Updated Tariff Guidance: U.S.–Japan Agreement Brings 15% Baseline Rate

On September 16, 2025, the Department of Commerce published the tariff modifications needed to implement the United States–Japan Agreement (Executive Order 14345). The agreement sets a baseline 15% tariff on nearly all imports from Japan, with special treatment for automobiles, auto parts, and civil aircraft. These changes stem from both IEEPA reciprocal tariffs and Section 232 measures, meaning importers must pay close attention to HTSUS classification and sequencing to avoid misfilings.

General Reciprocal Tariff

For most Japanese products, the duty calculation depends on the standard Column 1 duty rate:

• If the Column 1 rate is 15% or higher, the additional reciprocal tariff is zero (HTSUS 9903.02.72).
  
• If the Column 1 rate is below 15%, the combined rate must equal 15% (HTSUS 9903.02.73).

This framework applies to Japanese goods entered for consumption on or after August 7, 2025. Importers with entries filed under now-retired heading 9903.02.30 must update them using the new headings to ensure correct treatment.

Civil Aircraft

Effective September 16, 2025, Japanese civil aircraft and related products covered by the WTO Civil Aircraft Agreement are exempt from reciprocal tariffs and certain Section 232 duties on steel, aluminum, and copper. These products should now be filed under HTSUS 9903.96.02.

Automobiles and Auto Parts

Japanese automobiles and parts face a baseline of 15%:

• Automobiles and parts with a Column 1 duty rate of 15% or more owe no additional Section 232 duty (HTSUS 9903.94.40 and 9903.94.42).
  
• Automobiles and parts with a Column 1 duty rate of less than 15% will be brought up to 15% by a Section 232 duty equal to the difference (HTSUS 9903.94.41 and 9903.94.43).

Importers should report the 15% rate on the Chapter 99 number and the entry line value on the appropriate Chapter 1–97 number.

U.S.–Japan Agreement Interaction with Section 232

Products of Japan that fall under Section 232 (steel, aluminum, copper, and vehicles/parts) remain exempt from reciprocal tariffs. Filers should continue using HTSUS 9903.01.33 for these categories.

HTSUS Sequencing

CBP emphasizes that entries with multiple HTSUS numbers must follow this order:

1. Chapter 98 (if applicable)
2. Chapter 99 for additional duties (if applicable)
   • Section 301
   • IEEPA Fentanyl
   • IEEPA Reciprocal
   • Section 232 or 201 duties
   • Section 201 or 232 quota
3. Chapter 99 for replacement duty/other use
4. Chapter 99 for other quota
5. Chapter 1–97 commodity tariff

Conclusion

The baseline shift to 15% represents a substantial change in the U.S.–Japan trade relationship, but the details—especially around autos, civil aircraft, and Section 232 overlaps—require careful compliance work.

As new tariff regulations continue to evolve, navigating these changes requires experienced legal counsel. At Liang + Mooney, PLLC, our seasoned tariff lawyers can answer your questions and concerns with sophisticated legal solutions.  If you seek strategic counsel and insight into which tariffs apply to your operations, we invite you to contact us to schedule a consultation.