Executive Summary: On September 25, 2025, the U.S. administration under President Trump announced a significant expansion of import tariffs, set to take effect on October 1, 2025. These measures build on prior trade actions and target key sectors including consumer goods, industrial equipment, and pharmaceuticals. While the pharmaceutical tariffs (up to 100%) include exemptions for U.S.-based manufacturing and may have limited relevance for many of our clients, the duties on furniture, cabinets, and heavy trucks—primarily sourced from Asia—pose immediate challenges for importers and exporters alike.

Key Tariffs at a Glance

1. Cabinets/Vanities: 50% – Hits wood imports hard.
2. Upholstered Furniture: 30% – Broad scope for textiles/upholstery.
3. Heavy Trucks: 25% – National security angle; components included.
4. Pharma: 100% – Mostly irrelevant for our manufacturing clients but watch for exemptions.

These tariffs invoke Section 232 of the Trade Expansion Act, citing national security concerns for trucks and broader protectionism for consumer products. The short lead time—mere days—underscores the administration’s aggressive stance on “America First” policies, potentially pressuring foreign producers to relocate operations domestically.

Why These Products? Strategic and Political Context

The selection reflects a blend of economic protectionism and geopolitical signaling:

• U.S. Industry Safeguards: Domestic producers of cabinets, vanities, and furniture claim unfair competition from low-cost Asian imports, which have “flooded” the market. Heavy trucks tie into infrastructure investments like the Bipartisan Infrastructure Law.
• National Security Pretext: Section 232 provides expansive authority, historically used for steel and aluminum, now extending to vehicles critical for logistics and defense.
• Electoral Timing: With visible impacts on everyday consumer items, these tariffs amplify protectionist messaging ahead of policy cycles, while incentivizing foreign investment in U.S. facilities—mirroring exemptions in the pharmaceutical sector.

Disproportionate Effects on Asian Supply Chains

Asian economies, long central to U.S. imports in these categories, face the brunt:

• China: As the top exporter of wood furniture and cabinets, ongoing shifts under “China+1” strategies will accelerate, but new duties exacerbate existing pressures from prior rounds.
• Vietnam: A rising star in furniture production, its exports (valued at billions annually) are now squarely targeted, potentially reversing recent gains.
• Cambodia: Highly vulnerable due to heavy reliance on U.S. markets (58% of exports), Cambodia’s furniture sector—including upholstered seats and wooden items—faces severe contraction, with forecasts of up to 23.9% drop in U.S.-bound shipments and potential loss of over half its U.S.-oriented exports overall.

Example: Tariff Stacking for Upholstered Furniture from Cambodia

As an example, upholstered furniture (HTS 9401.61) exported from Cambodia:

• The new tariff announced is 30% on upholstered furniture.
• There is already a base U.S. “reciprocal tariff” or other general tariff structure in place (e.g., the 19% rate finalized on Cambodian goods in August 2025 following a universal tariff reset), then that base rate might still apply.
• If there are no special or additional duties already on that line of furniture from Cambodia, then likely the 30% is the effective additional duty. However, under Section 232 authority, these new tariffs generally stack with existing duties like reciprocal tariffs.

So, if stacking is allowed and there is an existing duty, for example:

• With the 19% base reciprocal tariff in place for Cambodian imports, upholstered furniture from Cambodia might face 19% + 30% = 49% total. But for every product we will have to check the HTD codes covering the product, whether there is an explicit order regarding stacking, and whether a specific country is subject to other prior measures (AD, CVD).

Actionable Strategies for Compliance and Mitigation

Our tariff counseling team recommends a phased approach to safeguard your operations. Below, we outline immediate, near-term, and long-term tactics, grounded in U.S. Customs and Border Protection (CBP) regulations.

Immediate Strategies (Pre-October 1)

• Shipment Acceleration: Prioritize in-transit goods to clear U.S. ports before the deadline. For high-value items, consider expedited air shipping to lock in pre-tariff rates.
• HTS Code Audits: Conduct urgent reviews of Harmonized Tariff Schedule classifications. Subtle differences in coding (e.g., for modular vs. assembled cabinets) can yield lower duties—our firm has successfully challenged misclassifications in similar cases.
• Duty Mitigation Tools: Leverage bonded warehousing to defer payments or duty drawback programs for re-exportable goods, reclaiming up to 99% of duties paid.

Near-Term Strategies (3–6 Months)

• Origin Engineering: Restructure supply chains for “substantial transformation” in non-targeted countries (e.g., final assembly in Mexico or India). Robust documentation is essential to withstand CBP audits.
• Trans-Shipment Caution: Steer clear of superficial rerouting through third countries without value addition—penalties for evasion can exceed 300% of duties owed.
• Contractual Safeguards: Renegotiate with U.S. buyers for shared tariff burdens via force majeure clauses or price escalation terms.

Longer-Term Strategies

• Geographic Diversification: Expand into ASEAN+ markets or non-U.S. destinations like the EU to dilute reliance on American sales.
• U.S. Localization: Explore joint ventures or limited domestic assembly to qualify for exemptions, as signaled in the pharmaceutical carve-outs.
• Policy Monitoring: Stay ahead of retaliatory actions from affected nations, which could impact U.S. exports.

In summary, while these tariffs demand swift action, they also present opportunities for resilient supply chain redesign. Forum law can assist and guide clients through strategy, audits, negotiations, and restructuring. Let’s turn compliance into competitive advantage.

US-ASEAN Tariff Tracker

DFDL’s Trade & Tariffs Group monitors the latest U.S. reciprocal tariffs and their impact across ASEAN markets.
Stay informed on key trade developments and policy shifts — download the latest US-ASEAN Tariff Tracker below.

*This Client Alert is for informational purposes only and does not constitute legal advice. Specific advice should be sought for your particular circumstances.*

Key Contacts

David Doran, Founding Partner, Head of Thai Practice

Melissa Welebir Kuhn, Of Counsel