applied to electric vehicles and syringes.

There are some exclusions. Goods not subject to the reciprocal tariff include:

• Articles subject to 50 USC 1702(b) 
• Bullion
• Copper, pharmaceuticals, semiconductors, and lumber articles
• Energy and certain minerals that are not available in the United States
• Steel/Aluminum articles and autos/auto parts already subject to Section 232 tariffs, and all articles that may be subject to future Section 232 tariffs 

Drawback is available with respect to the reciprocal tariffs. U.S. Customs and Border Protection (CBP) is publishing updated guidance as it can.

On April 8, 2025, the U.S. increased the reciprocal China tariffs from 34% to 84%. The 84% duty took effect at 12:01 a.m. ET on April 9, 2025.

On April 2, 2025, President Trump invoked IEEPA to impose an additional 34% reciprocal tariff on China starting April 9, 2025. The 34% rate included the new baseline 10% tariff that applies to all countries as of April 5.

On March 3, 2025, the U.S. increased the fentanyl tariff from 10% to 20% for products of China and Hong Kong entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on March 4, 2025.

On February 4, 2025, the new 10% tariff on China took effect.

On February 1, President Trump used IEEPA to set a 10% tariff on top of the existing Section 301 tariffs on Chinese imports (including products of Hong Kong) effective February 4. The executive order didn’t provide for drawback, and there was no stated exclusion process.

The de minimis exemption provided by 19 U.S. C. § 1321(a)(2)(C) (aka Section 321 shipments) allows one shipment of goods (per person, per day) valued at or under $800 to enter the U.S. free from duty and import taxes.

The. U.S. suspended the de minimis exemption for China and Hong Kong effective May 2, 2025.

New duty and postal fees for de minimis imports arriving by international mail

Goods from China and Hong Kong valued at or under $800 became subject to an ad valorem rate of duty or a postal fee starting May 2, 2025, at 12:01 a.m. ET.

The duty was initially set at 30% of the value of the postal item, but on April 8, the duty was increased to 90% of the value of the postal item. On April 9, President Trump increased the de minimis duty to 120%.

Then, on May 12, the president issued an executive order lowering the duty rate for de minimis mail shipments to 54% effective May 14, 2025, at 12:01 a.m. ET.

The per postal item containing goods duty for low-value postal shipments is $100 as of May 2 (after being increased by executive orders dated April 8 and April 9) This fee increased to $200 on June 1, 2025.

There are new duty rates for international postal shipments in the executive order that eliminates de minimis for all countries, as described here. The specific duty for postal shipments:

• $80 per item for countries with an effective IEEPA tariff rate of less than 16%.
• $160 per item for countries with an effective IEEPA tariff rate between 16% and 25%.
• $200 per item for countries with an effective IEEPA tariff rate above 25%. 

Effective May 2, 2025, a new import process is required for shipments of products of China and Hong Kong, including postal shipments. Entry Type 86 is no longer accepted for low-value imports from China and Hong Kong. Other than for mail, entries must be made in the CBP Automated Commercial Environment (ACE); paper documents are no longer accepted.

The new import processes will increase costs and shipping times. Filers and importers must: 

• File the appropriate formal or informal entry 
• Pay all applicable duties, taxes, and fees

Formal entry (Entry Type 1) is required for shipments with a value greater than $2,500. 

Informal entry (Entry Type 11) may now be the best option for most low-value shipments from China and Hong Kong. It’s also appropriate for certain low-risk goods (e.g., products exempt from quotas or countervailing duties).  

Entry Type 11 is an informal entry process, but it’s still more burdensome than the process many businesses have historically used for de minimis shipments.  

The main requirement with Entry Type 11 is the completion of CBP Form 7501, which must be filed electronically through the ACE system. 

“Completing the form is an additional administrative step that many will find burdensome,” says Patrick Frith, Senior Director of Growth Cross-Border at Avalara.

Information requirements for Entry Type 11

The key information required for CBP Form 7501 includes:

• Importer and entry information
• Shipment and transport details
• Merchandise and classification, including the 10-digit Harmonized Tariff Schedule (HTS) code for each item
• Valuation and duty calculation (transaction value is based on the price paid for the merchandise when sold for export to the U.S., plus any applicable packing costs, selling commission, royalty fees, etc.)
• Additional declarations and certifications

Estimated duties must be deposited within 10 days of the release of the merchandise.

Challenges of using Entry Type 11

Determining the proper 10-digit HTS code is one of the most challenging tasks for businesses shipping goods internationally. But it’s essential: If ecommerce sellers, online marketplaces, importers, shippers, or others responsible for filing the informal entry use the wrong code, the incorrect duty may be applied. This can result in additional delays at customs and/or penalties and fines.

Businesses that have benefited from the de minimis exemption may not be accustomed to classifying products with 10-digit HTS codes. Their systems may not be set up to apply tariffs for these shipments.

“The suspension of de minimis for all countries — removing the long-standing low-value threshold many businesses have depended on — marks a pivotal shift in U.S. trade policy,” says Shane Bogdan, Director of Cross-Border Sales at Avalara. “This is no time for a ‘wait-and-see’ approach. To avoid surprises at the border and maintain consumer trust, businesses must act now to ensure accurate product classification and duty calculations. Transparent landed cost pricing is no longer a ‘nice-to-have’ — it’s a competitive necessity for selling into the U.S. market.”

The most effective way for businesses to meet the changing demands of tariff changes is to automate customs duty compliance.

Avalara Cross-Border delivers real-time calculation of customs duties and import taxes and automates the assignment of the full 10-digit HTS codes required under Entry Type 11.

Our customers are benefitting from our technology. “Avalara’s suite of compliance services can help you stay on top of this rapidly changing environment, giving you peace of mind that you are keeping pace with the changes,” says Craig Reed, General Manager of Cross-Border at Avalara.  

More tariff changes are likely, and finding accurate, up-to-date information can be difficult. Whatever happens, let us help you stay ahead of change and continue to grow globally. Contact us today to learn more.