US Customs Issues Guidance on Reciprocal Tariff Changes for Switzerland and Liechtenstein Under New Trade Framework

The U.S. Customs and Border Protection (CBP) has issued detailed guidance to implement tariff-related elements of the Framework for a United States–Switzerland–Liechtenstein Agreement, pursuant to Executive Order 14346. The guidance follows a Federal Register Notice published on December 18, 2025, and applies to imports entered on or after 12:01 a.m. ET on November 14, 2025.

Key points:

· Reciprocal tariff structure revised:

o For covered products of Switzerland or Liechtenstein with a Column 1 duty rate ≥ 15%, the additional Reciprocal tariff is 0%.

o Where the Column 1 duty rate is < 15%, the combined Column 1 plus Reciprocal tariff is capped at 15% ad valorem, using newly specified HTSUS Chapter 99 headings.

· Specific/compound duties:

o For products subject to specific or compound duties, an ad valorem equivalent must be calculated to determine whether the 15% threshold is met.

· New exemptions introduced:

o Certain agricultural goods, unavailable natural resources, generic pharmaceuticals and inputs, and civil aircraft and related parts from Switzerland or Liechtenstein are now fully exempt from Reciprocal tariffs, subject to specific HTSUS Chapter 99 provisions and documentation requirements.

· Obsolete headings withdrawn:

o HTSUS headings 9903.02.36 and 9903.02.58 are no longer valid for entries after November 13, 2025.

· Entry filing and duty reporting:

o CBP reiterates strict sequencing rules for reporting multiple HTSUS classifications and requires duties to be correctly associated with each applicable HTSUS number. Duties may not be combined across classifications.

· Corrections and refunds:

o Importers may file post-summary corrections (PSC) for unliquidated entries to obtain refunds, or protests within 180 days for liquidated entries, where excess duties were paid.

· Drawback eligibility:

o Reciprocal tariffs imposed under Executive Order 14257, as amended, remain eligible for drawback.

CBP indicated that further clarification will be issued through CSMS messages as needed and advised importers and filers to consult updated HTSUS provisions for complete details.

[ABS News Service/18.12.2025]

Implementation of Tariff-Related Elements of the Framework for a United States-Switzerland-Liechtenstein Agreement

Executive Order (EO) 14346, “Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreements” signed on September 5, 2025, directed and authorized the Secretary of Commerce (Commerce), the Secretary of Homeland Security, and the United States Trade Representative (USTR) to take all necessary actions to implement and effectuate EO 14346. EO 14346 further directed Commerce and USTR to determine whether the United States must take any action to implement a final trade and security framework agreement between a foreign trading partner and the United States, including any necessary modifications to the Harmonized Tariff Schedule of the United States (HTSUS) through notice in the Federal Register.

On November 14, 2025, the United States, Switzerland, and Liechtenstein announced a Framework to negotiate an Agreement on Fair, Balanced, and Reciprocal Trade (“the Framework”), and have agreed to the modification of certain tariff rates. On December 17, 2025, a Federal Register Notice (FRN), “Implementing Certain Tariff-Related Elements of the Framework for a United States–Switzerland–Liechtenstein Agreement on Fair, Balanced, and Reciprocal Trade” was posted for public inspection in the Federal Register, with a scheduled publication date of December 18, 2025. The guidance below is based on this FRN which includes modifications to the International Emergency Economic Powers Act (IEEPA) tariffs (specifically, the “Reciprocal” tariffs imposed pursuant to Executive Order 14257 of April 2, 2025, as amended) applicable to certain imported articles that are products of Switzerland and certain imported articles that are products of Liechtenstein.

The modifications have been deployed in the Automated Commercial Environment (ACE). Filers can update previously filed entries in line with these changes per the directions below.

Importers and filers are reminded to refer to the updates in the HTSUS for the complete changes.

Changes to Reciprocal Tariffs

The Reciprocal tariffs for covered products of Switzerland and covered products of Liechtenstein, entered for consumption or withdrawn from warehouse for consumption on or after 12:01 eastern time November 14, 2025, are dependent on the Column 1 ad valorem (or ad valorem equivalent) duty rate applicable.

· For a covered product of Switzerland with a Column 1 duty rate greater than or equal to 15 percent ad valorem, the additional Reciprocal tariff is zero (0). Use heading 9903.02.82.

· For a covered product of Switzerland with a Column 1 duty rate less than 15 percent ad valorem, the combined Column 1 and additional Reciprocal tariff rate is 15 percent ad valorem. Use heading 9903.02.83.

· For a covered product of Liechtenstein with a Column 1 duty rate greater than or equal to 15 percent ad valorem, the additional Reciprocal tariff is zero (0). Use heading 9903.02.87.

· For a covered product of Liechtenstein with a Column 1 duty rate less than 15 percent ad valorem, the combined Column 1 and additional Reciprocal tariff rate is 15 percent ad valorem. Use heading 9903.02.88.

For any covered product of Switzerland or Liechtenstein that is subject to a specific or compound rate of duty under column 1-General, the ad valorem equivalent rate of duty for such product is determined by dividing the amount of duty payable under Column 1-General by the customs value of the product. For example, if a product is subject to a specific duty of 50 cents per kilogram, and one kilogram of the product is entered with a customs value of $10, then the ad valorem equivalent rate of duty would be obtained by dividing 50 cents by $10, yielding 5 percent ad valorem.

When submitting an entry summary to declare the 15 percent ad valorem duty on imports that are products of Switzerland or Liechtenstein, file using the appropriate HTSUS heading listed above followed by the appropriate classification under Chapter 1 to 97, HTSUS. Report the 15 percent ad valorem duty on heading 9903.02.83 for covered products of Switzerland and on heading 9903.02.88 for covered products of Liechtenstein and report the entry summary line value and 0 duty on the Chapter 1-97 HTSUS classification.

Reciprocal tariffs, pursuant to Executive Order 14257, as amended, continue to be eligible for drawback.

Headings 9903.02.36 and 9903.02.58 are no longer in use after November 13, 2025.

New Reciprocal Tariff Exemptions for Certain Products

Certain products, including certain agricultural goods, unavailable natural resources, generic pharmaceuticals and their ingredients and chemical precursors, and articles of civil aircraft that are products of Switzerland or of Liechtenstein are no longer subject to Reciprocal tariffs, effective for such products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time November 14, 2025. Use the following headings to declare these exemptions, as applicable:

9903.02.84: A product of Switzerland that are certain agricultural products or unavailable natural resources, as provided for in subdivision (v)(xxiv)(b) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS

9903.02.89: A product of Liechtenstein that are certain agricultural products or unavailable natural resources, as provided for in subdivision (v)(xxiv)(b) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS.

9903.02.85: A product of Switzerland that are articles of civil aircraft (all aircraft other than military aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components, excluding unmanned aircraft, that otherwise meet the criteria of General Note 6 of HTSUS (Articles Eligible for Duty-Free Treatment Pursuant to the Agreement on Trade in Civil Aircraft), and are classified in the HTSUS classifications listed in subdivision (v)(xxiv)(c) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS, but regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub-column.

9903.02.90: A product of Liechtenstein that are articles of civil aircraft (all aircraft other than military aircraft); their engines, parts, and components; their other parts, components, and subassemblies; and ground flight simulators and their parts and components , excluding unmanned aircraft, that otherwise meet the criteria of General Note 6 of HTSUS (Articles Eligible for Duty-Free Treatment Pursuant to the Agreement on Trade in Civil Aircraft), and are classified in the HTSUS classifications listed in subdivision (v)((xxiv)(c) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS, but regardless of whether a product is entered under a provision for which the rate of duty “Free (C)” appears in the “Special” sub-column.

9903.02.86: A product of Switzerland that are non-patented articles for use in pharmaceutical applications, classified in the subheadings enumerated in subdivision (v)(xxiv)(d) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS, but regardless of whether a product is entered under a provision for which the rate of duty “Free (K)” appears in the “Special” sub-column.

9903.02.91: A product of Liechtenstein that are non-patented articles for use in pharmaceutical applications, classified in the subheadings enumerated in subdivision (v)(xxiv)(d) of U.S. note 2 to subchapter III of chapter 99 of the HTSUS, but regardless of whether a product is entered under a provision for which the rate of duty “Free (K)” appears in the “Special” sub-column.

Filers should ensure that all supporting documentation that substantiate proof that the products are non-patented articles for use in pharmaceutical applications are kept on file for recordkeeping purposes.

Exemptions from Reciprocal Tariffs
Beyond the changes explained above, all other aspects of the Reciprocal tariffs remain in effect for products of Switzerland and products of Liechtenstein, including the exemptions from the Reciprocal tariffs that are provided for products covered by HTSUS headings 9903.01.30, 9903.01.31, 9903.01.32, 9903.01.33, 9903.01.34 and 9903.02.78.

HTSUS Sequence and Duty Reporting
For entry summary lines that include multiple HTSUS numbers, CBP requires that the duty be appropriately associated to the correct HTSUS number. Duties across several required HTSUS numbers on a given entry summary line must not be combined and cannot be reported on only one HTSUS number within the entry summary line.

For entry summary lines including multiple HTSUS secondary classifications (in addition to the Chapter 1-97 primary classification), the following sequence must be followed.

1. Chapter 98 classification (if applicable)

2. Chapter 99 classification(s) for additional duties (if applicable)

3. For trade remedies, if applicable

· First report the Chapter 99 classification for Section 301,

· Followed by the Chapter 99 classification for IEEPA Fentanyl,

· Followed by the Chapter 99 classification for IEEPA Reciprocal,

· Followed by the Chapter 99 classification for Section 232 or 201 duties,

· Followed by the Chapter 99 classification for Section 201 or 232 quota.

4. Chapter 99 classification(s) for REPLACEMENT duty or other use, e.g., Miscellaneous Tariff Bill (MTB) or other provisions (if applicable). Please note replacement duty for the purposes of IEEPA or Section 232 are to be included in #3 above.

5. Chapter 99 classification for other quota (not covered by #3) (if applicable)

6. Chapter 1 to 97 primary classification for the commodity tariff

The entered value of the commodity covered by the entry summary line should be reported on the Chapter 1-97 subheading, except if Chapter 98 reporting provisions require the entered value to be reported differently.

Previously Filed Entries

Filers should take action to correct previously filed entries as necessary to reflect the modified duty rate applicable under the HTSUS provisions above as soon as possible. For unliquidated entries for which estimated duties have already been deposited, importers may file a post summary correction (PSC) to request a refund. Upon PSC approval, the refund will be issued at liquidation. For liquidated entries, importers may request a refund by filing a protest within 180 days after liquidation in accordance with 19 U.S.C. 1514.

CBP will provide additional guidance to the trade community through CSMS messages as appropriate.