Trade Update: Key Tariff and Customs Changes in December

IEEPA Tariffs: Court Clarifies Refund Rights

On December 15th, the U.S. Court of International Trade ruled that importers do not need to immediately file lawsuits to preserve potential refunds of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The court confirmed it retains authority to order reliquidation and refunds, even after entries have liquidated, if the tariffs are later ruled unlawful. While litigation is not required at this time, importers are still advised to file protests at liquidation as a protective measure.

CBP Guidance on Switzerland & Liechtenstein Tariffs

CBP issued new guidance on December 17 implementing tariff changes under the U.S.–Switzerland–Liechtenstein Framework Agreement. The updates modify certain IEEPA “Reciprocal” tariffs and are now active in ACE. For covered products, reciprocal duties are capped at 15%, with no additional duty where Column 1 rates are 15% or higher. CBP also introduced new Chapter 99 HTSUS codes and expanded exemptions for select agricultural products, civil aircraft parts, and non-patented pharmaceutical products. These changes apply to entries on or after November 14th, 2025.

End of De Minimis Increases Enforcement

CBP also announced it has collected over $1 billion in duties since the phaseout of de minimis treatment began in May 2025, covering more than 246 million low-value shipments. Since implementation, CBP reports an 82% increase in seizures of unsafe and non-compliant goods, reflecting heightened enforcement and scrutiny of low-value imports.

Radius International Insight

These updates highlight an ongoing shift toward greater enforcement, evolving tariff frameworks, and increased compliance expectations. Radius International continues to monitor regulatory developments and assist clients with tariff strategy, classification review, protests, and entry corrections.