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China Reciprocal Tariffs Further Suspended Until November 10, 2025: What Importers Need to Know

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China Reciprocal Tariffs Further Suspended:

What Importers Need to Know


By Schulz Trade Law PLLC

August 14, 2025


Introduction:

Another Extension in U.S.–China Tariff Policy


On August 11, 2025, President Trump issued a new Executive Order, Further Modifying Reciprocal Tariff Rates to Reflect Ongoing Discussions with the People’s Republic of China. This order extends the suspension of certain “reciprocal” tariffs from the previous deadline of August 12, 2025, to 12:01 a.m. Eastern Standard Time on November 10, 2025.


This move continues the tariff freeze first enacted under Executive Order 14298, providing importers a three-month reprieve from higher duty rates while the United States and China continue negotiations on long-standing trade disputes.



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Key Provisions of the Executive Order


The August 11 order specifically addresses the suspension of tariff provisions under heading 9903.01.63 and subdivision (v)(xiv)(10) of U.S. note 2 to subchapter III of chapter 99 in the Harmonized Tariff Schedule of the United States (HTSUS).


Under this extension:

  • Reciprocal tariff rates for Chinese goods remain at 10% until November 10, 2025.

  • Fentanyl-related tariffs are unchanged — the IEEPA “fentanyl” tariff rate continues to be 20% for China-origin goods.

  • Importers have additional time to adjust supply chain and pricing strategies before any potential changes in tariff rates are implemented.


Why the Suspension Was Extended


According to the Administration, the continuation of this tariff pause reflects “significant steps” by China toward addressing U.S. concerns over non-reciprocal trade arrangements, as well as broader economic and national security issues.


By leaving the reciprocal tariff rate at 10% rather than increasing it, the White House signals optimism about progress in ongoing discussions while also maintaining leverage should negotiations falter.


This approach mirrors prior instances in trade diplomacy where temporary relief is offered as a sign of good faith, but with the clear understanding that tariff rates can be adjusted quickly if commitments are not met.


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Implications for Importers and Businesses


The suspension’s short-term nature means companies should treat the November 10 deadline as a firm marker for possible changes. Businesses that rely heavily on Chinese imports — especially those falling under the specified HTSUS provisions — should:


  1. Review their tariff exposure to determine the financial impact if the reciprocal tariff rate increases after November 10.

  2. Evaluate inventory strategies to potentially front-load imports before any rate changes.

  3. Update pricing models in anticipation of possible higher landed costs in Q4 2025 and beyond.

  4. Monitor compliance obligations under both reciprocal and fentanyl-related tariff regimes.



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Sector-Specific Considerations


While the reciprocal tariff rate covers a broad range of goods, certain industries may feel the impact more acutely:

  • Electronics and Technology: Many components are sourced from China under the affected HTSUS headings. Even a modest percentage change in tariffs can significantly affect profit margins.

  • Manufacturing Inputs: Raw materials and intermediate goods face cost pressures that can cascade through production lines.

  • Consumer Goods: Retailers relying on Chinese-manufactured products must balance cost stability with competitive pricing.


For sectors not affected by the reciprocal tariff but impacted by the fentanyl tariff, the unchanged 20% rate continues to require careful cost management and potential sourcing diversification.



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Compliance and Documentation Requirements


It is essential for importers to maintain accurate classification and origin documentation for all entries. U.S. Customs and Border Protection (CBP) has maintained heightened enforcement of tariff classifications, particularly in cases where preferential or reduced rates are applied.


Compliance measures should include:

  • HTSUS Verification: Confirm that products are classified under the correct headings to ensure accurate tariff application.

  • Origin Tracking: Maintain robust records proving the country of origin, especially when dealing with goods assembled in multiple jurisdictions.

  • Audit Readiness: Be prepared for post-entry reviews and Requests for Information (CF 28) from CBP.


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Strategic Planning Ahead of the November Deadline


Importers should not assume another extension will occur in November. Instead, businesses should take proactive steps now:

  1. Run “what-if” cost scenarios based on different potential tariff rates.

  2. Explore supplier diversification to reduce dependence on China-origin goods.

  3. Engage in advocacy through trade associations to ensure industry concerns are heard by policymakers.

  4. Consult with trade counsel to assess opportunities for tariff mitigation, such as first sale programs or duty drawback.



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Schulz Trade Law’s Role in Supporting Clients


At Schulz Trade Law PLLC, we actively track developments in U.S.–China trade relations and provide tailored advice to help clients navigate uncertainty.

Our team assists with:

  • Tariff exposure assessments to quantify potential cost impacts.

  • Compliance strategy development to ensure adherence to U.S. customs laws and regulations.

  • Risk mitigation planning to prepare for sudden changes in trade policy.

  • Representation before CBP and trade agencies in cases of enforcement actions or disputes.


We work with importers, manufacturers, and distributors across industries to create strategies that are both compliant and commercially practical.



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Conclusion:

Three Months of Breathing Room


While the extension to November 10, 2025, provides a temporary reprieve from higher reciprocal tariff rates, it is ultimately a pause, not a resolution. The ongoing negotiations between the United States and China will determine whether the current rates remain, increase, or change in scope.


Importers and other stakeholders should remain vigilant, using this window to review compliance, adjust sourcing strategies, and prepare for all scenarios. In the current trade climate, adaptability is a competitive advantage.



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About Schulz Trade Law


We are a dedicated team of trade law professionals, committed to helping businesses navigate the complexities of international regulations and tariffs. With deep industry knowledge and a client-first approach, we provide clear, actionable insights to protect your interests and drive success in a dynamic global market.



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