We wanted to share three key trade updates that have been the focus of recent discussions with many of our clients this week. Please review the following information regarding the new Section 232 tariffs, potential China tariffs, and a Hot Topic tip on managing steel/aluminum tariffs.
New Section 232 Tariffs on Timber, Lumber, and Derivative Products
Effective October 14, 2025
The U.S. government has implemented new Section 232 import duties affecting timber, lumber, and related products. Below is a summary of the new duty rates:
Softwood Timber and Lumber
- 10% additional ad valorem rate of duty
Upholstered Wooden Furniture Products
- From all countries except the United Kingdom, Japan, and EU member states: 25%
- From the United Kingdom: 10%
- From Japan: 15%
- From the European Union: 15%
Completed Kitchen Cabinets, Vanities, and Parts
- From all countries except the United Kingdom, Japan, and EU member states: 25%
- From the United Kingdom: 10%
- From Japan: 15%
- From the European Union: 15%
Other Kitchen Cabinets/Vanities and Parts (Unfinished or Incomplete)
- 0% additional ad valorem duty
Exemptions:
Products already subject to Section 232 duties on automobiles and automobile parts remain exempt.
Products subject to IEEPA tariffs also carry certain exemptions, including:
- Canada and Mexico IEEPA exemptions
- Reciprocal IEEPA tariff exemptions
- 40% IEEPA tariff on Brazil
- IEEPA oil tariffs on India and Russia
Additionally, Chapter 44 subheadings have been removed from Annex II reciprocal exceptions, meaning they are now subject to reciprocal tariffs.
Potential 100% Tariff on Imports from China
The White House has recently threatened a 100% tariff on all imports from China — “over and above any existing tariffs.”
At this stage, no official action has been taken. We are currently in a wait-and-see period until an Executive Order or official Customs announcement is issued.
It remains unclear whether any new tariffs would apply based on the entry date or if exceptions will be made for vessels already on the water prior to implementation.
We will continue to monitor developments closely and provide timely updates as more information becomes available.
Hot Topic: How to Legally Avoid Paying 50% Tariffs on the Entire Invoice Value of Steel/Aluminum Products
Question:
How do we avoid paying Section 232 steel/aluminum tariffs on the entire invoice value if only a portion of the product is made of steel or aluminum?
Answer:
Request that your supplier provides a detailed, itemized commercial invoice that clearly breaks down all cost components, including:
- Labor costs
- Packaging
- Logistics/Transportation
- Steel or aluminum content (in value)
- Non-steel/aluminum content (in value)
Only the value of the steel or aluminum is subject to Section 232 steel/aluminum tariffs.
- Non-steel/aluminum content of the article is subject only to applicable reciprocal tariffs.
- Labor, packaging, and transportation costs are not subject to any tariffs.
Pro Tip:
The more documentation, the better. Ask suppliers for:
- Affidavits
- Bills of material
- Detailed commercial invoices
- Supporting photos
Note:
U.S. Customs and Border Protection (CBP) is entitled to request any supporting information needed to verify the breakdown between steel/aluminum and non-steel/aluminum components. Ensure all supporting documents are readily available at the time of entry.
How to Protect Your Business
- Always work with a licensed U.S. customs broker.
- Maintain accurate invoices and supporting documentation.
- Conduct regular compliance audits.
- Be cautious of overseas forwarders offering “duty savings” schemes-you will be held liable.
Richard Murray & Co. is committed to safeguarding your supply chain. For questions about compliance or to review your customs processes, contact us today.
Trust. Compliance. Protection.












