Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports

April 2, 2025

Executive Orders

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Action Summary

Purpose: Address deceptive shipping practices by PRC-based shippers that conceal illicit synthetic opioids within low-value imports and exploit the de minimis exemption.
Scope & Timing: Applies to products of the PRC (and Hong Kong) described in Executive Order 14195 (as amended); effective for articles entered for consumption on or after 12:01 am EDT on May 2, 2025.
Duties & Tariffs:
- For all shipments: Removal of duty-free de minimis treatment under 19 U.S.C. 1321(a)(2)(C) for covered shipments.
- For low-value shipments (≤ $800): Duties imposed include additional tariffs already specified in previous orders.
Postal Shipments:
- All international postal items from the PRC or Hong Kong are subject to special duty rates.
- Two collection options: a 30% ad valorem duty or a specific duty ($25 per package until June 1, 2025, then $50 thereafter).
Carrier Duties & Reporting:
- Carriers must collect and remit duties to CBP on a monthly or other periodic basis.
- They are required to report details of the number and value of postal items transported.
Bond Requirement: All carriers transporting relevant postal packages must hold an international carrier bond sufficient to cover the imposed duties.
Formal Entry Discretion: CBP may mandate formal entry for packages, subjecting them to all applicable duties, taxes, and fees instead of the streamlined duty process.
Implementation & Coordination:
- The Secretary of Homeland Security, in consultation with the Secretaries of Treasury, Commerce, and the Attorney General, is responsible for enforcing the order.
- Agencies, including CBP and the U.S. International Trade Commission, will take necessary regulatory actions.
Monitoring & Reporting: Within 90 days, the Secretary of Commerce, in consultation with the USTR, must report on the order’s impact on American industries, consumers, and supply chains, assessing further action needs.
Legal & General Provisions:
- Authority derives from IEEPA, the National Emergencies Act, and other statutory provisions.
- The order does not impair any executive agency authority nor create enforceable rights for private parties.

Risks & Considerations

The Executive Order imposes additional duties on low-value imports from the People’s Republic of China (PRC) and Hong Kong, which could lead to increased costs for goods and materials imported by Vanderbilt University. This may affect research projects and procurement processes that rely on such imports.
There is a risk of supply chain disruptions due to the new duties and the requirement for formal entry of certain goods. This could impact the timely availability of essential research materials and equipment.
The order may lead to increased administrative burdens as Vanderbilt University may need to ensure compliance with the new import regulations and duty requirements, potentially requiring additional resources or adjustments in procurement strategies.
Vanderbilt University should monitor the impact of these duties on its financial operations, particularly if the cost of imported goods significantly increases, affecting budget allocations for research and development.

Impacted Programs

Research Departments that rely on imported materials from the PRC or Hong Kong may face challenges in maintaining their supply chains and managing increased costs due to the new duties.
The Procurement Office may need to adjust its strategies to accommodate the new import regulations and ensure compliance with the duty requirements, potentially requiring additional training or resources.
International Collaborations with institutions in the PRC or Hong Kong may be affected by the increased costs and administrative requirements, potentially impacting joint research projects or exchanges.

Financial Impact

The imposition of additional duties on low-value imports could lead to increased costs for goods and materials, affecting the financial planning and budgeting of various departments within Vanderbilt University.
There may be a need to reallocate funds to cover the increased costs associated with the new duties, potentially impacting other areas of research and development.
Vanderbilt University may need to explore alternative sources for materials and goods to mitigate the financial impact of the new duties, which could involve additional research and negotiation efforts.

Relevance Score: 3 (The order presents moderate risks involving compliance and potential financial impacts on university operations.)

Key Actions

Vanderbilt’s Office of Federal Relations should monitor the implementation of the new duties on low-value imports from the PRC and Hong Kong. Understanding these changes will be crucial for assessing potential impacts on research materials and equipment sourced internationally, which could affect various departments.
The Department of Economics should conduct research on the broader economic impacts of these duties on the U.S. economy and supply chains. This research can provide valuable insights into how these policies affect trade dynamics and economic relations with China, potentially influencing future policy recommendations.
Vanderbilt’s Procurement Office should evaluate current supply chain practices to identify any dependencies on low-value imports from the PRC and Hong Kong. By diversifying suppliers and exploring alternative sourcing options, the university can mitigate potential disruptions and cost increases.
The Center for International Business should explore opportunities for collaboration with Chinese institutions to understand the impact of these duties on international academic partnerships. This could include joint research initiatives and exchange programs to maintain strong academic ties despite trade tensions.

Opportunities

The executive order presents an opportunity for Vanderbilt’s Law School to engage in policy analysis and advocacy regarding international trade law and its implications. By providing expert commentary and recommendations, the law school can influence the national conversation on trade policy and its legal ramifications.
Vanderbilt can capitalize on the increased focus on supply chain security by developing new programs and partnerships with logistics and supply chain management firms. This could include joint research initiatives, student internships, and collaborative curriculum development, enhancing Vanderbilt’s reputation and reach in the business sector.
The emphasis on monitoring the impact of these duties offers an opportunity for Vanderbilt’s Owen Graduate School of Management to engage in research and analysis of supply chain resilience. By providing evidence-based recommendations, the school can influence how businesses adapt to changing trade policies and enhance their operational strategies.

Relevance Score: 3 (The order presents the potential for some adjustments needed to processes or procedures at Vanderbilt due to impacts on international sourcing and supply chains.)

Average Relevance Score: 3.6

Timeline for Implementation

May 2, 2025 at 12:01 am EDT – Products entering the United States for consumption on or after this date will be subject to the new duty rules, marking the cessation of duty-free de minimis treatment for the specified PRC/Hong Kong items.
Within 90 days of April 2, 2025 – The Secretary of Commerce must submit a report on the impact of this order to the President.

Relevance Score: 4

Impacted Government Organizations

U.S. Customs and Border Protection (CBP): Tasked with processing entries via the Automated Commercial Environment (ACE) and enforcing duty collection on low‐value imports from the PRC and Hong Kong, as well as overseeing formal entry requirements.
Department of Homeland Security (DHS): Charged with overall implementation of the order and ensuring compliance through CBP and other measures.
Department of Commerce: Involved in tariff revenue oversight and required to report on the impact of the order, particularly regarding the synthetic opioid supply chain.
United States International Trade Commission (ITC): Responsible for modifying the Harmonized Tariff Schedule of the United States (HTSUS) to reflect the changes introduced by this order.
Department of the Treasury: Consulted to ensure that carriers remit the correct duty payments and that financial oversight is maintained.
Department of Justice (Attorney General): Consulted as part of interagency coordination in implementing and enforcing the order’s provisions.
United States Trade Representative (USTR): Engaged in the reporting process to assess the order’s impact on trade and supply chains.
Office of Management and Budget (OMB): Mentioned in the context of ensuring that budgetary and administrative proposals are aligned with the order’s implementation.

Relevance Score: 3 (The order impacts 8 different Federal agencies, placing the influence in the 6-10 range.)

Responsible Officials

Secretary of Homeland Security – Charged with overall implementation of the order, including adopting rules and regulations and directing CBP in enforcing entry and duty collection procedures.
U.S. Customs and Border Protection (CBP) – Responsible for executing the entry procedures, collecting duties from shipments, and enforcing regulations as outlined in the order.
Secretary of Commerce – Tasked with coordinating with the U.S. Trade Representative and submitting a report on the order’s impact to the President, as well as ensuring tariff revenue processes are in place.
United States International Trade Commission – Required to update the Harmonized Tariff Schedule to reflect the new duty structure on relevant imports.
Secretary of the Treasury and Attorney General – Included in the consultation process with the Secretary of Homeland Security to support rulemaking and implementation of this order.

Relevance Score: 5 (Directives affect high-level Cabinet officials and agency heads, with significant implications for national trade and security policy.)