The Two-Stage Tariff Plan: What Trump's New Import Taxes Mean for You

• Initial 10% Tariff for All Countries (Effective April 5, 2025, at 12:01 a.m. EDT) The first stage of the tariff policy will impose a 10% tariff on imports from all countries starting on April 5, 2025, at 12:01 a.m. EDT. This baseline tariff will apply universally, regardless of the trade relationship between the U.S. and the individual countries. The goal of this measure is to set a uniform tariff on all imports, marking a step toward addressing trade imbalances in a more generalized way.

• Individualized Reciprocal Tariffs for Countries with the Largest Trade Deficits (Effective April 9, 2025, at 12:01 a.m. EDT) Following the initial 10% tariff implementation, the second stage will see individualized reciprocal tariffs applied to countries with which the U.S. has the largest trade deficits. This more targeted approach will impose higher tariffs on goods imported from specific countries, where the U.S. feels the trade imbalance is most pronounced. For example, countries such as the UK will face a 10% tariff, while the EU will see a 20% tariff. These individualized tariffs are designed to encourage fairer trade practices and rectify what the U.S. perceives as unfavourable trade terms.

Key Topics & Overview

Commodity Specific Exemptions

As part of the new tariff measures, certain commodity-specific exemptions have been introduced. These exemptions primarily target specific HS (Harmonized System) codes for products that are deemed essential or of strategic importance. Key HS headings 3001, 3002, 3004, and 2934—which cover a range of pharmaceuticals, medicinal products, and research samples we see regularly shipped—will receive relief from the additional tariffs. This means that products falling under these categories will not be subject to the higher tariffs introduced under the reciprocal tariff policy.

These exemptions are particularly important for the life science industry, where goods are central to research, diagnostics, and treatment development. These exemptions appear to be unaffected currently, but are subject to change.

For the full list of exemptions, refer to: https://www.whitehouse.gov/wp-content/uploads/2025/04/Annex-II.pdf

FDA and USDA Impact

With any change to customs process and tariffs ther is  understandable uncertainty. With particular focus on the support departments within the US regulatory bodies, the changes announced are expected to cause delays. There is a high potential regulatory bodies such as the FDA (Food and Drug Administration) and the USDA (United States Department of Agriculture), will experiece significant pressure and increases to workloads both organisations are responsible for reviewing import documents, including permits and licenses, making them a critical cog in the customs wheel. Given the additional customs complexities and potential increase in administrative time on existing import volume as a result of the tariff policy, these agencies are expected to face considerable challenges. Although the full scope of the impact on import procedures and timelines remains unclear, it is widely anticipated that delays and processing backlogs will occur.

The last time the US made significant changes to customs procedure and policy regarding De minimus values for example, the industry saw significant delays at the border until the decision was reversed. Importers will need to stay prepared for potential delays in receiving approval, which could disrupt the export timelines of essential goods, particularly for organisations reliant on pharmaceuticals, medical devices, and other regulated materials.

Should the De minimus value threshold be reduced to Zero then it may place significant pressure on regulatory bodies such as the FDA (Food and Drug Administration) and the USDA (United States Department of Agriculture), both of which are responsible for reviewing import documents, including permits and licenses. Given the additional customs complexities and potential increase in administrative time on existing import volume as a result of the tariff policy, these agencies are expected to face considerable challenges. Although the full scope of the impact on import procedures and timelines remains unclear, it is widely anticipated that delays and processing backlogs will occur.

Validation Process Moving Forward

Moving forward, it is crucial for companies to remain in close communication with their courier services. Couriers are expected to provide valuable updates on how these tariff changes will impact specific product lines and offer clarity on the best routes to entry for affected materials. This may include advising on which customs procedures to follow and whether goods can still be imported under simplified entry processes or whether more extensive documentation is required.

Companies should seek clear guidance from their courier partners to ensure a smooth transition as the validation process for importing goods evolves, particularly in light of the new tariff regime.

De Minimus Threshold and Its Potential Impact

In international trade, the term De Minimus refers to a threshold value below which goods can be imported with fewer regulatory requirements and simplified customs procedures. Typically, goods that fall below this threshold are subject to less stringent documentation and often qualify for simplified entry procedures, enabling faster and more efficient processing through customs. This can include the use of simplified declarations or clearance through a broker acting as the Importer of Record (IoR).

In the context of the U.S. reciprocal tariffs, the De Minimus value is of significant importance, as it determines the ease of importation for low-value goods, such as preclinical research samples, kits, and biological materials like blood and tissue samples. Historically, these items, which are essential to various industries including the life sciences sector, have often qualified for simplified entry processes, which help avoid complex customs procedures and facilitate faster clearance & global trade.

Potential Changes to the De Minimus Threshold

Rumours have circulated regarding the possible reduction or elimination of the De Minimus threshold, which currently stands at $800 for many goods imported into the U.S. This would mean that even low-value items that previously qualified for simplified entry would now require formal entry procedures. While these rumours remain unconfirmed, in the worst-case scenario, the shift could lead to substantial changes in how goods are imported, particularly for industries reliant on fast-tracking materials, such as research institutions and life sciences companies.

If the De Minimus threshold is indeed lowered to zero or significantly reduced, the impact on entry brokers could be considerable. Brokers, who previously had the ability to act as the Importer of Record (IoR) and facilitate rapid clearance for lower-value goods, would now face increased administrative requirements and cost.

This would necessitate formal entry clearance for goods that were once processed under simplified procedures. For example, materials such as preclinical research samples, diagnostic kits, and biological samples would require more detailed documentation, regulatory compliance checks, and could face customs delays due to the more formal clearance process which includes PoA and potentially additional letters to regulatory bodies depending on the product.

Consequences for the Life Sciences Industry

In practical terms, this shift would potentially delay shipments, as goods that previously moved quickly through customs would now be subject to full formal clearance procedures. The increased documentation requirements and additional regulatory burden could lead to longer wait times at customs, which could be disruptive for industries like the life sciences sector, where temperature control and timely access to materials are crucial for research, clinical trials, and product development.

Integrator Couriers such as FeDEx and UPS are most likely to feel the strain operationally in this environment. With most of the material moved via these networks being cleared utilising simplified entry and De Minimus thresholds, it is important for organisations to be aware of the pending risks. Speak with your integrator partner as early as possible to outline their plans for approaching the changes and take steps to mitigate the risks of delay.

Furthermore, the costs associated with formal entry would likely rise. Entry brokers would need to allocate more resources to managing the additional paperwork and compliance checks required for each shipment, potentially leading to higher fees for the end user in the US. These additional costs, combined with the potential for delays, could have a significant impact on supply chain operations, particularly for companies that rely on highly regulated or time-sensitive materials.

Additional Customs Entry Process and Checks (De Minimus)

If the De Minimus threshold is reduced this may move more goods, particularly low-value items, to formal entry requirements Companies will need to ensure thatPower of Attorneys (PoAs) are in place with both their customs broker and the Importer of Record (IoR) in the U.S. Formal entry may require more detailed documentation and could involve additional checks at the border in some cases relating to regulatory compliance and customs clearance procedures. If all material is required to move through this formal entry process, it is essential that the PoA authorisation is updated to reflect the new customs requirements. This will ensure that your customs broker can efficiently manage the clearance process and that the importer can meet all the necessary compliance requirements, reducing the risk of delays and penalties.

In summary, while the De Minimus value change has yet to be confirmed, any movement toward eliminating or reducing the threshold to zero could have profound consequences on how goods are imported into the U.S. Low-value items traditionally processed through simplified entry procedures would now face more stringent requirements, leading to delays, higher costs, and an increased burden on brokers and companies alike.

This is particularly relevant for the life sciences industry, where the timely importation of research samples and materials is often critical to the progression of scientific work and clinical advancements.

Next Steps for Managing Tariff and Import Changes

As the new reciprocal tariff policy takes effect, it’s essential for businesses to take proactive measures to ensure smooth operations and avoid disruptions in the importation of goods, especially those in regulated industries like life sciences. The following steps should be taken to address potential challenges and to ensure that your logistics and supply chain operations remain efficient during this transition:

Engage with Your Logistics Provider

Start by reaching out to your logistics provider to discuss your specific product lines and assess whether they will be impacted by the new tariffs. This is a crucial first step to understanding the potential delays or changes to the importation process. Work closely with your logistics provider to identify any the impact should your product require a formal entry procedure, as well as any commodity-specific exemptions that may apply to your material. This will help you stay ahead of any changes in customs procedures and ensure timely delivery.

Outline the Importer of Record (IoR) Procedure

It is essential to clarify the Importer of Record (IoR) process with your courier and customers. The IoR is the party responsible for ensuring that all regulatory requirements, including paying duties and taxes, are met for goods entering the U.S. With the potential increase in customs checks and formal entry procedures, it is vital that both the importer and the courier are aligned on their roles and responsibilities. Ensure any Power of Attorney (PoA) documents are in place for the customs broker and confirm who will be acting as the IoR for each shipment. Understanding this process ahead of time will reduce delays and ensure compliance with customs requirements.

Submit FDA and USDA Permit Applications Promptly

Given the potential risk of backlogs at regulatory agencies such as the FDA and USDA, it’s essential to think ahead. Where possible submit any required permit applications as early as possible ensuring you meet the guidelines for submission and are comprehensive in the request. Delays in processing these permits could significantly affect your ability to export, particularly for regulated items like pharmaceuticals, medical devices, and biological materials. Take the initiative to review the necessary documentation and application requirements now, and ensure that your applications are submitted promptly and accurately to avoid unnecessary delays should the backlogs begin.

Ensure Temperature Control with Priority Services

If your shipments include temperature-sensitive materials, such as biological samples, medications, or other temperature-sensitive goods, it is essential to confirm that your courier has the appropriate temperature control capabilities in the port of entry to the US. Ensure that your logistics provider is equipped to handle any delays that may arise, particularly with sensitive products that require strict temperature control to maintain stability and integrity. Ensure your courier is utilising priority airfreight services to help expedite shipments and reduce the time goods spend in transit. This will be especially important if the shipping timelines are affected by longer customs clearance process due to the new tariff policy generally.

By taking these proactive steps, you can minimise the potential impact of the new tariffs and regulatory changes on your supply chain. Establishing clear communication with your logistics provider, ensuring regulatory compliance, and preparing for potential delays will help your business remain agile and prepared for the shifts in the international trade landscape.

If any current or potential customers would like to speak regarding their specific products and requirements please contact sales@arcabiologistics.com for a FREE consultation.