What Importers Need to Know: Retroactive Tariffs Under the U.S.–Japan Agreement

Le
Sep 5
2 min read

Updated: Sep 15

On September 4, 2025, the White House issued an Executive Order (EO) titled “Implementing the United States–Japan Agreement.” This order—signed under the International Emergency Economic Powers Act (IEEPA)—marks a major change in how U.S. Customs and Border Protection (CBP) will apply duties to imports from Japan.

Key Highlights of the Executive Order

Baseline 15% Duty: Nearly all imported products of Japan are now subject to a 15% ad valorem tariff.
Sector-Specific Treatment: Certain industries are treated separately, including:
- Automobiles & automobile parts
- Aerospace products
- Generic pharmaceuticals
- Natural resources not naturally available or produced in the U.S.
Retroactive Implementation: The new tariffs apply retroactively to goods from Japan that entered for consumption—or were withdrawn from warehouse for consumption—on or after 12:01 a.m. EDT, August 7, 2025.

What Retroactive Means for Importers

Subsection 2(d) of the EO requires that duties be applied to qualifying entries backdated to early August. This means importers who entered Japanese goods after August 7 may be entitled to a refund or may owe additional duty depending on how their products were originally filed.

However, CBP has directed that no Post Summary Corrections (PSCs) or protests be filed at this time. Instead, importers must wait for formal instructions from CBP on how refund requests and adjustments will be processed.

Next Steps for Importers

Review recent entries: Identify shipments from Japan entered or withdrawn from warehouse since August 7, 2025.
Wait for CBP guidance: Do not file PSCs or protests until CBP provides instructions through future Cargo Systems Messaging Service (CSMS) updates.
Stay in touch with your broker: Your customs broker can help you monitor affected entries and prepare documentation for when refund or duty-payment instructions are issued.
Report filing errors: If you encounter issues on an entry summary, reach out to your CBP client representative or the ACE Help Desk.