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.

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Reciprocal Tariffs (IEEPA)

UPDATE: On April 9, President Trump announced a 90-Day Pause on Reciprocal Tariffs, except for China.

On April 2, President Donald Trump unveiled a sweeping tariff policy that will affect nearly every U.S. trading partner. Under the new “reciprocal” tariff system, all imports into the U.S. will face a minimum 10% tariff starting April 5, with higher country-specific rates taking effect on April 9. These targeted rates are based on the trade imbalances and barriers each country imposes on U.S. goods.

According to a White House fact sheet, countries with significant trade surpluses with the U.S. will see steeper levies. Imports from China will be hit with an 84% tariff, the European Union 20%, and Vietnam 46%. These IEEPA Reciprocal duties are in addition to the regular rates of duty (MFN) in place. For China, the IEEPA Reciprocal duties are in addition to the previous 20% round 1 IEEPA duties and in addition to Sec. 301 duties if applicable.

  • Effective April 5, 2025 a 10% Tariff imposed on imports from all countries.
  • Effective April 9, 2025 increase from 10% to the country-specific rate. See chart here.
  • Effective April 9, 2025, China specific rate to increase from 34% to 125%
  • Canada and Mexico exempt from Reciprocal tariffs due to existing fentanyl/migration IEEPA
  • Products subject to Section 232 tariffs (Steel/Aluminum articles and derivatives, autos/parts) are exempt from the Reciprocal tariffs
  • Products imported under a special program in Chapter 98 are exempted from the Reciprocal Tariffs
  • Goods listed in Annex II to the Executive Order (EO) are not subject to the Reciprocal 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.

Trade Reviews Announced with Potential Future Tariffs

America First Trade Policy

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.

Section 232 Investigation of Imports of Copper

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.
Section 232 Investigation of Imports of Timber, Lumber, and their Derivative Products

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.

Section 301 Investigation of China’s Targeting of Maritime, Logistics and Shipbuilding Sectors

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.
  • On March 24, 2025, President Trump issued an Executive Order instructing the Secretary of State, in consultation with the Secretary of Commerce, Homeland Security and the USTR to determine whether a tariff of 25% will be imposed on goods from any country that imports Venezuelan oil, directly or indirectly, on or after April 2, 2025.

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 (Fentanyl)

    • 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 - (Fentanyl/MIgration)

    • 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 24, 2025 Customs and Border Protection (CBP) issued CSMS#64472173 with a list of Energy and Energy Resources products from Canada that are subject to the 10% IEEPA Tariffs effective March 4, 2025.
    • 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.
    • March 7, 2025 –  10% on Non-USMCA Potash from Canada.  See the CBP Guidance CSMS#64335789 for more information.
    • March 7, 2025 –  10% on Non-USMCA Potash from Mexico.  See the CBP Guidance CSMS#64336037 for more information.
    • March 7, 2025 – 10% on Energy and Energy Resources from Canada. See the CBP Guidance CSMS#64470353 for more information.

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.
  • EU Steel Extended Exclusions (STX) are revoked effective March 12, 2025. All other 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 Items Subject to Section 232
    • Aluminum Derivatives outside Chapter 76: A list of the aluminum derivative products is provided in subdivision (k), of the Federal Register Notice.
    • Steel Derivatives listed outside Chapter 73: A list of the derivative iron or steel products is provided in subdivision (n) of the Federal Register Notice.
    • Reporting Values for Steel and/or Aluminum Content: When importing products identified as steel and aluminum derivatives that are outside Chapters 73 and76, the 25% additional tariff is assessed on the value of the steel and/or aluminum content.
      • Importers must include a breakout of the values and the weight in kilograms (KG) of the steel/aluminum content for each product on the Commercial Invoice. If Importers will need to work with the foreign suppliers to obtain the needed value and weight content.
      • If an importer is not able to obtain the value and weight detail, or the detail is unknown, the 25% duties will be assessed on the full value of the product.
      • As always, communicate with your customs broker to ensure that the needed content information is available to make proper entry.
  • April 4, 2025 – The Whitehouse revised the Aluminum Section 232 tariffs of 25% to include imported Beer and Aluminum Cans.
    • The 25% tariff on Beer imports will apply to the value of the aluminum cans. See the Federal Register notice here.

Section 232 – Automotive and Automotive Parts

  • March 26, 2025, the Whitehouse posted a Presidential Proclamation on 25% Section 232 tariffs on Automobiles and Automobile Parts to go into effect on entries entered on or after 12:01 a.m. April 3, 2025, unless such actions are expressly reduced, modified, or terminated
    • The tariffs will apply to imported passenger vehicles (sedans, SUVs, crossovers, minivans, cargo vans) and light trucks.
    • When published in the Federal Register, on a date no later than May 3, 2025, automobile parts (engines, transmissions, powertrain parts, and electrical components), and additional parts if necessary.
  • March 26, 2025, the Whitehouse posted a Fact Sheet on the Automotive Section 232 tariffs
  • Automobiles that qualify for USMCA – the importer will have the opportunity to certify identifying the U.S. content value. The Secretary may approve imports of such automobiles to be eligible to apply the ad valorem tariff of 25% exclusively to the value of the non-U.S. content of the automobile.
  • The 25% will not apply to automobile parts that qualify for USMCA until such time that Commerce establishes a process to apply the tariffs to the non-U.S. value of the parts.
  • No Duty Drawback shall be available

Retaliations Against the U.S.

European Union’s Response

The EU is taking retaliatory measures against U.S. products due to the March 12, 2025, implementation of the Steel and Aluminum tariffs.

  • First, they will allow the suspension of the 2018 and 2020 countermeasures against the U.S. to expire on April 1.
  • Second, they have released a list of products that could be subject to new tariffs.

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.

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.

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.

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