---
title: "What CBP’s Feeder Vessel Update Means for In-Transit Reciprocal Tariff Provisions"
description: "CBP has clarified that feeder vessel loading dates cannot be used for IEEPA reciprocal tariff in-transit provisions. Here's what that means for importers."
language: en
canonical: https://www.flex.thisisbrew.com/blog/what-cbps-feeder-vessel-update-means-for-in-transit-reciprocal-tariff/
lifecycle: live
---

# What CBP’s Feeder Vessel Update Means for In-Transit Reciprocal Tariff Provisions

On May 15, U.S. Customs and Border Protection (CBP) provided critical [clarification](https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ#:~:text=How%20are%20feeder%20vessel%20scenarios%20impacted%20by%20the%20in%2Dtransit%20guidance%20for%20reciprocal%20entries%3F) regarding feeder vessel scenarios and in-transit provisions for IEEPA reciprocal tariffs. Per CBP’s updated IEEPA FAQs, **any U.S.-bound cargo loaded onto its final ocean vessel after the following cutoff dates (Table 1) is *****not***** eligible for the reciprocal in-transit exemption or the baseline 10% reciprocal tariff—even if the cargo departed the original port of loading *****before***** the cutoff date.** 

This means that many importers will be subject to higher duties—including retroactive duties associated with any required changes to filed entries.

**Table 1: In-Transit Provisions for Reciprocal Duties Under IEEPA (Source: CBP)**

## Qualifying for Reciprocal In-Transit Provisions

Based on yesterday’s clarification, eligibility for the reciprocal in-transit exemption and the 10% reciprocal duty rate is based on the date the cargo was loaded onto its final ocean vessel—*not* the final mode of transport itself (ocean freight), as was previously thought. As a result, importers cannot use feeder vessel loading dates to exempt themselves from reciprocal tariffs, or to qualify for the 10% reciprocal duty rate. 

Here’s a closer look at CBP’s clarification:

**Scenario A: Cargo Qualifies for the Reciprocal In-Transit Provision**

Before the cutoff date, U.S.-bound cargo is loaded onto a U.S.-bound vessel. On its way to the U.S., the vessel may stop at foreign ports to load or offload other cargo or to refuel, but the U.S.-bound cargo remains on board. 

The cargo in this situation qualifies for the relevant reciprocal in-transit provision, as it was loaded onto a U.S.-bound vessel—its “final mode of transit”—*before* the cutoff date. During its journey, the U.S.-bound cargo was not unloaded or transferred onto another vessel. 

**Scenario B: Cargo Does Not Qualify for the Reciprocal In-Transit Provision**

Before the cutoff date, U.S.-bound cargo is initially loaded onto a vessel bound for a foreign port—i.e., a feeder vessel. On or after the cutoff date, the U.S.-bound cargo is transshipped from the feeder vessel to a U.S.-bound vessel, and makes its way to its port of destination in the U.S.

The cargo in this situation does *not* qualify for the relevant reciprocal in-transit provision, given that it was loaded onto a U.S.-bound vessel—the final mode of transit—on or after the cutoff date.

## Flexport’s Guidance for Importers

With eligibility contingent upon the date of loading onto the final U.S.-bound vessel, fewer entries qualify for the in-transit exemption and baseline reciprocal tariffs. As a result, importers will have to pay more duties.

CBP is likely to challenge some dates of export on entries that have already been filed. Importers have two options:

- Agree with CBP’s assessment, and pay the higher duty rate associated with the changed date

- File a protest with CBP (Flexport’s trade advisory team will be able to support these cases)

Flexport’s trade advisory experts can help you navigate changes to your shipments and customs entries, file a protest with CBP, mitigate tariff impacts, and more. Please reach out to your account manager or [advisory@flexport.com](mailto:advisory@flexport.com) for more details. You can also calculate and analyze tariff impacts in real time with the new Flexport Tariff Simulator. [Get started here](https://tariffs.flexport.com/).

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