U.S.–Switzerland–Liechtenstein Tariff Updates

Overview

The United States Trade Representative (USTR) and the Department of Commerce have implemented tariff modifications under the U.S.–Switzerland–Liechtenstein Framework Agreement. These changes are outlined in Federal Register Notice FRN 2025 23316 and apply retroactively to goods entered for consumption or withdrawn from warehouse on or after November 14, 2025.

Key Changes

• Tariff Structure: 
  • U.S. duties on most goods from Switzerland and Liechtenstein will now be the greater of the MFN rate or a flat 15% tariff.
• Zero-Duty Categories: 
  • Certain agricultural products, natural resources, aircraft and parts, and generic pharmaceuticals/chemical precursors may qualify for 0% reciprocal tariffs under Annex I.
• Retroactive Application: 
  • Applies to entries on or after November 14, 2025.
• Review Trigger: 
  • If a full agreement is not finalized by March 31, 2026, the U.S. reserves the right to review and revise these interim tariffs. 

Applicability

The adjustments apply to specific HTS codes, grouped under two annexes: 

• Annex I: Over 300 distinct 10-digit HTSUS entries. HTSUS subheadings for products exempt from reciprocal tariffs (e.g., select agricultural goods, live animals, natural resources, aircraft parts, and generic pharmaceuticals/precursors).
• Annex II: All entries under HTSUS headings 9903.01.25–9903.01.76 and 9903.02.01–9903.02.71, covering dozens of subheadings. Details HTS modifications under Chapter 99, Subchapter III (headings 9903.01.xx and 9903.02.xx), implementing the “higher of MFN or 15%” tariff structure.

Strategic Rationale

The USTR emphasized that these measures aim to:

• Remove longstanding trade barriers impacting U.S. exporters.
• Promote reciprocal trade and correct imbalances.
• Attract investment projected to generate billions in U.S. economic activity and thousands of jobs.

Action Steps for Clients

• Review import portfolios for goods subject to these HTSUS headings.
• Update HTS classifications in ACE to reflect new duty rates.
• Check eligibility for zero-duty categories under Annex I.
• Monitor developments toward the full agreement and anticipate potential revisions after March 31, 2026.
• Consider Post Summary Corrections for refund claims for entries between November 14 and today.

Reach out to the Crane Worldwide Trade Advisory to help navigate these changes.