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 compliance@medey.com or your trade attorney.

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Reciprocal Tariffs (IEEPA)

On July 7, 2025, the Whitehouse published an Executive Order (EO) further extending the pause on the country specific Reciprocal Tariff Rates to August 1, 2025

  • See the Executive Order here.

On July 7, 2025, President Trump sent out letters to many countries with new Country Specific Reciprocal Rate starting August 1, 2025. Additionally, the Whitehouse published a Fact Sheet with the specific updated Tariff Rates.

  • The President sent letters to 14 countries with more expected to come in the coming days and weeks.
  • Fact Sheet: President Donald J. Trump Continues Enforcement of Reciprocal Tariffs and Announces New Tariff Rates. See the Fact Sheet here.

On May 13, 2025, the Whitehouse modified the Reciprocal Tariff rate for China. As a result of the trade negotiations and the agreement reached, the EO makes the following amendments related to the China Specific Reciprocal Tariff:

  • Pause of the China Specific Reciprocal rate for 90 days. Effective for entries made on or after 12:01 May 14, 2025, imports from China will be subject to the 10% Reciprocal tariff.
  • The China Specific rate is reduced from 125% to 34% effective after the 90 day pause (August 12, 2025)
  • China De Minimis (low value entries) rate decreased from 120% to 54%. For postal items the rate will remain at $100 and will increase to $200 effective June 1, 2025.
  • See the Executive Order here, and the Fact Sheet here.

On April 9, President Trump announced a 90-Day Pause on Reciprocal Tariffs, except for China. The Whitehouse Executive Order modified the country specific Reciprocal Tariff Rates beginning at 12:01 easter daylight time on April 10, 2025. The EO modified the country specific rates for 90 days; until July 9, 2025. Additionally, the EO increased the China specific rate and the China de minimis rate.

  • Effective April 10, 2025, all country specific rates, except China, Mexico and Canada are set at 10%
  • Effective April 10, 2025, China specific rate increased from 84% to 125%
  • China De Minimis (low value entries) rate increased from 90% to 120%, and for postal items from $75 to $100
  • See the Executive Order (EO) here.

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. 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 Annex I for the specific country rate.
  • Effective April 9, 2025, China specific rate to increase from 34% to 84%.
  • 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.

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: Duties on China Products - IEEPA (Fentanyl)

  • 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.
  • 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.

CANADA & MEXICO - IEEPA - (Fentanyl/MIgration)

  • March 7, 2025 – 10% on Energy and Energy Resources from Canada. See the CBP Guidance CSMS#64470353 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 Non-USMCA Potash from Canada.  See the CBP Guidance CSMS#64335789 for more information.
  • 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 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.
  • 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.
  • 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.
  • 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 4, 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 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.
  • 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
  • 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

Section 232 – Duties on Steel and Aluminum

  • On June 16, 2025, the Department of Commerce (DOC), Bureau of Industry and Security (BIS), published a notice in the Federal Register, with additional Section 232 Steel Derivative products for certain household products including, but not limited to, washing machines and dryers, stoves, refrigerators, and freezers. These items will be subject to the Section 232 tariffs of 50% for all countries except for the UK which is 25% on the value of the Steel content value, effective on entries submitted on or after 12:01 a.m. Easter Time on June 23, 2025.  A full list of products is available in the Federal Register Notice here.
  • On June 13, 2025, Customs provided updated guidance regarding reporting “unknown” for the Country of Smelt and Cast for Aluminum products under Section 232 tariffs. The new guidance advised that if the Smelt and Cast is not know, the entry must be submitted with “UN” (unknown), and the goods are then subject to 200% duties for Russia aluminum. See the CBP Guidance CSMS#65340246 for more information.
  • On June 3, 2025, the Whitehouse published a Presidential Proclamation adjusting the Section 232 tariffs on Steel and Aluminum increasing the tariff from 25% to 50% for all countries except for the UK which will remain at 25% on entries effective 12:01am Easter time on June 4, 2025.
    • Customs and Border Protection (CBP) provided three Updated Guidance documents which included new breakouts for Reporting entries of UK origin:
      • Updated Guidance Amending Executive Order 14289 – Imports of Steel and Aluminum CSMS#65236574
      • Aluminum and Aluminum Derivative Products – Duty is assessed on the value of the aluminum content
      • Steel and Steel Derivative Products – Duty is assessed on the value of the steel content
  • On May 8, 2025, The White House announced a Trade Deal reached with the United Kingdom (UK) which will include an alternative arrangement for the Section 232 Auto tariffs. See the White House Fact Sheet here.
  • 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.
  • 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.
  • 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.
  • 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.
  • 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.

Section 232 – Automotive and Automotive Parts

  • On May 8, 2025 The Whitehouse announced a Trade Deal reached with the United Kingdom (UK) which will include an alternative arrangement for the Section 232 Auto tariffs.
    • Under the deal, the first 100,000 vehicles imported into the U.S. by UK car manufacturers each year are subject to the reciprocal rate of 10% and any additional vehicles each year are subject to 25% rates.
    • Additional details are to come. See the Whitehouse Fact Sheet here.

  • On April 29, 2025, the Whitehouse announced a Section 232 Automotive parts offset for automobiles assembled in the United States. See the Whitehouse Proclamation here.

  • 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.
  • 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.
  • China exempts certain U.S. goods from the 125% Retaliatory tariffs.

Trade Reviews Announced with Potential Future Tariffs

Section 232 Investigation – Commercial Aircraft and Jet Engines

May 1, 2025 – The Department of Commerce (DOC) initiated an investigation to determine the effects on the national security of imports of commercial aircraft and jet engines, and parts for commercial aircraft and jet engines.

  • The DOC opened a 21 day public comments period on May 1, 2025 and closing on June 3, 2025 (Docket ID: BIS-2025-0027).
  • The DOC will then have 270 days to provide a report and tariff recommendations to the Whitehouse.

See Federal Register Notice here.

Section 232 Investigation – Trucks

April 22, 2025 – The Department of Commerce (DOC) initiated an investigation to determine the effects on the national security of imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts, and their derivative products.

  • The DOC opened a 21 day public comments period on April 22, 2025 and closing on May 16, 2025 (Docket ID: BIS-2025-0024).
  • The DOC will then have 270 days to provide a report and tariff recommendations to the Whitehouse.
  • See Federal Register Notice here.
Section 232 Investigation – Semiconductors and Semiconductor Manufacturing Equipment

April 16, 2025 – The Department of Commerence (DOC) announced in a Federal Register notice the initiation of an investigation to determine the effects on the national security of imports of semiconductors and semiconductor manufacturing equipment (SME), and their derivative products.

  • The DOC opened a 21 day public comments period on April 16, 2025 and closing on May 7, 2025 (Docket ID: BIS-2025-0021).
  • The DOC will then have 270 days to provide a report and tariff recommendations to the Whitehouse.
  • See the Federal Register Notice here.

Section 232 Investigation – Pharmaceuticals and Pharmaceutical Ingredients

April 16, 2025 – The Department of Commerence (DOC) announced the initiation of an investigation to determine the effects on the national security of imports of pharmaceuticals and pharmaceutical ingredients, including finished drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients, and key starting materials, and derivative products of those items..

  • The DOC opened a 21 day public comments period on April 16, 2025 and closing on May 7, 2025 (Docket ID: BIS-2025-0022).
  • The DOC will then have 270 days to provide a report and tariff recommendations to the Whitehouse.
  • See Federal Register Notice here.

Section 232 Investigation of Critical Minerals and Derivative Products

April 15, 2025 – the President published an Executive Order (EO) and Fact Sheet initiating a Section 232 an investigation under the Trade Expansion Act of 1962 to determine the effects on national security of imports of processed critical minerals and their derivative products.

  • Within 90 days of the date of this order, the Secretary of Commerce shall submit for internal review and comment a draft interim report, followed by a 15 day period for comments on the draft by the Secretary of the Treasury, the Secretary of Defense, the United States Trade Representative, the Assistant to the President for Economic Policy, and the Senior Counselor to the President for Trade and Manufacturing.
  • The Secretary of Commerce shall submit a final report and recommendations to the President within 180 days of the investigation’s commencement.

Venezuelan Oil Imports

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.

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

March 12, 2024 – 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.

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

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 232 Investigation of Imports of Copper

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.

America First Trade Policy

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.

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