CBP issued Harmonized System Update 2541 for Brazil and China IEEPA tariff changes
CBP title: Harmonized System Update (HSU) 2541
This message is from December 5, 2025. Later CSMS messages may have changed it. See the latest trade news
What did CBP announce?
CBP announced Harmonized System Update (HSU) 2541, created November 21, 2025, containing three Harmonized Tariff records and seven ABI records. The update implemented changes from a Brazil IEEPA Reciprocal Executive Order and a China IEEPA Reciprocal Executive Order addressing the synthetic opioid supply chain. CBP directed questions to its trade remedy and HTS Administrator mailboxes.
What is Allied's position?
At the time, this update changed the tariff and ABI data filers used for entries involving Brazil and China IEEPA duties. The Supreme Court later ruled in Learning Resources, Inc. v. Trump that IEEPA does not authorize tariffs, and Executive Order 14389 ended IEEPA duties on February 20, 2026, so these specific rate changes no longer apply. Clients with entries from this period who paid these duties should ask us to review whether a CAPE Declaration refund applies to their entries.
General information, not legal advice.
What does the CBP message say?
The Harmonized System Update (HSU) 2541 was created on November 21, 2025. It contains three Harmonized Tariff records and seven ABI records.
HSU 2541 contains the updates pursuant to the recent Brazil IEEPA Reciprocal Executive Order https://www.whitehouse.gov/presidential-actions/2025/11/modifying-the-scope-of-tariffs-on-the-government-of-brazil/ and the updates pursuant to the China IEEPA Reciprocal Executive Order https://www.whitehouse.gov/presidential-actions/2025/11/modifying-duties-addressing-the-synthetic-opioid-supply-chain-in-the-peoples-republic-of-china/.
Questions regarding these updates should be directed to traderemedy@cbp.dhs.gov (mailto:traderemedy@cbp.dhs.gov).
Questions or concerns with this Harmonized System Update should be directed to the HTS Administrator at HTSadmin@cbp.dhs.gov (mailto:traderemedy@cbp.dhs.gov).