Annex II and the Reciprocal Tariff: Which Goods Were Exempt, and When

Whether a product paid the reciprocal tariff often came down to one question: was its HTS code on Annex II on the date it entered?

April 2025: the original list

Executive Order 14257 exempted, through Annex II, categories including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products. Goods subject to Section 232 steel, aluminum, and auto duties were excluded separately, and goods with at least 20 percent U.S. content were treated differently.

April 11, 2025: electronics

CBP issued guidance excluding smartphones, computers, semiconductors, and certain other electronics from the reciprocal tariff, applied back to April 5, 2025.

September 8, 2025: revisions

An order effective September 8, 2025 added bullion, certain critical minerals, and pharmaceuticals under Section 232 investigation, and removed items including aluminum hydroxide, certain resins, and silicones. It also created a new list of goods eligible for reduced rates under trade agreements.

November 13, 2025: agricultural products

An order exempted farm products including coffee, tea, tropical fruits and juices, cocoa, spices, bananas, oranges, tomatoes, and beef from the reciprocal tariff for goods entered on or after November 13, 2025.

What this means for importers

A product exempt on one date may have paid reciprocal duty on another. Check each HTS code against the list in effect when the entry was made. Annex II applied to the reciprocal tariff, not to separate IEEPA duties such as those on China, Canada, Mexico, Brazil, or India.

General information, not legal or customs advice. Facts last reviewed September 24, 2026. Confirm dates and options for your entries with a licensed professional.