Canada and Mexico Duties Deadlines Arrive with No Indications of Delay

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Mar. 3, 2025
By: Marvin E. McPherson

Despite speculation about possible negotiations, there are no signs that discussions will halt the implementation of new tariffs on imports from Canada and Mexico. The additional duties outlined in the latest federal register public inspection will take effect at 12:01 a.m. EST on March 4, 2025. This comports with reports from the end of February as well.

Under this directive, products of Canada and Mexico—defined as goods either originating in or undergoing substantial transformation before U.S. importation, will be subject to the new ad valorem tariffs. These duties, detailed under HTSUS headings 9903.01.10 - 9903.01.13 (Canda) and “9903.01.01 - 9903.01.03 (Mexico), are in addition to all other applicable tariffs, taxes, and fees.

The March 2, 2025, Executive Order confirms that the de minimis exemption (19 U.S.C. 1321(a)(2)(C)) remains available for affected imports, ensuring that small-value shipments continue to receive duty-free treatment. However, the additional tariffs will apply broadly, with limited exclusions.

Notably, goods entered under Chapter 98 of the tariff schedule may be exempt from these additional duties if they qualify under CBP regulations. The exception does not extend to goods under subheadings 9802.00.40, 9802.00.50, and 9802.00.60, where tariffs will be imposed on the value of processing done in Canada or Mexico. Similarly, for heading 9802.00.80, duties will be assessed on the value of the assembled article, minus the cost of U.S. components.

Even products benefiting from special tariff treatment under General Note 3(c)(i) including those under USMCA, or those eligible for temporary duty exemptions or reductions under subchapter II, chapter 99, will still be subject to these additional duties.

We know from the initial round of proposals that Canada has a retaliation list at hand. Whether Canada will utilize that list is not clear at this moment.

The Canada Annex for the new tariffs is here. The Mexico Annex is here.

With no indication that these tariffs will be postponed, businesses importing from Canada and Mexico should act immediately to assess the impact on their supply chains and compliance obligations. If you need further guidance on mitigating tariff exposure, please contact any attorney at Barnes Richardson and Colburn.