FAQs

US Tariffs

 

What tariffs apply to New Zealand goods exported to the US?

On 20 February, US President Trump signed Proclamation 11012(external link) that sets an additional 10% tariff on most goods entering the US. This applies in addition to the US’s standard MFN tariff under the WTO. The entered into effect from 24 February 2026 (and on 28 February 2026 for product in transit at the time). See also the Fact Sheet(external link). 

The new tariffs have been levied under Section 122 of the Trade Act of 1974(external link), and apply for a maximum period of 150 days (unless extended by Act of Congress).

For full details of which tariffs apply to any product / tariff line, refer to:
www.tariff-finder.govt.nz(external link).

Any information you feel comfortable sharing on how your business is impacted is valuable to us. Please get in touch to share this information, ask questions or share your views by emailing us.exports@mfat.govt.nz

 

The IEEPA tariffs have been removed, can I get a refund?

The court’s decision does not provide immediate clarity on the issue of refunds. The Supreme Court has referred this question to a lower court. Exporters who may be impacted should talk to their customs brokers in the first instance.

 

Are any exemptions or exceptions?

There are currently some exceptions to the 10% additional tariff:

  • Certain products not produced in sufficient amounts in the US (including some beef products and kiwifruit). See Annex I and Annex II of Proclamation 11012.
  • Products covered by other US tariff increases:
  • Some products   are currently exempt from any additional tariffs, due to ongoing investigations under Section 232 of the Trade Expansion Act of 1962(external link), listed here(external link):
    • Pharmaceuticals and pharmaceutical ingredients
    • Commercial aircraft, parts and jet engines.
    • Unmanned aircraft systems, their parts and components.
    • Polysilicon and its derivatives.
    • Wind turbines, parts and components.
    • Robotics and industrial machinery.
    • Medical Supplies.
      Please note these sectors under section 232 investigations could be subject to sectoral tariffs in future (as well as other sectors or products subject to future investigations).
  • These products, and certain other products also excluded from additional tariffs, are listed in Annex I(external link) and Annex II(external link) of Proclamation 11012(external link).
  • Goods with 20% or more value content from the US may be partially exempt (here(external link)).

 

What is tariff stacking?

Tariff stacking means multiple duties are applied sequentially to the same product - often without caps - significantly increasing the total landed cost.

For example, a New Zealand origin product may face: 

  • a Most Favoured Nation (MFN) tariff (e.g. 3.5%);
  • the additional 10% Section 122 tariff; 
  • For certain metals products, a sector-specific tariff (e.g. 50%), only on the metal content); and
  • anti-dumping or countervailing duties, if applicable.

 

Are the 10% tariffs additional to the section 232 sectoral tariffs?

Products covered by US sectoral tariffs, such as steel products(external link) and their derivatives and aluminium products(external link) and their derivatives are not subject to a 10% s122 tariff on any metal content, as they already face a separate section 232 additional tariff.  But the 10% additional tariff applies to non-metal content of the product. 

US Customs and Border Protection has released further guidance, including:

Please note that under the section 232 regime: 

  • Products imported into the US on specified tariff lines containing steel, aluminium and copper derivatives are now subject to a 50% tariff on the value of the metal content, on top of any existing MFN tariffs. 
    The remainder of the product’s value will be subject to the 10% Section 122 tariff, on top of any existing MFN tariffs.

MFAT’s Tariff Finder(external link) has been updated to reflect the above.

 

How do I calculate what tariff I pay for section 232 tariffs on steel and/or aluminium?

NZTE has published some guidance(external link) on how exporters might want to approach export documentation to help ensure they are not being overcharged.

 

What are trans-shipment charges and how do they apply?

Trans-shipment charges may apply if goods are routed through a third country (here(external link)).

 

Do I still pay tariffs if I have a US entity?

Yes. Tariffs apply regardless of importer’s identity as tariffs are imposed based on the goods’ origin.

Goods shipped from NZ to a US-based subsidiary are still subject to the same tariffs. 

 

Do any of the US announcements on tariffs apply to services or digital exports?

The US tariff announcements do not apply to services trade.

 

Where can I find out what tariffs the US is charging?

For full details of which tariffs apply to any product / tariff line, refer to: www.tariff-finder.govt.nz(external link). 

 

How do I identify the correct HS code for my product?

Consult the US Harmonized Tariff Schedule (HTS) database(external link).

  • The first 6 digits are global; the last 4 are US-specific.
  • Choose the code that best reflects your product’s essential character, material composition, function, and intended use.
  • If multiple codes seem applicable, choose the most specific one. Use the “essential character” test if the product is a composite or set. If still unclear, apply the “last in order(external link)” rule as a fallback.

Mis-classification can trigger serious consequences, including: underpayment or overpayment of duties; shipment delays or holds at the border; and penalties or enforcement actions by US Customs and Border Protection (CBP).

CBP may reclassify your goods, apply retroactive duties, and require payment of any shortfall, potentially with interest and penalties(external link).

 

Where can I get help with HS codes?

Use the USITC HTS search tool(external link) (here) or CBP’s CROSS database(external link).

Consult a US customs broker or trade lawyer for complex products.

You can request a binding ruling from CBP(external link).

 

Where does the US publish all these documents?

Executive Orders and Proclamations usually appear on the White House website(external link) first. Some are accompanied by a ‘Fact Sheet(external link)’. 

Executive Orders are subsequently published on the Federal Register(external link). 

US Customs and Border Protection’s (US CBP) webpage(external link). 

 

What is the US’ approach to country of origin when inputs from multiple countries are involved?

US Customs and Border Protection (CBP) is the US agency responsible for determining the country of origin of items imported into the US.  CBP uses non-preferential rules of origin (ROO) to determine the origin of goods imported from countries with which the United States has most-favoured-nation (MFN) status. A key principle used in non-preferential ROO cases is "substantial transformation(external link)," where multiple countries are involved in the supply chain of a product which means the country in which the last substantial manufacturing or processing, deemed sufficient to give the commodity its essential character took place.

A product is considered substantially transformed if the processing results in:

  • a new character – its physical or chemical properties have changed.
  • a new use – it serves a different commercial purpose than before.
  • a new name – it is now described differently in trade or customs terms.

Since no US laws specifically govern non-preferential ROO, these determinations are made by CBP primarily on a case-by-case basis using CBP's own rules and precedents.

More information can be found in this NZTE article(external link).

 

What documentation is needed to prove origin?

Maintain detailed records, including: bills of materials, production and processing records, supplier invoices and sourcing documentation, contracts or purchase orders showing where and how goods were made.

A New Zealand Country of Origin Certificate(external link) helps evidence origin but is not binding on CBP.

 

What changes has the US made to de minimis tariff exemption for low-value shipments?

The US suspended duty-free de minimis treatment for all countries since 29 August 2025. This means shipments of low value/de minimis goods from New Zealand, and all other countries, valued under US$800, are no longer eligible to enter the US duty free. 

For details, see Executive Order 14388(external link) (which modified Executive Order 14324, first issued in July 2025): 

  • The tariff applied to low-value goods sent through regular post will 10% (section 122 tariff).
  • The tariff applied to low-value goods sent through other forms of transport will be the US’s standard MFN tariff + any other applicable tariff (either 10% section 122 tariff, or any applicable section 232 or section 301 tariff)

The removal of the de minimis exemption impacts direct-to-consumer e-commerce models, potentially increasing costs and customs clearance times. Some products may now need FDA approval to be entered for consumption in the US. 

Exemptions remain in place for gifts valued at less than US$100.

NZ Post has resumed sending items by post to the US for most businesses. See more detail in NZ Post’s Press Release(external link).

Businesses can now send to the US, with Economy, Economy Tracked, Economy Plus, Courier and Express services in addition to a new sending service(external link) for business customers to the US. Letters sent via economy and letters and documents sent via express are unchanged. 

Gifts under NZD $150 can be sent via Economy, Courier or Express without being subject to taxes and duties, when using a digital customs form. 

More information on the suspension of de minimis and what it means for e-commerce businesses is available on the US Customs and Border Protection website(external link), and further information on the changes for NZ Post users is available in the FAQs section on its website(external link).

 

My product will have a tariff applied. Who can I talk to?

NZTE has established Talking Tariffs(external link) – which includes information, resources, and events to help exporters understand what these changes mean for their business. Additionally, exporters can also register any other trade barriers experienced when exporting to MFAT’s Trade Barriers website(external link), or contact MFAT for support via the Exporter Helpline (0800 924 605) or at us.exports@mfat.govt.nz. We also encourage exporters to sign up to our Market Intelligence Reports(external link) for updates on developments in international trade.

 

How is the US calculating the tariffs?

  • US Customs and Border Protection (CBP) Information Article number 000001126 from 2024 states:
    “Duty is not assessed on Cost Insurance Freight (CIF) charges. U.S. Customs and Border Protection (CBP) value is determined based on the "Price Paid" or "Payable" for the goods, which is usually on the bill of sale or invoice and bill of lading as the Freight On Board (FOB) price. 
    The CIF price, which is the price paid for the goods including freight and insurance, is not the value to declare for CBP purposes.”
  • Therefore, as far as we are aware, the 10% tariff being an ‘ad valorem’ rate, will be calculated on the FOB sale price of the goods – that is the price just for the goods in a state ready to be exported, with all international freight etc excluded.  Freight costs are not subject to this tariff, but will still be subject to any other taxes that they are currently subject to, such as Federal taxes.
  • For this reason, exporters who invoice on a CIF or CFR basis may find it beneficial if their invoicing clearly delineates between the cost of the goods and the cost of the freight/insurance.
  • CBP’s detailed guidance is here.

 

Who pays the tariff when exporting to the US?

Tariffs are usually paid by the Importer of Record (IOR) identified according to contract terms, Incoterms, and customs responsibilities.

The IOR can contractually pass tariff costs to another party - often the exporter - via pricing or cost-sharing clauses.

Exporters should review contracts to confirm who bears the tariff burden.

 

What is a section 232 investigation, and what ones are currently under way?

  • A Section 232 trade investigation is conducted under the Trade Expansion Act of 1962(external link) to determine whether imports of certain goods threaten national security. The investigation is initiated by the Secretary of Commerce and includes a comprehensive review of factors like overcapacity, dumping, and illegal subsidies. If the investigation finds that imports pose a threat, the President can impose tariffs or other trade restrictions to protect national security. 
  • The Act specifies that Section 232 investigations must be completed, and a report submitted to the President within 270 days of the investigation being initiated. 
  • There are currently a number of section 232 investigations under way(external link):
    • Pharmaceuticals and pharmaceutical ingredients
    • Commercial aircraft, parts and jet engines. 
    • Unmanned aircraft systems, their parts and components.
    • Polysilicon and its derivatives. 
    • Wind turbines, parts and components.
    • Robotics and industrial machinery.
    • Medical Supplies.

Please note these sectors under section 232 investigations could be subject to sectoral tariffs in future (as well as other sectors or products subject to future investigations).

 

Are any countries exempt from tariffs?

  • Certain goods from Mexico and Canada are exempt from all tariffs, if they meet USMCA rules of origin requirements. 
  • Canadian and Mexican goods traded outside the Agreement (i.e. do not qualify under the USMCA Rules of Origin or do not claim the USMCA preference) are subject to the additional section 122 tariffs (like New Zealand) on top of the US’s standard ‘MFN’ tariff. 
  • Mexican and Canadian products remain subject to sectoral tariffs, including for autos and auto parts, steel and aluminium and their derivatives; and copper and derivatives. 
  • Certain textiles products from Parties to the Dominican Republic-Central America FTA (CAFTA-DR: Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, and the Dominican Republic) are also exempt from tariffs if they meet the requirements of the DR-CAFTA agreement.
  • These exemptions are specified in Annex I(external link) of Proclamation 11012(external link).

 

Has the US put tariffs on movies made outside of the US?

No, there are currently no tariffs on movies made outside of the US. 

 

Where can I find information about other deals?

Many details of the US deals are yet to be published, but we regularly publish updates through our Market Intelligence reports, you can sign up here(external link). Alternatively, you can send us a questions at us.exports@mfat.govt.nz

What is a trade barrier?

Trade barriers take many forms, and may differ depending on whether you export goods or services. A trade barrier is any rule, administrative procedure or other government intervention that makes it slow, costly or difficult to export to a particular market. Sometimes trade barriers exist for good reasons - for example, regulations that protect public health or the environment.

In other cases, we may be able to reduce, resolve, or prevent barriers, especially where rules:

  • are not transparent or clear
  • are overly restrictive
  • are unevenly applied or have been introduced to unfairly advantage local industries
  • are inconsistent with trade rules

What are some examples of common trade barriers?

Common examples include:

  • customs procedures
  • requirements for goods to be locally produced
  • requirements to use local assets, components or workers
  • quantity restrictions (such as quotas)
  • difficulty enforcing international rules and regulations
  • poor protection of intellectual property rights
  • licensing requirements
  • limitations on access to key infrastructure
  • restrictions on foreign entry or movement of people
  • data storage requirements
  • privacy requirements
  • local presence requirements
  • taxes that favour domestic over foreign firms
  • restrictions on investment
  • qualification requirements
  • price controls
  • requirements about company directors
  • procurement rules
  • subsidies
  • product labelling requirements
  • testing, inspection and certification procedures
  • sanitary, phytosanitary or technical regulations and standards.

How long will it take for my enquiry to be addressed?

We aim to provide an initial response to each enquiry within 48 hours. The timeframe for tackling the particular trade barrier that you have identified will depend on the type of trade barrier and also on the willingness of the trade partner to resolve it. Some trade barriers can be resolved very quickly, while others can take many years to overcome. Occasionally, despite New Zealand’s best efforts, a trade barrier cannot be resolved.

I need assistance with my commercial strategy offshore, can you help me?

The Trade Barriers Helpdesk has been set up to deal with governmental barriers to trade. However, New Zealand Trade & Enterprise (NZTE) helps New Zealand businesses to grow internationally by providing access to market knowledge, resources and connections, as well as connections to investors and partners for growth.  NZTE can be contacted via their website.

Which agencies are involved in handling my enquiry?

The Trade Barriers Helpdesk is jointly operated by the Ministry of Foreign Affairs and Trade, Ministry of Business Innovation & Employment, Customs, Ministry for Primary Industries, Education New Zealand, and New Zealand Trade & Enterprise. Once we have examined the particular details of your enquiry, we will determine which of our agencies is best placed to assist you.

What happens to my personal data and confidential information?

Our data privacy statement explains how we will use your personal data and confidential information.

Does the Trade Barriers Helpdesk service cost me anything?

The Trade Barriers Helpdesk is completely free to use, and there is no limit on the number of times you can use it.