In a significant move to stabilize bilateral trade relations, the International Trade Administration (ITA) has officially published the terms of a new trade agreement with Switzerland and the Principality of Liechtenstein. Effective immediately, the agreement rolls back the previous country-specific reciprocal tariff of 39% to a capped rate of 15%.
Critically for U.S. importers, this reduction is retroactive to November 14, 2025.
Key Provisions of the Notice
The Federal Register notice clarifies that the new 15% “cap” functions similarly to existing trade structures with the European Union and Japan.
- The 15% Cap Rule: For articles where the standard Column 1 (MFN) rate is already less than 15%, the reciprocal tariff will be the difference required to reach a 15% total. (Example: If the MFN rate is 5%, the reciprocal rate is 10%).
- Pharmaceutical and Civil Aircraft Exemptions: Certain Swiss origin goods are now exempt from reciprocal tariffs if they meet specific classification and use requirements. Civil Aircraft: Articles meeting the terms of General Note 6 (Civil Aircraft Agreement) are exempt under subheadings 9903.02.85 (CH) and 9903.02.90 (LI). Pharmaceuticals: Articles used in pharmaceutical applications that are “not patented in the United States” are exempt under subheadings 9903.02.86 (CH) and 9903.02.91 (LI). Note: U.S. Customs and Border Protection (CBP) has yet to provide a formal definition for “not patented in the United States,” leaving a point of potential ambiguity for importers.
Retroactive Relief: What Importers Need to Do
Because the 15% cap is retroactive to November 14, 2025, companies that have imported Swiss or Liechtenstein origin goods over the past month may be eligible for significant refunds.
- Entries Made Within the Last 10 Days: Importers should immediately issue corrected entries to reflect the lower rates before liquidation.
- Entries Made Since November 14: For entries older than 10 days but made on or after the effective date, companies should file Post-Summary Corrections (PSCs) to reclaim overpaid duties.
What Remains Unchanged
The notice specifically addresses reciprocal tariffs and does not impact existing Section 232 actions. Tariffs on steel, aluminum, and automobiles remain in effect according to their previous status.
Furthermore, the U.S. government has signaled that this is an “interim” finalization. Several aspects of the deal remain subject to negotiation and must be finalized by March 31, 2026. The U.S. reserves the right to reconsider or adjust terms based on those final discussions.
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