Reciprocal Tariff Exclusion for Specified Products: Full Guide 2025

What Is Reciprocal Tariff Exclusion Guidance?

In early 2025, American importers faced a whirlwind of new reciprocal tariffs that threatened to drive up costs on almost every foreign good. On April 5, a blanket 10% tariff hit imports from nearly all countries, with President Trump announcing even steeper country-specific rates days later. Businesses braced for chaos, but certain key industries were offered a lifeline as high-priority imports, like smartphone components, became eligible for reciprocal tariff exclusions.

Roughly 20% of U.S. imports were initially excluded from the “Liberation Day” reciprocal tariffs announced in April. In fact, 1,039 product categories were carved out as exceptions, including pharmaceuticals, semiconductors, medical supplies, lumber, copper, and certain energy products. Some of these categories were exempt because they were already subject to different tariffs, like the Section 232 tariffs on steel and aluminum. These exclusions helped shield key industries from the most severe impacts of the new tariff measures.

Eligibility Criteria for Reciprocal Tariff Exclusions

Product categories considered for exclusion typically fall into one or more of the following:

• Items critical to public health or national security, such as pharmaceuticals and medical devices

• Components essential to major domestic industries, including electronics and aerospace

• Inputs with limited or no viable domestic substitutes, such as specific chemicals, raw materials, or technical machinery

How to Apply for Reciprocal Tariff Exclusions

Classify products correctly to claim exclusions. If your imports fall under one of the exempted HTS categories (such as semiconductors, pharmaceuticals, or specific machinery), you must flag that on your customs entry. CBP’s guidance specifies that importers should report the secondary HTS code 9903.01.32 (or other applicable Chapter 99 code) for excluded products.

CBP also allowed products entered on or after April 5 to be corrected within 10 days of release, and for already-paid duties to be refunded via post-summary corrections or protests. It’s important to stay on top of these filings to avoid unnecessarily paying tariffs. 

Leverage US content in your products. What if your product category isn’t on the exclusion list? There’s another angle: the reciprocal tariffs deliberately don’t apply to the US-made portion of a product. According to the Executive Order, if at least 20% of a product’s value is from US-origin components, then the tariff is charged only on the remaining foreign content value. 

This means importers can reduce tariff costs by carefully documenting the American-made parts or materials in their imports. Customs may require proof (like certificates of origin, bills of materials, and manufacturing details) to verify that at least one-fifth of the product is indeed US content. 

This “content exclusion” essentially rewards companies for sourcing domestically. It also encourages foreign suppliers to incorporate more US-made components if they want to maintain price competitiveness. The key for importers is to maintain good records and be ready to declare the US content on entry documentation.

Monitor low-value shipment rules (de minimis). Importers have long relied on the de minimis rule, the provision that allows duty-free import of goods valued under $800, to bring in samples, e-commerce parcels, or small orders without hassle. In the reciprocal tariff era, this avenue still exists, but with a big exception: shipments from China (and Hong Kong) no longer enjoy the de minimis exemption as of May 2025. 

Initially, the US government moved to impose a 120% tariff or a flat $100 fee per parcel, whichever the carrier chose. After negotiations, the rate was dialed down: from May 14 onward, small Chinese packages face a 54% tariff (or $100 fee), and a planned increase of the flat charge to $200 was called off. 

While de minimis does remain available for other countries’ goods, many importers are already exploring alternative sourcing from suppliers in places like Vietnam or Mexico for small orders to preserve duty-free treatment. But caution: rules can change fast, and CBP can enforce formal entries if abuse is suspected. Always stay updated on the latest guidance for low-value imports to remain compliant.

List of Specified Products Eligible for Exclusion

Products excluded from the reciprocal tariffs include:

• Steel/aluminum articles already subject to Section 232 tariffs

• Automobiles/automobile parts already subject to Section 232 tariffs

• Any products that become subject to Section 232 tariffs in the future

• Products already subject to 50 USC § 1702(b), including books and informational materials

• All articles from countries that are already subject to rates from Column 2 of the Harmonized Tariff Schedule (HTS), including Russia, North Korea, and Cuba

• Other products listed in Annex II of Executive Order 14257, including copper, lumber, pharmaceuticals, semiconductors, key minerals, and energy-related products. On April 11, Trump also broadened Annex II to include more HTS headings and subheadings, declaring that smartphones, computers, and a wider range of electronic devices were also eligible for exclusion 

Impact of Exclusions on Import Costs

The reciprocal tariff program remains costly overall, but exclusions have helped blunt the economic blow. Shielding roughly one-fifth of imports from duties cushioned key sectors and prevented some severe price spikes. Analysts estimate that the broader tariff policy still adds between $26.3 and $34.5 billion in extra costs to U.S. consumers and businesses in its first year.

Had semiconductors or pharmaceuticals been subject to full tariffs, the impact could have been more damaging. The exclusions preserved stability in sectors like electronics manufacturing and construction. Despite this, higher import costs on the remaining 80% of goods have fueled price inflation.

Early economic data showed U.S. GDP dipped 0.3% in Q1 2025, with policy uncertainty cited as a contributing factor. Some households may see hundreds of dollars per year in additional expenses due to tariff pass-through costs. The exclusions have clearly mitigated risks for some importers, but not all.

Updates and Changes in 2025

The tariff landscape in 2025 is constantly evolving. As legal and policy developments continue to shift the rules, it's important to stay vigilant. Importers should monitor trade developments weekly and stay in touch with legal counsel, compliance updates, and CBP guidance. The ability to act quickly—whether adjusting sourcing, coding entries correctly, or petitioning for product-specific relief—can translate into major cost savings and competitive advantage.