Trump Tariff Shift Spurs Bullion Trade Realignment: Dealers Urged to Review HTSUS Revision 10

Following President Trump’s imposition of a sweeping 10% global tariff on imports effective April 5, 2025, and subsequent reciprocal tariffs targeting specific nations, the coin and bullion industry has seen swift changes to import dynamics—particularly now that newly issued clarifications on exempted items exclude specific forms of investment-grade bullion from the tariffs.

The update came through an expanded list of exclusions released April 12, retroactively shielding only select bullion categories from tariffs under the Harmonized Tariff Schedule of the United States (HTSUS) Revision 10 (2025). These developments have already prompted a reversal of bullion flows, with some gold shipments previously hoarded in US warehouses now returning to markets like Switzerland.

Key Exemptions Under HTSUS Rev. 10

According to the updated schedule, the following HTS codes are generally exempt from the 10% import tariff:

• 7108.12.10.00—Non-monetary gold bullion, unwrought
• 7106.91.10.00—Silver bullion, unwrought
• 7110.11.00.00—Platinum, unwrought or in powder form
• 7112.91.05.00—Waste and scrap of gold
• 7112.92.05.00—Waste and scrap of platinum

According to Section 3(b)(iv) of Executive Order 14257 and further clarified in Annex II, the following bullion-related items are exempt from the additional reciprocal tariffs (Reciprocal Tariff Exclusion for Specified Products; April 5, 2025):

• Gold Bullion: Nonmonetary, unwrought forms (typically classified under HTSUS code 7108.12.10.00).
• Silver Bullion: Unwrought, non-numismatic silver (see 7106.91.10.00).
• Platinum Bullion: Unwrought or in powder form (see 7110.11.00.00).
• Waste and Scrap of Precious Metals: Including gold and platinum (see, for instance, 7112.91.05.00 and 7112.92.05.00).

You can access the official text of Executive Order 14257, including Annex II, which outlines the exclusions from the reciprocal tariffs, through the Federal Register at https://www.federalregister.gov/documents/2025/04/07/2025-06063/regulating-imports-with-a-reciprocal-tariff-to-rectify-trade-practices-that-contribute-to-large-and.

Dealers and importers must ensure that all bullion meets the definition of investment-grade and is properly classified under the updated HTS codes.

Products Still Subject to Tariffs

Despite these exemptions, at the least, the 10% tariff still applies to any numismatic and semi-finished bullion and precious-metal products. These include

• 7118.10.00.00—Collectible coins and sets
• 7108.13.10.00—Semi-manufactured gold
• 7115.10.00.00—Miscellaneous articles of precious metals
• Jewelry and crafted items under Chapters 71.13–71.17

Industry Response and Compliance Guidance

The bullion market, already reactive to geopolitical pressure and currency volatility, is experiencing rapid shifts in supply chains and pricing strategy. Industry organizations urge dealers to review their product classifications and import documentation closely to ensure compliance.

“Dealers must now be as savvy about tariff codes as they are about spot prices,” said David Crenshaw, executive director of the National Coin & Bullion Association. “HTSUS Revision 10 isn’t just a bureaucratic update—it’s now a direct factor in your bottom line.”

Dealers and importers can access the full HTSUS Revision 10 at https://hts.usitc.gov/download.

To access the specific sections relevant to bullion and precious metals, see

• Chapter 71—Precious Metals and Related Articles https://hts.usitc.gov/reststop/file?filename=Chapter+71&release=currentRelease
• Chapter 99—Temporary Modifications and Other Provisions https://hts.usitc.gov/reststop/file?filename=Chapter+99&release=currentRelease

If you need assistance navigating these documents or identifying specific HTS codes relevant to your products, visit the HTS Help page. Questions related to the Harmonized Tariff Schedule (HTS) may be submitted via a form at https://www.usitc.gov/tariff_affairs/hts_help. Given the complexity of this matter, we strongly recommend that dealers and importers consult with a qualified customs attorney who can offer personalized legal guidance and advocate on your behalf with US Customs.