On April 30, 2025, U.S. Customs and Border Protection (CBP) published clarification on its International Emergency Economic Powers Act (IEEPA) Frequently Asked Questions page regarding import duties for goods in transit.

The FAQ page features a helpful table to be referenced by importers to determine if U.S. import entries qualify for the In-Transit Provision. CBP indicates that it is the importer’s responsibility for confirming if a shipment qualifies under the provision, as well as noting that tariff rates are subject to change. Additionally, CBP stated:

“The in-transit provisions for reciprocal tariffs only apply to the vessel mode of transportation; they do not apply to other modes of transportation such as air, rail, truck, etc. As defined in 19 U.S.C. 1401 and 19 CFR 4.0, vessel includes every description of water craft or other contrivance used or capable of being used as a means of transportation on water, but does not include aircraft. The in-transit provisions do not apply when the shipment begins by vessel and then arrives in the United States using a different final mode of transportation, often referred to as transloading.

For entries transported other than by vessel that were filed using HTS 9903.01.28, filers should take immediate action to correct such entries, as necessary, as soon as possible. For those entries that have been filed with CBP erroneously using HTS 9903.01.28, importers should correct the entry summary by filing a post summary correction. ”

A.N. Deringer, Inc. will continue to share relevant developments and clarifications as they become available. Should our customers have questions regarding a specific shipment, please contact your Customer Service Center.

Due to the rapidly changing application and modifications of duty rates, please note that Deringer is not responsible for coordinating the timing of U.S. entry and imposed tariff rates.