Executive summary

The United States (US) Department of Commerce and the Office of the US Trade Representative (USTR) published a notice (USTR Notice) in the Federal Register on 18 December 2025, implementing certain tariff-related elements of a trade framework between the United States, Switzerland and Liechtenstein. The USTR Notice modifies the Harmonized Tariff Schedule of the United States (HTSUS) to apply, for products from Switzerland or Liechtenstein, the higher of either the US most-favored-nation (MFN) rate or a total rate of 15% composed of the MFN duty plus a country-specific International Emergency Economic Powers Act (IEEPA) tariff.

Certain products from Switzerland and Liechtenstein are exempt from the country-specific IEEPA tariff under the Potential Tariff Adjustments for Aligned Partners Annex identified in Annex I of the USTR Notice. Products cited include certain agricultural goods, unavailable natural resources, aircraft and aircraft parts, generic pharmaceuticals and their ingredients and chemical precursors.

The HTSUS modifications in Annex II apply to goods entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 a.m. Eastern Time on 14 November 2025.

If a final trade agreement is not successfully negotiated by 31 March 2026, the United States will review and reconsider these modifications.

Further, US Customs and Border Protection (CBP) released CSMS # 67133044 on 17 December 2025, providing additional guidance for importers consistent with the USTR Notice.

Background

Executive Order 14346 (5 September 2025) authorized the Secretary of Commerce and the USTR to implement current or forthcoming trade and security framework agreements, including by modifying US tariffs through a Federal Register notice, in line with Executive Order 14257 (2 April 2025). Consistent with that authority, the agencies have determined tariff modifications for products from Switzerland and Liechtenstein pursuant to the Framework announced on 14 November 2025. (For background, see EY Global Tax Alert, US announces new trade frameworks and expanded agricultural tariff exclusions, dated 17 November 2025.)

Overview of tariff modification for products originating in Switzerland or Liechtenstein

If the Column 1 General MFN duty rate is less than 15%, an additional IEEPA duty applies so that the total duty rate equals 15% ad valorem.

If the Column 1 General MFN duty rate is 15% or higher, no additional IEEPA duty applies and the MFN rate remains in effect.

Note also that under specific tariff classifications listed in Annex I of the USTR Notice (the Potential Tariff Adjustments for Aligned Partners (PTAAP) Annex), certain products of Switzerland or Liechtenstein are exempt from the country-specific IEEPA tariffs; however, the MFN duty applies.

Sectors specifically noted within the USTR Notice

Agriculture: Selected agricultural goods are subject to tariff adjustments, with potential exemptions under Annex I. Importers handling products in Chapters 1-24 should review HTSUS classifications against Annex I and Annex II.

Natural resources: Certain raw materials and commodities are identified for adjustment; origin and HTSUS codes need to be confirmed to determine eligibility for exemptions.

Aircraft and aircraft parts: Products in Chapter 88 are specifically identified. Importers of these products should verify whether airframes, engines or components are listed in Annex I or Annex II to confirm eligibility for exemption from the country-specific IEEPA tariffs.

Generic pharmaceuticals and inputs: Adjustments apply to selected finished generics, active pharmaceutical ingredients and chemical precursors in Chapters 29 and 30; consult Annex I or Annex II for country-specific IEEPA tariff exemptions for specific products.

Effective dates and refund mechanics

The modified rates and exemptions apply to entries for consumption and warehouse withdrawals made on or after 14 November 2025, beginning at 12:01 a.m. Eastern Time. Because the USTR Notice has retroactive effect, CBP will process any applicable duty refunds in accordance with existing law and standard procedures.

What this means for US importers

The Framework Agreement generally represents a significant decrease in the tariff rate for Swiss- and Liechtenstein-origin goods. Effects will vary by HTSUS classification and whether a product is listed in Annex I. The Framework reflects policy intent pending a final agreement targeted for the first quarter of 2026; however, if a final trade agreement is not concluded by 31 March 2026, the United States may revise or withdraw these changes, creating potential rate volatility for forward contracts and pricing. Importers in the highlighted sectors should consider carefully reviewing Annex I and Annex II to determine whether specific products are exempt from the country-specific IEEPA duty or subject to other adjustments.

Actions for businesses to consider

Affected entities may want to consider the following actions:

• Identify all entries of Swiss- and Liechtenstein-origin goods entered on or after 14 November 2025 and reconcile HTSUS classifications while confirming country-of-origin determinations
• Compare HTSUS codes against Annex I, which details HTSUS modifications, and Annex II, which lists exemptions from the country-specific IEEPA tariffs, and then update broker instructions and internal tariff tables
• Quantify changes for tariff lines with MFN rates below 15% and assess whether any lines qualify for exemptions
• Update pricing, budgets and landed cost models to reflect these adjustments

Refund and post-entry adjustment

For entries on or after 14 November 2025 that are unliquidated, importers may consider filing a Post Summary Correction to adjust the duty rate to the correct total under the USTR Notice, including removal of the country-specific IEEPA if an Annex I exemption applies.

For Foreign Trade Zone (FTZ) admissions, businesses should consider assessing whether privileged status or election of privileged or non-privileged status will affect the applicable duty rate upon entry for consumption.

Further, importers should consider maintaining product-origin statements, bills of materials and classification support to substantiate eligibility for Annex I exemptions and the correct rate application.

Looking ahead

Importers should closely track updates in the Federal Register for any changes to HTSUS notes, covered HTSUS classifications and additional CBP guidance on refund processing. Furthermore, the US Trump Administration anticipates finalizing the "Agreement on Fair, Balanced, and Reciprocal Trade" with Switzerland and Liechtenstein in the first quarter of 2026, and the outcomes of those negotiations could lead to further adjustments in tariff treatment.