Understanding multi-tariffs
Multi-HTS tariffs in the US
In some situations, the United States CBP requires that you report multiple tariffs/HTS codes on one tariff line. This traditionally applied when reporting clocks and watches, but in more recent years with the advent of retaliatory tariffs we have seen the requirement for multi-tariff reporting explode. You can find an explanation of the different trade remedy actions on the Customs website.
Some multi-tariffs we want to highlight are:
1. Section 301
Section 301 of the Trade Act of 1974 grants the United States Trade Representative (USTR) the authority to investigate and respond to unfair foreign trade practices that harm U.S. interests. If a foreign country violates trade agreements or engages in practices that are "unjustifiable" or "unreasonable" and burden U.S. commerce, the USTR can act.
These actions can include imposing new tariffs, withdrawing trade agreement concessions, or negotiating binding agreements. A notable example is the tariffs imposed on China in 2018, which targeted a wide range of goods in response to China's policies on intellectual property and technology transfer.
Example Section 301 chapter 99s:
- 9903.88.01: Additional duties on certain products from China
- 9903.88.02: Additional duties on other specified products from China
- 9903.88.03: Additional duties on further specified products from China
- 9903.88.04: Additional duties on additional specified products from China
- 9903.88.15: Additional duties on certain other products from China
- 9903.91.01 to 9903.91.11: Additional duties on various products from China, effective from different dates
2. Section 232
Section 232 of the Trade Expansion Act of 1962 allows the President to impose tariffs or other trade restrictions on imports if the Department of Commerce determines that these imports threaten to impair national security. In 2018, the U.S. used Section 232 to impose tariffs of 25% on steel and 10% on aluminum imports, citing national security concerns. These tariffs aimed to protect domestic industries from global overcapacity and unfair trade practices, particularly from countries like China.
Example Section 232 chapter 99s:
- 9903.80.01: Additional duties on steel articles
- 9903.85.01: Additional duties on aluminum articles
- 9903.85.02: Additional duties on certain aluminum derivative articles
- 9903.85.03: Additional duties on other aluminum derivative articles
3. IEEPA
The International Emergency Economic Powers Act (IEEPA) grants the U.S. President the authority to regulate international commerce in response to unusual and extraordinary threats to national security, foreign policy, or the economy. In early 2025, President Trump used IEEPA to impose additional tariffs on imports from Canada, Mexico, and China.These tariffs included a 25% duty on goods from Canada and Mexico, and a 10% duty on goods from China.The rationale was to address national security concerns and other economic threats.
Example chapter 99s for IEEPA:
Chapter | Brief Description | Duty Impact |
|---|---|---|
9903.01.20 | This heading applies to most articles that are products of China and Hong Kong, and it imposes an additional 10% ad valorem duty on these products. This additional duty is in addition to any other applicable duties. | Additional 10% |
9903.01.21 | This heading covers articles that are products of China and Hong Kong that are donated by people under US jurisdiction for humanitarian reasons, such as food, clothing, and medicine. These items will still have to pay the regular duties, but not the additional 10%. | Excluded, no additional duties |
9903.01.22 | This heading applies to informational materials from China and Hong Kong, including publications, films, posters, and other media. These will still have to pay regular duties, but not the additional 10%. | Excluded, no additional duties |
9903.01.23 | This heading provides an exception for certain goods that were already in transit before February 1, 2025. To qualify for this exception, the goods must have been loaded onto a vessel or in transit before 12:01 a.m. eastern standard time on February 1, 2025, and entered for consumption before 12:01 a.m. eastern standard time on March 7, 2025. These goods will still have to pay the regular duties, but not the additional 10%. | Excluded, no additional duties |
Tools to manage multi-tariffs (Item Master Custom Rules)
The Item Master Custom Rules (IMCR) is a cross-platform tool within ONESOURCE Global Trade that supports the setup of multi-tariffs. It allows you to set up different rules and apply the multi-tariffs configured to the product transactions that match the criteria. This tool is generally used for U.S. imports or for admissions into a U.S. Foreign Trade Zone. You can find more information in the
Item Master Custom Rules
article. Currently, IMCR integrates with the following products:
- Import MGMT
- US Foreign Trade Zone
- US ABI