Tariff Updates Under the Trump Administration
This page outlines current key tariff policies and proposed changes to tariffs and trade policy under the New Administration. As this information is extremely fluid, be sure to check regularly for updates. This information is advisory only and is intended to be a resource in staying current on major trade developments. Requests for legal or binding advice should be directed to our compliance team at [email protected] or your trade attorney.
China: Section 301 Duties
- Beginning on July 6, 2018, President Trump and the USTR implemented additional duties on most goods imported from China as a result of an investigation of unfair trade practices under Section 301(b) of the Trade Act of 1974. See China Tariff Actions here.
- Duties ranged from 7.5% to 25%, on roughly $370 billion worth of Chinese imports across four lists (Lists 1–4A).
- Some product exclusions were granted, allowing certain goods to avoid the 301 additional tariffs.
- View M.E. Dey’s Tariff Tracker to look up the 301 duty rates or possible exclusion by HTS code.
- Current available exclusions are set to expire on May 31, 2025
- On September 18, 2024, following the completion of the USTR’s four-year review of the Section 301 action, the Biden Administration announced that all Section 301 tariffs would remain in place and increased the tariffs on certain commodities.
- For more information on Section 301 duties see our Whitepaper here.
China: NEW Duties on China Products - IEEPA
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- On February 1, 2025, the Trump Administration released Executive Orders (EOs) invoking the International Emergency Economic Powers Act (IEEPA), declaring that the threats posed by illegal immigration and the flow of drugs like fentanyl, from Canada, Mexico, and China, constitute a national emergency.
- While Canada & Mexico were postponed, China duties of 10% were implemented with an effective date of February 4, 2025
- These duties are in addition to the existing Section 301 duties.
- There are NO exclusions or exclusion process for relief from these duties
- Once duties are paid, there is no opportunity for refund of duties
- On Feb. 27, 2025, President Trump announced in a Truth social post that the IEEPA tariffs on China will increase from 10% to 20% on March 4, 2025
- Duty-free De Minimis Per the EO, also effective on February 4, 2025, imported goods under $800 in value would no longer be allowed to enter duty-free.
- However, on February 5, 2025, the Whitehouse published an EO reverting back to allowing the duty-free De Minimis entry as Customs could not handle the volume of low-value shipments. Once the Secretary of Commerce advises that adequate systems are in place to process and collect duties, the De Minimis treatment will no longer be available for low-value shipments and duties will need to be paid.
- On March 4, 2025, Chinese tariffs were doubled to 20%, with the White House citing inadequate efforts to curb illicit fentanyl shipments to the U.S.
CANADA & MEXICO - IEEPA
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- Mexico – February 1, 2025, the Whitehouse EO proposed 25% tariffs on imports from Mexico pursuant to the IEEPA.
- On February 3, following negotiations and actions taken by Mexico, the Whitehouse EO paused the tariffs for 30 days; until March 4, 2025
- Canada – February 1, 2025, the Whitehouse EO proposed 25% tariffs on imports from Canada pursuant to the IEEPA.
- On February 3, following negotiations and actions taken by Canada, the Whitehouse EO paused the tariffs for 30 days; until March 4, 2025
- On February 27, 2025, President Trump announced, in a Truth social post, that the IEEPA tariffs on Mexico and Canada will go into effect on March 4, 2025
- On March 4, 2025, 25% tariffs on all imports from Canada and Mexico were imposed with the exception of Canadian energy products, which will face a 10% rate.
- On March 5, 2025, after meeting with America’s three major automakers (Ford, General Motors, and Stellantis), President Trump granted a one month exemption to the 25% tariffs on automobiles.
- Two March 6, 2025 Federal Register notices advised that De Minimis imports from Canada and Mexico shall cease to be available upon notification by the Secretary of Commerce that adequate systems are in place to process and collect tariff revenue.
- March 6, 2025, Trump announced in a Truth Social post that he has agreed to exempt goods that qualify for USMCA from MX from the 25% IEEPA tariffs until April 2nd.
- March 6, 2025 The Whitehouse publishes Executive Orders (EOs) exempting USMCA qualifying products from BOTH Canada and Mexico from the IEEPA 25% on goods entering the U.S. on or after 12:01 a.m. March 7, 2025.
- Mexico – February 1, 2025, the Whitehouse EO proposed 25% tariffs on imports from Mexico pursuant to the IEEPA.
Section 232 – Duties on Steel and Aluminum
- On March 18, 2018, under the Trade Expansion Act of 1962, President Trump implemented Section 232 tariffs, on steel (25%) and aluminum (10%) imports, citing national security concerns.
- Exemptions granted: Canada, Mexico, and Australia were exempted from the additional tariffs and Argentina, Brazil, South Korea, the European Union, Japan, and the UK were exempt based on certain quota limits.
- Exclusions granted: Importers who applied for review were granted product-specific exclusions, and a list of General Approved Exclusions (GAEs) was established, providing relief from the duties.
- Derivative Products: In 2020, an additional 25% tariff was implemented for a specific list of Steel Derivative products, and 10% for a specific list of Aluminum Derivative products.
- Ukraine: Steel tariffs were suspended for imports from Ukraine through June 1, 2025.
- Russia: In 2023, any aluminum articles from Russia, or any aluminum derivative articles that were produced in other countries but where the aluminum was smelted or cast in Russia, are subject to 200% additional tariffs.
- February 10, 2025, the White House Proclamation announced that a 25% duty will be implemented on steel and aluminum imports from all countries, except Russia which will remain at 200%, and will go into effect on March 12, 2025. A fact sheet from the White House can be read
here. - All country exceptions expire on March 12, 2025.
- No new product exclusions will be considered.
- Product exclusions granted to companies will remain in effect until their expiration date or when the quantitative limit is filled, whichever occurs first. No renewals will be considered.
- All GAEs will terminate on March 12, 2025.
- On February 14, 2025, the White House released annexes of steel and aluminum derivative items that will be subject to Section 232 tariffs effective March 12, 2025.
- If a product is listed in the Steel and/or Aluminum Annex, the 25% tariff will be due on either the whole product or only on the steel or aluminum component value if a product breakdown is provided.
- Derivative products OUTSIDE chapters 73 and 76 will not go into effect until the Secretary of Commerce certifies that an effective system is in place to collect the new tariffs (see note A in each Annex).
Retaliations Against the U.S.
Canada’s Response
Canadian Prime Minister Justin Trudeau initially denounced the tariffs as unwarranted and harmful to both economies, warning that they would disrupt cross-border trade and drive up costs for consumers. In retaliation, Canada had announced plans to impose a 25% tariff on approximately $155 billion worth of U.S. goods, specifically targeting consumer products, alcohol, appliances, furniture, and industrial goods.
- February 3, 2025, Canada and the United States agreed to delay the imposition of our respective tariffs on imported goods.
- Canada imposes United States Surtax Order (2025-1) of 25% on U.S. goods entered into Canada effective March 4, 2025.
- Canadian Prime Minister Justin Trudeau announced a 25% retaliatory levy on C$30 billion worth of U.S. imports, effective immediately. Tariffs on another C$125 billion in U.S. goods will take effect in 21 days, he added.
Mexico’s Response
Mexican President Claudia Sheinbaum strongly rejected the tariffs, calling them unjustified and politically motivated. She also pushed back against the link between Mexico and fentanyl production, arguing that the U.S. should focus on its own drug crisis rather than penalizing its trading partners.
- As part of the arrangement reached with the United States, Sheinbaum announced that she and President Donald Trump had agreed to a one-month pause on tariffs. In exchange, Mexico committed to several key actions.
- Mexico’s president said retaliatory tariffs are coming Sunday.
China’s Response
China’s Ministry of Commerce has strongly condemned the U.S. tariffs, labeling them as a violation of global trade rules and announcing plans to file an official complaint with the World Trade Organization (WTO). The ministry argues that the U.S. measures are unilateral and protectionist, undermining international trade norms.
- The latest retaliatory measures include a 15% levy on coal and liquefied natural gas, as well as a 10% tariff on crude oil, agricultural machinery, and large-engine vehicles imported from the U.S. These tariffs took effect on Monday, February 10.
Trade Reviews Announced with Potential Future Tariffs
On February 13, 2025, the White House released a memo on Reciprocal Trade and Tariffs. This memo initiates a review of countries that maintain higher tariffs on American goods or enforce non-tariff trade barriers to exports of U.S. goods.
- A White House fact sheet highlights examples of the “unfair trade practices,” such as Value-added Tax (VAT), and non-tariff barriers such as phytosanitary measures, export subsidies, lack of trademark/copyright protection, and other barriers to U.S. goods.
- On February 21, 2025, the White House published a Fact Sheet directing the USTR to renew the Digital Service Taxes (DST) investigation that was initiated during President Trump’s first term.
- While details on implementation remain unclear, the White House has indicated that Section 301 tariffs will play a key role, with potential reliance on Section 232, Section 338, and the International Emergency Economic Powers Act (IEEPA) to enforce the measures.
On January 20, 2025, the President published the America First Trade Policy memorandum instructing certain government agencies to investigate the cause of persistent trade deficits in goods, as well as the economic and national security implications and risks resulting from such deficits. The agencies are required to provide their reports and recommend appropriate measures by April 1, 2025.
On February 25, 2025, the President issued an Executive Order (EO) to initiate an investigation under Section 232 of the Trade Expansion Act to determine whether imports of copper, scrap copper, and copper’s derivative products threaten to impair national security.
- Within 270 days (about 9 months) from the EO, the Secretary of Commerce must submit a report to the president with findings and recommendations.
- A White House Fact Sheet on Section 232 review on copper imports can be found here.
On Saturday, March 1, 2025, the President published an Executive Order instructing Commerce to initiate a Section 232 investigation on imports of timber, lumber and their derivative product.
- Commerce has 270 days to submit a report on findings and recommendations to the Whitehouse.
- A White House Fact Sheet on the Section 232 review of Timber and Lumber can be found here.
On March 12, 2024, a petition was filed for an investigation of China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance. The report was completed on January 15, 2025, with findings that China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance is unreasonable and burdens or restricts U.S. commerce and thus is actionable.
- In a February 27, 2025 Federal Register (FR) Notice, the USTR announced the proposed Section 301 action, and announced a public hearing and comment period.
- The proposed actions include significant service fees, of up to $1 million dollars, to be charged on Chinese-built vessels upon entrance of the vessel into a U.S. port.
- The public comment period opened on February 21, 2025. Comments must be submitted by March 24, 2025.
- To be assured of consideration to appear at the hearing, requests to appear must be submitted by March 10, 2025.
- Submit comments or request to appear in the hearing through USTR’s electronic portal: https://comments.ustr.gov/s/. The docket number for written comments and rebuttal comments is USTR–2025–0002. The docket number for requests to appear is USTR–2025–0003.
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