When Do New Tariff Rates Start for Chinese Imports?

The Language Surrounding "Consumption" and Why it Matters

Today is the day to “enter for consumption” and “withdrawn from warehouse for consumption.”

Not familiar with these terms? There is no better time than now to learn what they mean.

In U.S. trade law, tariffs are assessed based on the date goods enter the United States for consumption, not when they are shipped from the origin country. This principle is essential for importers navigating changing trade policy, as seen in the U.S.-China reciprocal tariff reductions on Monday, May 11th, formalized by an executive order on Tuesday, May 12th.

That executive order, titled “Modifying Reciprocal Tariff Rates to Reflect Discussions with the People’s Republic of China”, specified that reduced tariff rates would be “effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on May 14, 2025.”

This language matters. In a nutshell, here is how to distinguish these designations:

• “Entered for consumption” means the date when goods arrive at a U.S. port and are formally declared for entry into the market (i.e., when duties are assessed).

• “Withdrawn from warehouse for consumption” refers to goods previously stored in a bonded warehouse; these are not assessed duties until the date they are released into U.S. commerce.

The effective time of 12:01 a.m. EDT on May 14 establishes a clear legal cutoff. Goods entered or withdrawn before that time are subject to the now old- and higher- tariff rates, while those entered or withdrawn on or after that time benefit from the reduced rates.

This distinction highlights the importance of timing and documentation in customs compliance. For example, if entry was filed before arrival in the U.S., then the vessel arrival date is the “entered for consumption” date.

Conversely, if the entry documentation was filed after vessel arrival, then the “entered for consumption” date is the date that the entry documentation is submitted.

The saying goes that to thrive, a business needs a strong accountant and attorney. Add a customs broker to the adage! For shippers, the value of a customs broker has never been more evident than today.