According to President Trump, “Tariff is the most beautiful word in the dictionary.” Throughout his presidential campaign, Trump promised to use tariffs as a central part of his foreign policy strategy. His America First Trade Policy memorandum also directs the administration to review various tariff- and tariff-adjacent levers the United States could use to further its new trade policy.

Reed Smith’s International Trade and National Security team tracks the latest threatened and implemented U.S. tariffs, as well as counter-tariffs from other countries around the world.

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Section 301 forced labor tariffs | Section 301 excess capacity investigations | Additional country-specific tariffs  |  Worldwide product-specific tariffs  |  Tariff stacking | IEEPA refund process |  Updates and relevant publications

Section 301 forced labor tariffs

Implemented
(effective July 24, 2026)
Reference: 91 Fed. Reg. 47318 (July 28, 2026)

Ad valorem rates

10% inclusive of the Column 1 Duty Rate: European Union, Thailand

10%: Argentina, Bangladesh, Cambodia, Canada, Ecuador, El Salvador, Guatemala, Honduras, India, Indonesia, Jordan, Malaysia, Mexico, Pakistan, Philippines, Sri Lanka, Trinidad and Tobago, United Kingdom, Vietnam

12.5% inclusive of the Column 1 Duty Rate: Japan, South Korea, Switzerland

12.5%: Algeria, Angola, Australia, The Bahamas, Bahrain, Brazil, Chile, China, Colombia, Costa Rica, Dominican Republic, Egypt, Guyana, Hong Kong, Iraq, Israel, Kazakhstan, Kuwait, Libya, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, Qatar, Russia, Saudi Arabia, Singapore, South Africa, Thailand, Turkey, United Arab Emirates, Uruguay, Venezuela

Exemptions

The following foreign-origin items are exempt from the Section 301 forced labor tariffs:

  • Goods subject to the saving clause. The savings clause covers goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before entry into the United States before 12:01 a.m. (ET) on July 24, 2026 and entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. (ET) on July 28.
  • Goods subject to the Section 232 tariffs.
  • Certain articles of civil aircraft as described in U.S. Note 2(aa)(iv) to Subchapter III of Chapter 99 of the HTSUS.
  • Goods qualifying for duty-free treatment under the USMCA.
  • Articles of textiles or apparel (a) of Jordan or (b) that qualify for duty-free treatment under CAFTA-DR.
  • The additional articles listed in Annex II to the USTR’s Federal Register notice, including certain agricultural products, copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products. Over 90% of the goods on Annex II mirror those previously exempt from the reciprocal tariffs.
  • Certain goods listed in Annex I to the Federal Register notice that originate in Argentina, Bangladesh, Cambodia, Ecuador, El Salvador, European Union, Guatemala, Indonesia, Jordan, Malaysia, Taiwan, United Kingdom, or Switzerland.
  • Articles that are donations by persons subject to the jurisdiction of the United States, such as food, clothing and medicine, intended to be used to relieve human suffering.
  • Information materials.

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Section 301 excess capacity investigations

Threatened
(Mar. 11, 2026)
Reference: 91 Fed. Reg. 12886 (Mar. 17, 2026)

Investigated economies

Bangladesh, Cambodia, China, the European Union, India, Indonesia, Japan, Malaysia, Mexico, Norway, Singapore, South Korea, Switzerland, Taiwan, Thailand, Vietnam

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Additional country-specific tariffs

🔔 Updated: September 10, 2026 at 3:00 pM ET

Litigation update (May 8, 2026): On May 7, the Court of International Trade declared Proclamation 11012, which imposed the Section 122 tariffs, invalid as contrary to law. The court did not, however, issue a universal injunction preventing U.S. Customs and Border Protection (CBP) from continuing to collect the tariffs or order CBP to issue a refund to all importers. The Government has appealed the decision.

CountryType & StatusAd Valorem Rate 1Exemptions & NotesAnnounced Countermeasures
All Additional (DSTs):
Threatened
(Aug. 25, 2025) 		TBDAll products from any country that imposes a digital services tax (DST)
Russia-related sanctions:
Threatened
(Jan. 7, 2026)		500%If the Sanctioning Russia Act of 2025 passes Congress and is signed into law, the President can impose the tariff on imports from any country that knowingly sells, supplies, transfers, or purchases Russian-origin oil, uranium, natural gas, petroleum products, or petrochemical products.
Additional (Iran military weapons):
Threatened
(Apr. 8, 2026)		50%All products from any country that supplies military weapons to Iran
Austria Additional (DSTs):
Threatened
(Feb. 21, 2025) 		TBD
Details   ▸
Brazil Section 301 (unreasonable policies):
Implemented
(effective July 22, 2026)		25%Exemptions:
(a) Items subject to the savings clause (loaded onto a vessel at the port of loading and in transit before July 22 and entered before July 29)
(b) Items subject to Section 232 tariffs
(c) Items listed in Annex II to the USTR’s Federal Register notice
Canada
Tariff CMs   ▸Vehicle product surtaxes: 25% on certain non-USMCA compliant vehicles

(effective Apr. 9, 2025)

“Reciprocal” tariff countermeasures: 25% on certain U.S.-origin products

(effective Mar. 4, 2025; updated Sept. 1, 2025)
Section 338:
Implemented
(effective Aug. 22, 2026)		50%Scope:
Items listed in Annex II to the motor vehicles, alcohol, and dairy proclamations.

🔔 Modified
See Sept. 8, 2026 alcoholic beverages and motor vehicles proclamations (effective Sept. 15, 2026)

Exemptions:
(a) Items that fall under the WTO Agreement on Trade in Civil Aircraft.
(b) Items subject to Section 232 tariffs 🔔 (to be removed, effective Sept. 15, 2026)
Details   ▸
Implemented
(effective Sept. 8, 2026)
Counter tariffs on $27.6 billion in products imported from the United States
Additional (dairy and lumber):
Threatened
(Mar. 7, 2025) 		250%
Additional (aircraft):
Threatened
(Jan. 29, 2026)		50%
China
Trade Deal
Tariff CMs   ▸
  • Export controls on tungsten, tellurium, bismuth, molybdenum, and indium products (effective Feb. 4, 2025)
  • 15% tariff on supercooled natural gas and coal from the U.S. (effective Feb. 10, 2025)
  • Imports of U.S.-origin logs suspended (effective Mar. 4, 2025)
  • 15% tariff on U.S.-origin chicken, cotton, corn, and wheat (effective Mar. 10, 2025)
  • 10% tariffs on U.S.-origin aquatic products, beef, dairy products, fruit, pork, sorghum, soybeans, and vegetables (effective Mar. 10, 2025)
  • 10% tariff on U.S.-origin crude oil
  • [Suspended until Nov. 10, 2026] Export controls on seven categories of medium and heavy rare earth-related items, including samarium, gadolinium, zirconium, dysprosium, lutetium, scandium, and yttrium (effective Apr. 4, 2025; suspended Nov. 7, 2025)
  • [Suspended until Nov. 10, 2026] Export controls on certain foreign-produced items that incorporate Chinese rare earth materials (effective Oct. 10, 2025 with further controls effective Dec. 1, 2025; suspended Nov. 7, 2025)
 Maritime and cargo handling equipment:
Delayed until Nov. 10, 2026
(effective Nov. 10, 2025) 		25% See Worldwide, product-specific tariffs table below
European Union
Trade Deal
Tariff CMs   ▸Suspended:
  • 4.4–25% tariffs on U.S.-origin goods in Annexes I-IV to Implementing Regulation (EU) 2025/1564
  • 7.5–30% tariffs on U.S.-origin goods in Annexes VI-XI to Implementing Regulation (EU) 2025/1564 and the direct or indirect export of goods classified in headings 7204 (ferrous waste and scrap; remelting scrap ingots of iron or steel) or 7602 (aluminum waste and scrap) to the United States
  • 25% tariffs on U.S.-origin goods in Annex V to Implementing Regulation (EU) 2025/1564
  • 10–30% tariffs on U.S.-origin goods in Annexes XII-XIII to Implementing Regulation (EU) 2025/1564
Proposed: A tariff-rate quota regime where specified volumes of in-scope steel can enter the EU duty free, but any imports beyond those quotas would be subject to a 50% tariff. The new regime would replace the current safeguards that are set to expire in mid-2026.
 Additional (alcohol products):
Threatened
(Mar. 13, 2025) 		200%
Additional (DSTs):
Threatened
(Feb. 21, 2025) 		TBD
Details   ▸
France Additional (alcohol products):
Threatened
(Jan. 19, 2026)		200%
Germany
Sec. 301 Invest.		Section 301:
Threatened
(Mar. 11, 2026)		TBD
Details   ▸
    The USTR is investigating Germany’s acts, policies, and practice relating to structural excess capacity and production in certain sectors, including the automobiles and automobile parts, machinery, electronic equipment, pharmaceutical products, and chemicals sectors.

    References:
    Fed. Reg. notice (released Mar. 11, 2026)
Ireland
Sec. 301 Invest.		Section 301:
Threatened
(Mar. 11, 2026)		TBD
Details   ▸
    The USTR is investigating Ireland’s acts, policies, and practice relating to structural excess capacity and production in certain sectors, including the pharmaceutical sector.

    References:
    Fed. Reg. notice (released Mar. 11, 2026)
Nicaragua Section 301:
Implemented
(effective Jan. 1, 2026)		0% for goods that are originating under CAFTA-DR

Jan. 1, 2026 to Dec. 31, 2026: 0%

Jan. 1, 2027 to Dec. 31, 2027: 10%

Starting Jan. 1, 2028: 15%
Details   ▸
    The USTR determined that Nicaragua’s acts, policies, and practices related to labor rights, human rights and fundamental freedoms, and the rule of law are unreasonable and burden or restrict U.S. commerce, and are therefore actionable under Section 301 of the Trade Act of 1974.

    References:
    Fed. Doc. 2025-22690 (filed Dec. 11, 2025)
    90 Fed. Reg. 48511 (Oct. 23, 2025)
Russia Ukraine-related sanctions:
Threatened
(Jan. 7, 2026)		500%If the Sanctioning Russia Act of 2025 passes Congress and is signed into law, the President can impose the tariff on all imports of Russia-origin goods.
Spain Additional (DSTs):
Threatened
(Feb. 21, 2025) 		TBD
Details   ▸
Turkey Additional (DSTs):
Threatened
(Feb. 21, 2025) 		TBD
Details   ▸
United Kingdom
Trade Deal 		Additional (DSTs):
Threatened
(Feb. 21, 2025) 		TBD
Details   ▸
Vietnam
Trade Deal 		Section 301 (intellectual property):
Threatened
(May 29, 2026)		TBD
Details   ▸
Reciprocal Trade Agreements and Frameworks   ▸ While the reciprocal tariffs were in effect, the following agreements and frameworks for reciprocal trade were announced:
Invalidated Tariff Actions   ▸
Baseline Reciprocal Tariffs and Exemptions   ▸ (effective Apr. 5, 2025; declared invalid Feb. 20, 2026)
  • Rate: 10%
  • Transshipment penalty: 40% (in lieu of baseline or country-specific rate)
  • Exempt countries: Belarus, Canada, Cuba, Mexico, North Korea, and Russia
  • Exemptions:
    • Goods subject to the Section 232 tariffs on articles and derivatives of aluminum and steel,automobiles, automobile parts, buses, medium- and heavy-duty vehicles (MHDVs), MHDVparts, lumber, semi-finished copper and intensive copper derivative products, and semiconductors.
    • The additional articles listed in Annex II to Executive Order 14257 (as amended),including certain agricultural products, copper, pharmaceuticals, semiconductors, lumberarticles, certain critical minerals, and energy and energy products. On November 14, President Trump modified Annex II to add certain agricultural products. These modifications were retroactive to November 13.
  • Authority: Exec. Order 14257 (Apr. 2, 2025) (as amended)
Country-Specific Reciprocal Tariffs   ▸ (effective Aug. 7, 2025; declared invalid Feb. 20, 2026)
  • Exemptions: See Baseline Reciprocal Tariffs and Exemptions above
  • Rates:
    • Afghanistan: 15%
    • Algeria: 20%
    • Angola: 15%
    • Bangladesh: 20%
    • Bolivia: 15%
    • Bosnia and Herzegovina: 30%
    • Botswana: 15%
    • Brazil: 10%
    • Brunei: 25%
    • Cambodia: 19%
    • Cameroon: 15%
    • Chad: 15%
    • China (including Hong Kong and Macau): 10% (as of Feb. 20, 2026); previously as high as 125%
    • Costa Rica: 15%
    • Côte d’Ivoire: 15%
    • Democratic Republic of Congo: 15%
    • Dominican Republic: 25%
    • Ecuador: 10%
    • El Salvador: 10%
    • Equatorial Guinea: 15%
    • European Union:
      • 0% for all products with a Column 1 Duty Rate ≥ 15%
      • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%
    • Falkland Islands: 10%
    • Fiji: 10%
    • Guatemala: 10%
    • Ghana: 15%
    • Guyana: 15%
    • Iceland: 15%
    • India: 25%
    • Indonesia: 19%
    • Iraq: 35%
    • Israel: 15%
    • Japan:
      • 0% for all products with a Column 1 Duty Rate ≥ 15%
      • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%
    • Jordan: 15%
    • Kazakhstan: 25%
    • Laos: 40%
    • Lesotho: 15%
    • Libya: 30%
    • Liechtenstein: 15%
    • Madagascar: 15%
    • Malawi: 15%
    • Malaysia: 19%
    • Mauritius: 15%
    • Moldova: 25%
    • Mozambique: 15%
    • Myanmar (Burma): 40%
    • Namibia: 15%
    • Nauru: 15%
    • Nicaragua: 18%
    • Nigeria: 15%
    • North Macedonia: 15%
    • Pakistan: 19%
    • Philippines: 19%
    • Serbia: 35%
    • South Africa: 30%
    • South Korea:
      • 0% for all products with a Column 1 Duty Rate ≥ 15%
      • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%
    • Sri Lanka: 25%
    • Switzerland: 39%
    • Syria: 41%
    • Taiwan: 20%
    • Thailand: 19%
    • Trinidad and Tobago: 15%
    • Tunisia: 25%
    • Turkey: 15%
    • Uganda: 15%
    • United Kingdom: 10%
    • Vanuatu: 15%
    • Venezuela: 15%
    • Vietnam: 20%
    • Zambia: 15%
    • Zimbabwe: 15%
  • Authority: Exec. Order 14257 (Apr. 2, 2025) (as amended)
Brazil “Free Speech” Tariffs   ▸ (effective Aug. 6, 2025; declared invalid Feb. 20, 2026)
  • Rate: 40%
  • Exemptions:
    • Products classified in the 8-digit HTSUS subheadings listed in Annex I to Exec. Order 14323 (revised Nov. 20, 2025)
    • Products subject to Section 232 tariffs
  • Authority: Exec. Order 14323 (July 30, 2025) (as amended)
Canada, China, and Mexico “Fentanyl” Tariffs   ▸ (effective Feb. 4, 2025 for China and Mar. 4, 2025 for Canada and Mexico; declared invalid Feb. 20, 2026)
  • Canada:
    • 0% for goods entered duty-free under the United States-Mexico-Canada Agreement (USMCA)
    • 10% for energy, energy resources, and potash
    • 35% for all other products (as of Feb. 20, 2026); previously 25%
    • 40% transshipment penalty in lieu of the applicable “fentanyl” tariff rate
  • China: 10% (as of Feb. 20, 2026); previously 20%
  • Mexico:
    • 0% for goods entered duty-free under the United States-Mexico-Canada Agreement (USMCA)
    • 10% for potash
    • 25% for all other products
  • Authorities: Exec. Order 14193 (Feb. 1, 2025) (as amended) (Canada); Exec. Order 14195 (Feb. 1, 2025) (as amended) (China); Exec. Order 14194 (Feb. 1, 2025) (as amended) (Mexico)
India Secondary Tariffs   ▸ (effective Aug. 27, 2025; terminated Feb. 7, 2026; declared invalid Feb. 20, 2026)
  • Rate: 25%
  • Exemptions:
    • Products listed in Annex II (as amended) to Exec. Order 14257
    • Products subject to Section 232 tariffs
  • Authority: Exec. Order 14329 (Aug. 6, 2025) (as amended)
Stacking of Invalidated Tariffs   ▸
  • The following duties and tariffs always stacked on top of any other applicable tariffs:
    • General duties.
    • Any applicable antidumping or countervailing duties.
    • Any applicable Section 301 tariffs on Chinese-origin goods.
    • Any applicable “fentanyl” tariffs on Chinese-origin goods.
  • The product-specific Section 232 tariffs were subject to the following stacking rules:
    • The automobile, automobile parts, bus, MHDVs, and MHDV parts tariffs did not stack on top of (a) any other Section 232 tariffs, (b) any applicable reciprocal tariffs, or (c) any applicable “fentanyl” tariffs on Canadian- or Mexican-origin goods.
    • The aluminum and steel tariffs could stack on top of each other if the product is subject to both.
    • The aluminum, steel, copper, lumber, and semiconductor tariffs did not stack on top of (a) any applicable reciprocal tariffs or (b) any applicable “fentanyl” tariffs on Canadian- or Mexican-origin goods.
Tariff Threats   ▸
  • Secondary tariffs on countries that import Venezuelan oil (Exec. Order 14125 (Mar. 24, 2025))
  • A 25–50% secondary tariff on imports from any country that imports Iranian- or Russian-origin oil (threatened Mar. 30, 2025)
  • A 100% secondary tariff on imports from any country that purchases Russian-origin goods (threatened July 14, 2025)
  • A 200% additional tariff on Chinese-origin imports in response to China’s rare earth export controls (threatened Aug. 25, 2025)
  • A 50–100% additional tariff on Chinese-origin imports until the war in Ukraine ends (threatened Sept. 13, 2025)
  • A 100% additional tariff on Chinese-origin imports in response to China’s expanded rare earth export controls (threatened Oct. 10, 2025)
  • An additional 5% tariff on Mexican-origin imports related to a dispute over Mexico’s failure to meet 1944 treaty obligations for water deliveries from the Rio Grande (threatened Dec. 9, 2025)
  • Additional tariffs (10% February 1 May 31 and then 25% starting June 1) on Finland, France, Germany, the Netherlands, Norway, Sweden, and the United Kingdom for deploying troops to Greenland (threatened Jan. 17, 2026; threat withdrawn Jan. 21, 2026)
  • A 100% additional tariff on Canadian-origin imports if Canada enters into a trade deal with China (threatened Jan. 24, 2026)
  • Secondary tariffs on countries that sell or provide oil to Cuba (Exec. Order 14380 (Jan. 29, 2026))
  • Secondary tariffs on countries that directly or indirectly purchase, import, or otherwise acquire goods or services from Iran (Exec. Order 14382 (Feb. 6, 2026))

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Worldwide, product-specific tariffs

🔔 Updated: September 2, 2026 at 11:00 AM ET

ProductStatusAd Valorem RateScopeExemptions & Notes
Agricultural productsThreatened
(Mar. 3, 2025)		TBDTBD
Aluminum articles and derivative productsImplemented
(effective Mar. 12, 2025; increased June 4, 2025; amended June 16, 2025; amended effective Apr. 6, 2026)		Russia: 200% if the product is Russian origin, contains any amount of primary aluminum smelted in Russia, or is cast in Russia

Annex I-A aluminum and derivative articles:
(a) 25% for UK-origin products with at least 95% of the aluminum content smelted or most recently cast in the United Kingdom
(b) 10% for derivatives with at least 95% of the aluminum content smelted and cast in the United States
(c) 50% for all other products

Annex I-B aluminum derivatives:
(a) 15% for UK-origin products with at least 95% of the aluminum content smelted or most recently cast in the United Kingdom
(b) 10% for derivatives with at least 95% of the aluminum content smelted and cast in the United States
(c) 25% for all other products

Annex III aluminum derivatives (Apr. 6, 2026 through Dec. 31, 2027):
(a) 0% for products with a Column 1 Duty Rate ≥ 15%
(b) 0% for products with at least 95% of the aluminum content smelted and cast in the United States and a Column 1 Duty Rate ≥ 10%
(c) 10% minus Column 1 Duty Rate for products with at least 95% of the aluminum content smelted and cast in the United States and a Column 1 Duty Rate < 10%
(d) 15% minus Column 1 Duty Rate for products with a Column 1 Duty Rate < 15%
(e) 25% for Belarusian-, Cuban-, and North Korean-origin goods		See Note 19, Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

Calculation (June 4, 2025 through Apr. 5, 2026):
(a) Aluminum tariff applies to the known value of the aluminum content
(b) Remaining value is subject to the applicable reciprocal tariff (or “fentanyl” tariff for Canadian- and Mexican-origin goods)

Calculation (starting Apr. 6, 2026): tariff applies to the full value of the good

Exemptions:
(a) Annex IV aluminum weight exemption
(effective Apr. 6, 2026)
(b) UK aerospace exemption
(effective June 23, 2025)
(c) EU aerospace exemption
(effective Sept. 1, 2025)
(d) Japan aerospace exemption
(effective Sept. 16, 2025)
(e) Taiwan aerospace exemption
(effective May 1, 2026)
Details   ▸
    Annex IV aluminum weight exemption: The exemption applies if: (1) the article is listed by HTSUS subheading in Annex IV(A)(c); (2) the article is not classified in Chapter 76; and (3) the aluminum is less than 15% of the article’s weight.

    UK aerospace exemption: applies to products that fall under the WTO Agreement on Trade in Civil Aircraft

    On or after July 9, 2025, the Secretary of Commerce may adjust the tariff rate for UK-origin products or implement import quotas, consistent with the U.S.-UK Economic Prosperity Deal announced on May 8, 2025.

    EU aerospace exemption: applicable products listed by HTSUS classification that satisfy the scope limitations in U.S. Note 2(v)(xviii), Subchapter III, Chapter 99, HTSUS

    Japan aerospace exemption: applies to products that fall under the WTO Agreement on Trade in Civil Aircraft (except unmanned aircraft)

    Stacking (Mar. 4 – June 4, 2025): goods that are also subject to (a) the Section 232 tariffs on automobiles or automobile parts or (b) the tariffs on Canadian- and Mexican-origin goods are not subject to Section 232 tariffs on aluminum and derivative products

    All country exclusions from the existing Section 232 tariffs on aluminum and derivative aluminum articles are revoked.

    Individual exclusions and General Authorized Exclusions are also being revoked.

    References:
    Procl. 11021 (Apr. 2, 2026)
    90 Fed. Reg. 43136 (Sept. 25, 2025)
    Exec. Order 14345 (Sept. 4, 2025)
    Exec. Order 14309 (June 16, 2025)
    Proclamation 10947 (June 3, 2025)
    Exec. Order 14289 (Apr. 29, 2025)
    Proclamation 10895 (Feb. 10, 2025)
AutomobilesImplemented
(effective Apr. 3, 2025; amended June 16, 2025)		25%

Modified rate for products of EU Member States, Japan, or South Korea:
(EU rate effective Aug. 1, 2025; Japan rate effective Sept. 16, 2025; South Korea rate effective Nov. 1, 2025)
  • 0% for all products with a Column 1 Duty Rate ≥ 15%
  • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%
See Note 33(a)-(e), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

EU rate:
Threatened increase to 25%
(May 1, 2026)

South Korea rate:
Threatened increase to 25%
(Jan. 27, 2026)

Calculation: If the product qualifies for preferential treatment under the USMCA, the tariff applies to the non-U.S. content.

UK aerospace exemption: products that fall under the WTO Agreement on Trade in Civil Aircraft
(effective June 23, 2025)
Details   ▸
Automobile partsImplemented
(effective May 3, 2025; amended June 16, 2025)		UK-origin products for use in UK-origin automobiles: 10% (including any most-favored nation duties)

All other countries: 25%

Modified rate for products of EU Member States, Japan, South Korea, or Taiwan:
(EU rate effective Aug. 1, 2025; Japan rate effective Sept. 16, 2025; South Korea rate effective Nov. 1, 2025; Taiwan rate effective May 1, 2026)
  • 0% for all products with a Column 1 Duty Rate ≥ 15%
  • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%
See Note 33(g)-(h), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

Exemptions:
USMCA
(effective Mar. 26, 2025)

Potential reductions:
(a) Domestic vehicle manufacturer’s import adjustment
(b) Domestic engine manufacturer’s import adjustment
Details   ▸
    Potential reductions:
    (a) Automobile manufacturers can apply for an import adjustment offset equal to 3.75% of the aggregate MSRP value of all automobiles they assemble in the United States from April 5, 2025 through April 30, 2030. The import adjustment will be applied to parts accounting for 15% of an automobile’s value. To be included in the import adjustment calculation, vehicles must undergo final assembly in the United States.
    (b) Commerce will establish a similar import adjustment for engine manufacturers. The offset accrual will be based on the aggregate value of automobile engines they assemble in the United States.

    Drawback eligibility: manufacturing drawback only
    (effective Oct. 17, 2025)

    References:
    Fed. Reg. Doc. 2025-21940 (filed Dec. 3, 2025)
    Procl. 10984 (Oct. 17, 2025)
    90 Fed. Reg. 43136 (Sept. 25, 2025)
    Exec. Order 14345 (Sept. 4, 2025)
    Exec. Order 14309 (June 16, 2025)
    Exec. Order 14289 (Apr. 29, 2025)
    Proclamation 10908 (Mar. 26, 2025)
Commercial aircraft and jet engines
Sec. 232 Invest.		Threatened
(May 13, 2025)		TBDTBD
Details   ▸
CopperImplemented
(effective Aug. 1, 2025; amended effective Apr. 6, 2026)		Annex I-A copper articles:
(a) 10% for derivatives with at least 95% of the copper content smelted and cast in the United States
(c) 50% for all other products

Annex I-B copper articles:
(b) 10% for articles with at least 95% of the copper content smelted and cast in the United States
(c) 25% for all other products		See Note 36, Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

Calculation (Aug. 1, 2025 through Apr. 5, 2026):
(a) Copper tariff applies to the known value of the copper content
(b) Remaining value is subject to the applicable reciprocal tariff (or “fentanyl” tariff for Canadian- and Mexican-origin goods)

Calculation (starting Apr. 6, 2026): tariff applies to the full value of the good

Exemptions:
(a) Annex IV copper weight exemption
(effective Apr. 6, 2026)
(b) EU aerospace exemption
(effective Sept. 1, 2025)
(c) Japan aerospace exemption
(effective Sept. 16, 2025)
(d) Taiwan aerospace exemption
(effective May 1, 2026)
Details   ▸
Integrated circuits
Sec. 232 Invest.		Threatened
(Aug. 6, 2025)		100%TBDSee semiconductors, semiconductor equipment, and derivative products below
Details   ▸
    On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of legacy chips, leading-edge chips, and microelectronics.

    References:
    90 Fed. Reg. 15950 (Apr. 16, 2025)
iPhonesThreatened
(May 23, 2025)		25%TBD
Lumber, timber, and derivative productsSoftwood timber and lumber
Implemented
(effective Oct. 14, 2025)		10%See Note 37(a)-(b), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification
Details   ▸
    HTSUS 4403.11.00, 4403.21.01, 4403.22.01, 4403.23.01, 4403.24.01, 4403.25.01, 4403.26.01, 4403.99.01, 4406.11.00, 4406.91.00, 4407.11.00, 4407.12.00, 4407.13.00, 4407.14.00, 4407.19.00
See stacking explanation below
Details   ▸
Upholstered wooden furniture:
Implemented
(effective Oct. 14, 2025)		UK-origin products: 10%

EU Member State-, Japan-, South Korea-, and Taiwan-origin products:
(EU and Japan rate effective Oct. 14, 2025; South Korea rate effective Nov. 14, 2025; modified Dec. 31, 2025; Taiwan rate effective May 1, 2026)
  • 0% for all products with a Column 1 Duty Rate ≥ 15%
  • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%

All other countries:
  • 25% (Oct. 14–Dec. 31, 2026)

  • 30% (starting Jan. 1, 2027)
See Note 37(c)-(d), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification
Details   ▸
    HTSUS 9401.61.4011, 9401.61.4031, 9401.61.6011, 9401.61.6031
See stacking explanation below

South Korea rate:
Threatened increase to 25%
(Jan. 27, 2025)
Details   ▸
Kitchen cabinets and vanities:
Implemented
(effective Oct. 14, 2025)		UK-origin products: 10%

EU Member State-, Japan-, South Korea-, and Taiwan-origin products:
(EU and Japan rate effective Oct. 14, 2025; South Korea rate effective Nov. 14, 2025; modified Dec. 31, 2025; Taiwan rate effective May 1, 2026)
  • 0% for all products with a Column 1 Duty Rate ≥ 15%
  • 15% minus Column 1 Duty Rate for all products with a Column 1 Duty Rate < 15%

All other countries:
  • 25% (Oct. 14–Dec. 31, 2026)
  • 50% (starting Jan. 1, 2027)
See Note 37(e)-(f), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification
Details   ▸
    HTSUS 9403.40.9060, 9403.60.8093, 9403.91.0080

    Includes finished kitchen cabinets and vanities, as well as parts imported for use in kitchen cabinets and vanities
See stacking explanation below

South Korea rate:
Threatened increase to 25%
(Jan. 27, 2025)
Details   ▸
Maritime cargo handling equipmentIntermodal chassis and chassis parts:
Delayed until Nov. 10, 2026
(effective Nov. 10, 2025)		100%See Note 31(k)(i)-(ii), Subchapter III, Chapter 99, HTSUS

Chinese-origin products (HTSUS 8716.39.0090, 8716.90.30, 8716.90.50)
Details   ▸
Ship-to-shore gantry cranes:
Delayed until Nov. 10, 2026
(effective Nov. 10, 2025)		100%HTSUS 8426.19.00

STS cranes that are:
(a) Chinese origin;
(b) manufactured, assembled, or made using Chinese-origin components; or
(c) manufactured anywhere in the world by a company owned, controlled, or substantially influenced by a Chinese national
Details   ▸
    See Note 31(l)(v), Subchapter III, Chapter 99, HTSUS defining owned, controlled, or substantially influenced by a Chinese national

    Chinese-origin components: The following Chinese-origin components, assemblies, and subassemblies bring non-Chinese-origin STS cranes within the tariffs’ scope: the boom, trolley, spreader, cabin, legs, cable reel, power supply, bogie set and wheels, and any information technology equipment used to operate or control the crane.
Exemptions: cranes fulfilling a contract for sale executed before April 17, 2025 and entered for consumption or withdrawn from warehouse before April 17, 2027
Details   ▸
Rubber tire gantry cranes, rail mounted gantry cranes, automatic stacking cranes, reachstackers, straddle carriers, terminal tractors and parts, top handlers/top loaders, and components of these items
Threatened
(Oct. 15, 2025)		150%HTSUS 8701.95.50, 8709.11.00, 8709.19.00, 8709.90.00, 8426.12.00, 8426.19.00, 8426.41.00, 8426.49.00, 8427.20.80, 8429.51.10, 8429.51.50, 8431.20, 8431.41.00, 8431.49.10
Details   ▸
MoviesThreatened
(May 4, 2025)		100%All foreign-produced moviesPresident Trump authorized Commerce and the USTR to initiate an investigation to implement these tariffs.
Oil and gasThreatened to start Feb. 18, 2025
(Jan. 31, 2025)		TBDTBD
Personal protective equipment, medical consumables, and medical equipment (including devices)
Sec. 232 Invest.		Threatened
(Sept. 24, 2025)		TBDTBD
Details   ▸
    On September 2, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of personal protective equipment, medical consumables, and medical equipment (including devices).

    “Personal protective equipment” (PPE) refers to PPE used in health care settings. PPE includes, but is not limited to, surgical masks, N95 respirators, gloves, gowns, and related medical parts and components.

    “Medical consumables” refers to single-use or short-term-use items used for patient diagnosis, treatment, and prevention of conditions. Medical consumables include but are not limited to: medical/surgical instruments (e.g., syringes, needles, infusion (IV) pumps, forceps, scalpels); medical/surgical supplies (e.g., intravenous (IV) bags, catheters, tracheostomy tubes, anesthesia equipment, gauze/bandages, sutures, diagnostic and laboratory reagents); and related medical parts and components. Pharmaceuticals, such as prescription drugs, over-the-counter drugs, biologics, and specialty drugs, will not be covered under this investigation as those imports are being examined in a separate Section 232 investigation.

    “Medical equipment” refers broadly as durable equipment, tools, and machines used in healthcare to support patient care. Examples include but are not limited to: carriages and wheelchairs; crutches; and hospital beds.

    A “medical device” is any instrument, apparatus, or machine used in the diagnosis, monitoring, or treatment of medical conditions. Examples include but are not limited to: pacemakers; insulin pumps; coronary stents; heart valves; hearing aids; robotic and non-robotic prosthetics; blood glucose monitors; orthopedic appliances; electromedical apparatus (e.g., computed tomography scanners, magnetic resonance imaging machines); electrosurgical apparatus; x-ray apparatus/other radiation equipment; respiratory machines (e.g., ventilators, respirators, oxygen apparatus); and MRI machines.
Details   ▸
Pharmaceuticals, pharmaceutical ingredients, and derivative products
Sec. 232 Invest.		Implemented
(effective July 31, 2026)		Article IV products and ingredients: 0%

Article I products and ingredients:
(a) 0% for companies listed in Annex II until Jan. 20, 2029
(b) 0% for companies listed in Annex III until Sept. 29, 2026
(c) 0% for items with a Column 1 Duty Rate ≥ 100%
(d) 0% for EU-, Japanese-, Liechtenstein-, South Korean-, and Swiss-origin items with a Column 1 Duty Rate ≥ 15%
(e) 10% for UK-origin items
(f) 15% minus Column 1 Duty Rate for EU-, Japanese-, Liechtenstein-, South Korean-, and Swiss-origin items with a Column 1 Duty Rate < 15%
(g) 20% of items subject to a qualifying onshoring plan
(h) 100% minus minus Column 1 Duty Rate for items with a Column 1 Duty Rate < 100%		See U.S. Note 40(c), Subchapter III, Chapter 99, HTSUS

Patented pharmaceutical articles and ingredients for those articles

Applies by HTSUS classification
Details   ▸
    “Pharmaceutical articles” means imported articles classified in U.S. Note 40(c), Subdivision III, Chapter 99, HTSUS, that are pharmaceutical products or ingredients (active pharmaceutical ingredients and key starting materials) used to make pharmaceutical products.

    “Patented pharmaceutical articles” are pharmaceutical articles that are subject to a valid, unexpired U.S. patent and are listed in the U.S. Food and Drug
    Administration’s (FDA) Approved Drug Products with Therapeutic Equivalence Evaluations (Orange Book) or in the FDA’s Lists of Licensed Biological Products (Purple Book); and ingredients (active pharmaceutical ingredients and key starting materials) for such articles.

    “Generic pharmaceutical articles” are FDA-approved pharmaceutical articles, and associated ingredients, that are not subject to a valid, unexpired U.S. patent and are off exclusivity. A generic pharmaceutical article is an active pharmaceutical ingredient or any component in a finished dosage form product that is used in a drug product or biosimilar biological product approved pursuant to a qualifying application; or a drug product or biosimilar biological product approved or licensed pursuant to a qualifying application. A qualifying application is: (a) an abbreviated new drug application submitted under Section 505(j) of the Federal Food, Drug, and Cosmetic Act (FDCA); (b) a new drug application submitted under Section 505(b)(2) of the FDCA that has been requested to be or that has been deemed therapeutically equivalent to a listed drug; (c) a biosimilar biologics application submitted under Section 351(k) of the Public Health Services Act; or (d) an application for an authorized generic drug or authorized biological product, as those terms are described in Section 505(t) of the FDCA and 42 U.S.C. § 1320f-1(e)(2)(B)(ii), provided that the products are imported by a generic or biosimilar manufacturer.
See stacking explanation below

Exemptions:
(a) Generic pharmaceutical articles
(b) Items classified in an HTSUS subheading enumerated in U.S. Note 40(c) but that are not pharmaceutical articles
Details   ▸
Polysilicon and its derivatives
Sec. 232 Invest.		Implemented
(effective Dec. 4, 2026)		Minimum import prices:
(a) $21 per kilogram for polysilicon
(b) $100 per kilogram for polysilicon ingots and wafers
(c) $0.22 per watt for solar cells
(d) $0.38 per watt for solar modules

Tariff rate:
(a) 10% for the United Kingdom
(b) 15% inclusive of the Column 1 Duty Rate for EU Member States, Japan, Liechtenstein, South Korea, Switzerland, and Taiwan
(c) 15% for all other countries		Applies by HTSUS classificationOnshoring program: The Secretary of Commerce may allow companies with approved onshoring plans to import necessary production equipment and covered products without paying Section 232 duties during facility construction.
Details   ▸
    The Secretary is authorized to adjust the minimum import prices from time to time to reflect market conditions. If CBP determines that an importer’s documentation was materially inaccurate, that importer and its affiliates shall permanently be prohibited from importing polysilicon and polysilicon derivatives into the United States.

    If a trading partner establishes a substantially equivalent minimum import price, the Secretary may alter the applicability of the MIP and tariffs to products from that trading partner.

    Drawback eligibility: manufacturing drawback only (for Trade Agreement Partner products where polysilicon content is entirely from a Trade Agreement Partner country)

    References:
    Proclamation 11052 (Aug. 6, 2026)
    90 Fed. Reg. 31955 (July 16, 2025)
Processed critical minerals and derivative products
Sec. 232 Invest.		Threatened
(Apr. 15, 2025; initial action taken Jan. 14, 2026)		TBDTBDThe Secretary of Commerce and USTR will negotiate agreements to address the threatened impairment of national security. A status report is due to the President by July 13.
Details   ▸
    “Processed critical minerals” are critical minerals that have undergone activities that occur after critical mineral ore is extracted from a mine up through its conversion into a metal, metal powder, or a master alloy.

    “Derivative products” include all goods that incorporate processed critical minerals as inputs, including semi-finished goods (e.g., semiconductor wafers, anodes, cathodes) and final products (e.g., permanent magnets, motors, electric vehicles, batteries, smartphones, microprocessors, radar systems, wind turbines and their components, advanced optical devices).

    On April 22, Commerce initiated a Section 232 investigation to determine the effects on the national security of imports of processed critical minerals, as well as their derivative products.

    References:
    Procl. 11001 (Jan. 14, 2026)
    90 Fed. Reg. 17372 (Apr. 25, 2025)
    Exec. Order 14272 (Apr. 16, 2025)
Robotics and industrial machinery
Sec. 232 Invest.		Threatened
(Sept. 24, 2025)		TBDTBD
Details   ▸
    On September 2, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of robotics and industrial machinery.

    “Robotics and industrial machinery” includes, among other things, robots and programmable, computer-controlled mechanical systems. This equipment spans CNC machining centers, turning and milling machines, grinding and deburring equipment, and industrial stamping and pressing machines. It also includes automatic tool changers, jigs and fixtures, and machine tools for cutting, welding, and handling work pieces. Application-specific specialty metalworking equipment used to treat, form, or cut metal, such as autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery is also included. Unmanned aircraft systems are not covered.
Details   ▸
Semiconductors, semiconductor manufacturing equipment, and derivative products
Sec. 232 Invest.		Implemented
(effective Jan. 15, 2026)		25%Logic integrated circuits or articles that contain a logic integrated circuit; are classified in HTSUS 8471.50, 8471.80, 8473.30; and meet certain technical parameters
Details   ▸
    To be included within the definition of semiconductor articles, the imported products must be a logic integrated circuit, or an article that contains a logic integrated circuit, that meets the technical parameters of having:
    (1) a total processing performance greater than 14,000 and less than 17,500, and a total DRAM bandwidth greater than 4,500 GB/s and less than 5,000 GB/s; or
    (2) a total processing performance greater than 20,800 and less than 21,100, and total DRAM bandwidth greater than 5,800 GB/s and less than 6,200 GB/s.

    “Total processing performance” and “total DRAM bandwidth” are defined in Note 39(b), Subchapter III, Chapter 99, HTSUS.
See stacking explanation below

Exemptions:
(a) Use in U.S. data centers
(b) For repairs or replacements performed in the United States
(c) For research and development in the United States involving covered chips
(d) Use by startups in the United States
(e) Use in non-data center consumer electronics applications in the United States
(f) Use in non-data center civil industrial applications in the United States
(g) Use in U.S. public sector applications
Details   ▸
    Commerce is required to continue monitoring imports of semiconductors; semiconductor manufacturing equipment; and derivative products, including downstream products that contain semiconductors. By July 1, 2026, Commerce must provide the President with an update on the market for semiconductors used in U.S. data centers, so the President can determine whether tariff modifications are appropriate.

    For the purposes of the exemptions:
    “U.S. data center” refers to a facility that requires greater than 100 MW of new load dedicated to AI inference, training, simulation, or synthetic data generation.
    “Research and development” means any activity that is (a) a systematic, intensive study directed toward greater knowledge or understanding of the subject studied; (b) a systematic study directed specifically toward applying new knowledge to meet a recognized need; or (c) a systematic application of knowledge toward the production of useful materials, devices, services or methods, and includes design, development and improvement of prototypes and new processes to meet specific requirements.
    “Startup” means an “emerging growth company,” as defined in 15 U.S.C. 77b(a)(19).

    References:
    Procl. 11002 (Jan. 14, 2026)
    90 Fed. Reg. 15950 (Apr. 16, 2025)
Steel articles and derivative productsImplemented
(effective Mar. 12, 2025; increased June 4, 2025; amended June 16, 2025)		Annex I-A steel and derivative articles:
(a) 25% for UK-origin products with at least 95% of the steel content melted and poured in the United Kingdom
(b) 10% for derivatives with at least 95% of the steel content melted and poured in the United States
(c) 50% for all other products

Annex I-B steel derivatives:
(a) 15% for UK-origin products with at least 95% of the steel content melted and poured in the United Kingdom
(b) 10% for derivatives with at least 95% of the steel content melted and poured in the United States
(c) 25% for all other products

Annex III steel derivatives (Apr. 6, 2026 through Dec. 31, 2027):
(a) 0% for products with a Column 1 Duty Rate ≥ 15%
(b) 0% for products with at least 95% of the steel content melted and poured in the United States and a Column 1 Duty Rate ≥ 10%
(c) 10% minus Column 1 Duty Rate for products with at least 95% of the aluminum content melted and poured in the United States and a Column 1 Duty Rate < 10%
(d) 15% minus Column 1 Duty Rate for products with a Column 1 Duty Rate < 15%
(e) 25% for Belarusian-, Cuban-, North Korean-, and Russian-origin goods		See Note 16, Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification

Reduced
127 HTSUS subheading removed by Annex II to the April 2, 2026 proclamation
(effective Apr. 6, 2026)		See stacking explanation below

Calculation (June 4, 2025 through Apr. 5, 2026):
(a) Steel tariff applies to the known value of the steel content
(b) Remaining value is subject to the applicable reciprocal tariff (or “fentanyl” tariff for Canadian- and Mexican-origin goods)

Calculation (starting Apr. 6, 2026): tariff applies to the full value of the good

Exemptions:
(a) Annex IV steel weight exemption
(effective Apr. 6, 2026)
(b) EU aerospace exemption
(effective Sept. 1, 2025)
(c) Japan aerospace exemption
(effective Sept. 16, 2025)
(d) Taiwan aerospace exemption
(effective May 1, 2026)
Details   ▸
    Annex IV aluminum weight exemption: The exemption applies if: (1) the article is listed by HTSUS subheading in Annex IV(A)(c); (2) the article is not classified in Chapters 72 or 73; and (3) the steel is less than 15% of the article’s weight.

    UK aerospace exemption: applies to products that fall under the WTO Agreement on Trade in Civil Aircraft

    On or after July 9, 2025, the Secretary of Commerce may adjust the tariff rate for UK-origin products or implement import quotas, consistent with the U.S.-UK Economic Prosperity Deal announced on May 8, 2025.

    EU aerospace exemption: applicable products listed by HTSUS classification that satisfy the scope limitations in U.S. Note 2(v)(xviii), Subchapter III, Chapter 99, HTSUS

    Japan aerospace exemption: applies to products that fall under the WTO Agreement on Trade in Civil Aircraft (except unmanned aircraft)

    Stacking (Mar. 4 – June 4, 2025): goods that are also subject to (a) the Section 232 tariffs on automobiles or automobile parts or (b) the tariffs on Canadian- and Mexican-origin goods are not subject to the Section 232 tariffs on steel and derivative products

    All country exclusions from the existing Section 232 tariffs on aluminum and derivative aluminum articles are revoked. Individual exclusions and General Authorized Exclusions are also being revoked.

    References:
    Procl. 11021 (Apr. 2, 2026)
    90 Fed. Reg. 43136 (Sept. 25, 2025)
    Exec. Order 14345 (Sept. 4, 2025)
    Exec. Order 14309 (June 16, 2025)
    90 Fed. Reg. 25208 (June 16, 2025)
    Proclamation 10947 (June 3, 2025)
    Exec. Order 14289 (Apr. 29, 2025)
    Proclamation 10896 (Feb. 10, 2025)
Trucks and truck partsMedium- and heavy-duty vehicles:
Implemented
(effective Nov. 1, 2025)		25%See Note 38(b), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

EU rate:
Threatened increase to 25%
(May 1, 2026)

Exemption: Vehicles manufactured 25+ years ago

Potential reduction: USMCA (if approved by Commerce on an importer-by-importer basis)
Details   ▸
    Potential reduction: Importers of vehicles that qualify for preferential treatment under the USMCA can submit documentations to the Secretary of Commerce identifying the amount of U.S. content in each model imported into the United States. “U.S. content” means the value of the vehicle attributable to U.S.-based activity supporting domestic production. If approved, the tariff will only apply to the value of the vehicle’s non-U.S. content.

    References:
    Procl. 10984 (Oct. 17, 2025)
    90 Fed. Reg. 17371 (Apr. 25, 2025)
Buses:
Implemented
(effective Nov. 1, 2025)		10%See Note 38(c), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

Exemption: Vehicles manufactured 25+ years ago
Details   ▸
Medium- and heavy-duty vehicle parts:
Implemented
(effective Nov. 1, 2025)		25%See Note 38(i), Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification		See stacking explanation below

Exemption: USMCA

Potential reduction: Domestic manufacturer’s import adjustment
Details   ▸
    Exemption: With the exception of knock-down kits or equivalent parts compilations (as determined by CBP), parts that qualify for preferential treatment under the USMCA will be exempt until Commerce and CBP establish a process for applying the tariff to only the value of the parts’ non-U.S. content.

    Potential reduction: Medium- and heavy-duty vehicle (MHDV) manufacturers can apply for an import adjustment offset equal to 3.75% of the aggregate value of all MHDVs they assemble in the United States from November 1, 2025 through October 31, 2030. The import adjustment will be applied to parts accounting for 15% of the MHDV’s value. To be included in the import adjustment calculation, the MHDV must undergo final assembly in the United States.

    Drawback eligibility: manufacturing drawback only
    (effective Oct. 17, 2025)

    References:
    Procl. 10984 (Oct. 17, 2025)
    90 Fed. Reg. 17371 (Apr. 25, 2025)
Unmanned aircraft systems and their parts and components
Sec. 232 Invest.		Implemented
(effective Sept. 3, 2026; Annex III components effective Feb. 9, 2027)		Annex I (UAS >25 kg, UAS with thermal imagers, docking stations, and critical components): 100%

Annex II (UAS ≤25 kg): 25%

Annex III (certain UAS components): 25%
(effective Feb. 9, 2027)

Modified rate for products of EU Member States, Japan, Liechtenstein, South Korea, Switzerland, or Taiwan: 15% (inclusive of the Column 1 Duty Rate)

Modified rate for products of the United Kingdom: 10%		UAS and UAS components as specified in Annexes I, II, and III to the proclamation

Applies by HTSUS classification		Blue UAS delay: For companies on the DoD’s Blue UAS Cleared List, Blue UAS Framework, or the FCC’s Conditional Approval List on September 2, 2026, the effective date is 180 days from the date of the proclamation for covered products and their components.

Onshoring program: The Secretary of Commerce may allow companies with approved onshoring plans to import covered products and production equipment without paying Section 232 duties during facility construction. Construction must occur before January 20, 2029.
Details   ▸
    The modified trade deal partner rates apply only if substantially all the critical components and technology are certified by importers to be products of the U.S., Japan, South Korea, Taiwan, Switzerland, Liechtenstein, an EU member nation, or the United Kingdom.

    Drawback eligibility: manufacturing drawback only (for Trade Agreement Partner products where at least 85% of content is from Trade Agreement Partners)

    References:
    Proclamation 11055 (Aug. 13, 2026)
    90 Fed. Reg. 31985 (July 16, 2025)
Wind turbines and their parts and components
Sec. 232 Invest.		Threatened
(Aug. 21, 2025)		TBDTBD
Details   ▸
    On August 13, Commerce initiated a Section 232 investigation to determine the effects on the national security of imports of wind turbines and their parts and components.

    References:
    90 Fed. Reg. 41380 (Aug. 25, 2025)

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Tariff stacking

The following duties and tariffs always stack on top of any other applicable tariffs:

  • General duties.
  • Any applicable antidumping or countervailing duties.
  • Any applicable Section 301 tariffs on Chinese-origin goods.

The product-specific Section 232 tariffs are subject to the following stacking rules:

  • The automobile, automobile parts, bus, MHDVs, and MHDV parts tariffs do not stack on top of (a) any other Section 232 tariffs or (b) any applicable Section 301 forced labor tariffs.
  • The aluminum and steel tariffs do not stack on top of each other if the product is subject to both.
  • The aluminum, steel, copper, lumber, pharmaceutical, and semiconductor tariffs do not stack on top of any applicable Section 301 forced labor tariffs.

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IEEPA tariff refund process

On April 20, 2026, U.S. Customs and Border Protection (CBP) launched the Consolidated Administration and Processing of Entries (CAPE) functionality within the Automated Commercial Environment (ACE) to streamline the submission and processing of valid IEEPA tariff refund requests.

Only importers of record and customs brokers who filed the original entries with CBP will be able to file refund requests (CAPE Declarations).

Current functionality

CAPE currently accepts CAPE Declarations for (1) unliquidated entries and (2) entries that liquidated within 80 days of the CAPE Declaration being accepted. This includes entries flagged for reconciliation. CAPE Declarations are not currently accepted for the following entries:

  • Entries designated on a drawback claim.
  • Entries covered by an open protest.
  • Entries not filed in ACE and entries without a liquidation status in ACE.
  • Entries subject to antidumping or countervailing duties (AD/CVDs) that are pending liquidating pursuant to Commerce-issued liquidation instructions.

The Government is currently appealing the portion of the CIT’s order requiring CBP to process refunds on finally liquidated entries. Instead, the Government’s current position is that only importers with pending refund cases before the CIT will be eligible for refunds on finally liquidated entries during CAPE Phase 3.

Refund timing

CBP anticipates electronic refunds generally being issued within 60-90 days of the CAPE Declaration being accepted. If a compliance concern is identified during CBP’s review, the refund processing may be delayed.

More information

For more information, visit CBP’s IEEPA Duty Refunds landing page.

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Updates and relevant publications

  • June 1, 2026: The USTR released a Federal Register notice proposing action on imports from Brazil under Section 301 of the Trade Act of 1974. Requests to appear at the public hearing must be submitted by June 22. Public comments are due by July 1.
  • Mar. 24, 2026: Commerce, working with the International Trade Administration (ITA), released a Federal Register notice announcing the opening of the inclusions window for the Section 232 automobile parts tariff inclusions process. The window will be open from April 1 to April 14. After the submission window closes, the submission window, accepted inclusion requests will be posted for a two-week public comment period on Docket ID ITA-2025-0040 on Regulations.gov.
  • Mar. 12, 2026: The USTR released a Federal Register notice initiating Section 301 investigations involving the following countries’ failure to impose and effectively enforce a ban on the importation of goods produced with forced labor: Algeria, Angola, Argentina, Australia, The Bahamas, Bahrain, Bangladesh, Brazil, Cambodia, Canada, Chile, China, Colombia, Costa Rica, Dominican Republic, Ecuador, Egypt, El Salvador, European Union, Guatemala, Guyana, Honduras, Hong Kong, India, Indonesia, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Malaysia, Mexico, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Pakistan, Peru, Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Taiwan, Thailand, Trinidad and Tobago, Turkey, United Arab Emirates, United Kingdom, Uruguay,  Venezuela, Vietnam. Public comments and requests to appear at the public hearing must be submitted by April 15. The public hearing will occur on May 5.
  • Mar. 11, 2026: The USTR released a Federal Register notice initiating Section 301 investigations involving Bangladesh, Cambodia, China, the European Union, India, Indonesia, Japan, Malaysia, Mexico, Norway, Singapore, South Korea, Switzerland, Taiwan, Thailand, Vietnam. Public comments and requests to appear at the public hearing must be submitted by April 15. The public hearing will occur on April 28.
  • Mar. 5, 2026: Podcast: The SCOTUS IEEPA ruling—Europe’s response and what it means for business
  • Feb. 24, 2026: Podcast: What comes next? Trump tariffs after the SCOTUS decision
  • Feb. 20, 2026: SCOTUS strikes down IEEPA tariffs; leaves refund question open
  • Dec. 6, 2025: Tariff refunds: What U.S. importers should know as the Supreme Court weighs the tariffs’ legality
  • Oct. 27, 2025: The USTR released a Federal Register notice announcing the initiation of a Section 301 investigation into China’s apparent failure to comply with the 2020 Economic and Trade Agreement Between the Government of the United States of America and the Government of the People’s Republic of China (Phase One Agreement). The docket for written comments will open on October 31, and comments must be submitted by December 1. The Section 301 Committee will convene a public hearing on December 16.
  • Oct. 15, 2025: The USTR released a Federal Register notice imposing 100% ad valorem tariffs on ship-to-shore (STS) cranes and certain Chinese-origin maritime cargo handling equipment. The USTR also proposed tariffs on additional Chinese-origin maritime cargo handling equipment. Public comments must be submitted by November 10.
  • Sept. 24, 2025: Commerce released Federal Register notices about newly initiated Section 232 investigations into (1) personal protective equipment, medical consumables, and medical equipment (including devices) and (2) robotics and industrial machinery. Public comments must be submitted by October 17.
  • Sept. 17, 2025: Commerce published an an interim final rule establishing the process for including additional automobile parts for passenger vehicles and light trucks within the scope of the Section 232 tariffs. Under the interim final rule, the International Trade Administration (ITA) will allow inclusion requests to be submitted by domestic producers of automobiles or automobile parts, or industry associations representing those producers, during four windows each year: at the beginning of January, April, July, and October. After the ITA’s review, non-confidential versions of the requests will be published for a 14-day comment period. The ITA will generate a decision memo on each request within 60 days of submission. A Federal Register notice will be issued shortly after the decision memo identifying the new automobile parts subject to the Section 232 tariffs. The October 2025 inclusion window will open on October 1.
  • Sept. 15, 2025: Commerce released a Federal Register notice announcing the opening of the inclusions window for the Section 232 steel and aluminum tariff inclusions process. The window will be open from September 15 to September 29. After the submission window closes, the submission window, accepted inclusion requests will be posted for a two-week public comment period on Docket ID BIS-2025-0023 on Regulations.gov.
  • Sept. 5, 2025: President Trump signed an executive order modifying Annex II to Executive Order 14257. Annex III to the executive order also identifies 1,908 HTSUS subheadings that are potentially eligible to be exempted from the reciprocal tariffs for each trading partner that concludes a trade agreement with the United States. Trade agreement-related exemptions will be determined by the Secretary of Commerce and U.S. Trade Representative.
  • Sept. 4, 2025: Tariff enforcement webinar: navigating DOJ’s new priorities and increased FCA risk
  • Aug. 29, 2025: The USTR released a Federal Register notice extending 178 Section 301 exclusions that were scheduled to expire on September 1. The exclusions will now remain valid through November 29, 2025. The extensions are available for any product that meets the description in the product exclusion.
  • Aug. 21, 2025: Commerce released a Federal Register notice about a newly initiated Section 232 investigation into wind turbines and their parts and components. Public comments must be submitted by September 9.
  • Aug. 15, 2025: Commerce released a Federal Register notice expanding the list of aluminum and steel derivative products subject to Section 232 tariffs. Effective August 18, 407 additional HTSUS codes will be considered aluminum and steel derivative products subject the Section 232 tariffs. The tariff will apply to the value of the aluminum or steel content in the derivative product. The non-aluminum or non-steel content will remain subject to any other applicable tariffs, including the reciprocal tariffs.
  • July 30, 2025: President Trump signed an executive order suspending the de minimis exemption, effective August 29, 2025. Shipments that are not sent through the international postal network will be subject to all applicable duties, tariffs, taxes fees, and exactions. Shipments sent through the international postal network will be subject to duties and tariffs based on the transportation carrier’s chosen methodology, which will either be: (a) duties and tariffs equal to the effective, applicable International Emergency Economic Powers Act (IEEPA) tariff rate assessed on the value of each package; or (b) a per package rate that varies depending on the effective, applicable IEEPA tariff rate. Under the per package methodology, the rates are: (1) $80 for countries with an effective IEEPA tariff rate less than 16%; (2) $160 for countries with a 16-25% effective IEEPA tariff rate; or (3) $200 for countries with an effective IEEPA tariff rate above 25%. “Effective IEEPA tariff rate” means the total “fentanyl” and reciprocal tariff rate that applies based on the product’s country of origin (after applying the “stacking” exceptions in Executive Order 14289, as amended). Transportation carriers may only update their methodology monthly. The exception for postal shipments may be revoked once the Secretary of Commerce informs the President that adequate systems are in place to fully and expeditiously process and collect duties applicable on all postal shipments.
  • July 30, 2025: President Trump issued a proclamation imposing Section 232 tariffs on certain semi-finished copper products and intensive copper derivative products, effective August 1. By October 28, the Secretary of Commerce will establish a process for including additional derivative copper articles within the scope of the Section 232 tariffs imposed under the proclamation.
  • July 17, 2025: The USTR announced a Section 301 investigation into Brazil’s acts, policies, and practices related to digital trade and electronic payment services; unfair, preferential tariffs; anti-corruption enforcement; intellectual property protection; ethanol market access; and illegal deforestation. A public hearing is scheduled for September 3, 2025. Written comments and requests to appear at the hearing are due on August 18.
  • July 14, 2025: Commerce released a Federal Register notice about newly initiated Section 232 investigations into (1) polysilicon and its derivatives and (2) unmanned aircraft systems and their parts and components. Public comments must be submitted by August 6, 2025.
  • July 14, 2025: DOJ dedicates significant resources to priority of investigating and prosecuting tariff evasion
  • June 27, 2025: In response to Canada’s decision to proceed with a 3% digital services tax (DST) on technology companies, President Trump terminated the United States’ trade discussions with Canada. The United States is expected to announce a new, Canada-specific tariff rate within seven days. It is not yet clear whether that tariff will be in addition to the “fentanyl” tariffs already in place for Canadian-origin goods that do not qualify for duty-free treatment under the USMCA.
  • June 12, 2025: Commerce released a Federal Register notice expanding the list of steel derivative products subject to Section 232 tariffs. The new products added to the steel derivatives list are: (1) combined refrigerator-freezers (8418.10.00 HTSUS); (2) small and large dryers (84521.21.00 and 8451.29.00); (3) washing machines (8450.11.00 and 8450.20.00 HTSUS); (4) dishwashers (8422.11.00 HTSUS); (5) chest and upright freezers (8418.30.00 and 8418.40.00 HTSUS); (6) cooking stoves, ranges, and ovens (8516.60.40 HTSUS); (7) food waste disposals (8509.80.20 HTSUS); and (8) welded wire rack (9403.99.9020 HTSUS).
  • June 3, 2025: President Trump issued a proclamation adjusting the Section 232 steel and aluminum tariff rates and amending Executive Order 14289. In addition to increasing the tariff rate, the proclamation imposes: (1) the increased tariff rate on imports of goods listed in the yet-to-be-published Annex II that were previously admitted to a free trade zone under privileged foreign status when entered for consumption; (2) only the value of the aluminum content of articles in Chapter 76 or the steel content of articles in Chapter 73 are subject to the increased tariff rate; and (3) the reciprocal tariffs on the non-aluminum, non-steel content of all aluminum and steel articles and derivates. Under the amended Executive Order 14289, goods subject the Section 232 tariffs on aluminum and steel articles or derivative products are not also subject to the tariffs on Canadian- or Mexican-origin goods. This exception was previously flipped.
  • June 3, 2025: The U.S. District Court for the District of Columbia stayed its preliminary injunction in Learning Resources v. Trump pending the outcome of the government’s appeal.
  • May 29, 2025: The U.S. District Court for the District of Columbia issued a preliminary injunction in Learning Resources v. Trump, concluding that the International Emergency Economic Powers Act does not enable the President to impose the “fentanyl” and reciprocal tariffs. The preliminary injunction only applied to the named plaintiffs. The government filed notice of its appeal and asked the court to issue a stay.
  • May 29, 2025: On May 29, the Court of Appeals for the Federal Circuit issued an immediate administrative stay of the CIT’s judgment and injunction. The plaintiffs-appellees have until June 5 to respond to the government’s motion for a stay. The government will have until June 9 to file a reply brief. The Federal Circuit will then consider the motion to stay the CIT’s judgment and injunction pending the outcome of the appeal. In the meantime, the “fentanyl” and reciprocal tariffs remain in effect.
  • May 29, 2025: Federal court permanent enjoins “fentanyl” and reciprocal tariffs; Trump requests stay
  • May 28, 2025: The Court of International Trade declared the executive orders implementing (1) the “fentanyl” tariffs on Canada, China, and Mexico and (2) the reciprocal tariffs invalid as contrary to law. The court permanently enjoined each of the relevant executive orders.
  • May 15, 2025: CBP released the HTSUS modifications to implement Executive Order 14289 (Addressing Certain Tariffs on Imported Articles). The executive order is retroactive for covered goods entered for consumption, or withdrawn for warehouse for consumption, on or after March 4. Importers may request refunds by filing post summary corrections or protests (as applicable).
  • May 13, 2025: Commerce released a Federal Register notice about a newly initiated Section 232 investigation into imports commercial aircraft and jet engines and parts of commercial aircraft and jet engines. Public comments must be submitted by June 3, 2025.
  • May 12, 2025: President Trump signed an executive order reducing the duties imposed on imports of Chinese-origin goods that would otherwise qualify for the de minimis exemption, effective May 14. Goods sent through the international postal network will be subject to duties of (a) 54% ad valorem or (b) $100 per item. The per item dollar amount will no longer increase to $200 on June 1.
  • May 8, 2025: The EU launched a public consultation on potential countermeasures to the U.S. automotive, reciprocal, and aluminum tariffs. These measures may be implemented if the EU’s negotiations with the United States are unsuccessful. Products under review for additional EU import duties include aircraft, automobiles, medical devices, IT equipment, and industrial machinery—covering €95 billion in U.S. originating imports. On the export side, scrap metals and chemicals are being considered for restrictions—covering €4.5 billion in EU exports. Comments are due by June 10.
  • May 1, 2025: CBP announced that by May 16, it will publish tariff refund procedures and HTSUS modifications to implement Executive Order 14289 (Addressing Certain Tariffs on Imported Articles).
  • Apr. 30, 2025: Commerce released an interim final rule establishing the process for requesting that additional derivative aluminum and steel articles be subject to the Section 232 tariffs. The interim final rule is effective April 30, and public comments are due by June 14. Under the interim final rule, the Bureau of Industry and Security (BIS) will allow inclusion requests to be submitted during three windows each year: May, September, and January. After BIS’s review, non-confidential versions of the requests will be published for a 14-day comment period. BIS will generate a decision memo on each request within 60 days of submission. A Federal Register notice will be issued shortly after the decision memo identifying new derivative products subject to the Section 232 tariffs.
  • Apr. 29, 2025: President Trump signed an executive order to prevent the cumulative effect of certain tariffs (also called “stacking”). Thus, (1) goods subject to the Section 232 tariffs on automobiles or automobile parts are not also subject to the tariffs on Canadian- or Mexican-origin goods or any applicable Section 232 tariffs on aluminum and steel articles or derivative products; and (2) goods subject to the tariffs on Canadian- or Mexican-origin goods are not also subject to any applicable Section 232 tariffs on aluminum and steel articles or derivative products. These changes apply retroactively to any entries on or after March 4. CBP will process refunds pursuant to its standard procedures.
  • Apr. 24, 2025: CBP released the HTSUS modifications that will implement the elimination of the de minimis exemption for Chinese origin products, effective May 2.
  • Apr. 23, 2025: Commerce released two Federal Register notices about newly initiated Section 232 investigations into (1) critical minerals and derivative products and (2) medium- and heavy-duty trucks and truck parts, as well as derivative products. Public comments are due within 21 days of the notices being published in the Federal Register, which is currently scheduled for April 25.
  • Apr. 18, 2025: USTR imposes fees and restrictions on certain maritime transport services
  • Apr. 14, 2025: Commerce released two Federal Register notices about newly initiated Section 232 investigations into imports of (1) pharmaceuticals, pharmaceutical ingredients, and derivative products and (2) semiconductors, semiconductor manufacturing equipment, and derivative products. The pharmaceuticals investigation will cover finished generic and non-generic drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients and key starting materials, and derivative products of those items. The semiconductors investigation will cover semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics, and SME components, as well as downstream products that contain semiconductors (e.g., electronics). Public comments are due within 21 days of the notices being published in the Federal Register, which is currently scheduled for April 16.
  • Apr. 11, 2025: President Trump issued a presidential memorandum to expand the reciprocal tariff exceptions to include the following HTSUS headings and subheadings:  8471, 8473.30, 8486, 8517.13.00, 8517.62.00, 8523.51.00, 8524, 8528.52.00, 8541.10.00, 8541.21.00, 8541.29.00, 8541.30.00, 8541.49.10, 8541.49.70, 8541.49.80, 8541.49.95, 8541.51.00, 8541.59.00, 8541.90.00, and 8542. CBP will issue refunds for any tariffs collected on imports classified under these headings or subheadings since April 5.
  • Apr. 9, 2025: President Trump signed an executive order increasing the tariffs that will be imposed on imports of Chinese-origin goods that would otherwise qualify for the de minimis exemption, effective May 2. Goods sent through the international postal network will be subject to duties of (a) 120% ad valorem or (b) $100 per item. The per item dollar amount will increase to $200, effective at 12:01 a.m. (ET) on June 1.
  • Apr. 8, 2025: President Trump signed an executive order increasing the tariffs that will be imposed on imports of Chinese-origin goods that would otherwise qualify for the de minimis exemption, effective May 2. Goods sent through the international postal network will be subject to duties of (a) 90% ad valorem or (b) $75 per item. The per item dollar amount will increase to $150, effective at 12:01 a.m. (ET) on June 1.
  • Apr. 8, 2025: CBP released guidance indicating that the reciprocal tariff savings clause for imports otherwise subject to country-specific tariff rates will also remain in effect until 12:00 a.m. (ET) on May 27.
  • Apr. 4, 2025: CBP released guidance indicating that the reciprocal tariff savings clause for imports on or after 12:01 a.m. (ET) on April 5 will remain in effect until 12:00 a.m. (ET) on May 27. The savings clause applies to goods loaded onto a vessel at the port of loading and in transit on the final mode of transport before entry into the United States before 12:01 a.m. (ET) on April 5.
  • Apr. 2, 2025: U.S. imposes 10% baseline tariffs; higher reciprocal tariffs for targeted countries (updated Apr. 3, 2025)
  • Mar. 28, 2025: What impact will President Trump’s reciprocal tariffs have on the United Kingdom?
  • Mar. 27, 2025: In response to the new U.S. tariffs on automobiles and automobile parts, the Chair of the International Trade Committee in the European Parliament suggested placing tariffs on U.S. digital services.
  • Mar. 25: 2025: Tariff mitigation through alternative sourcing: Navigating customs country of origin compliance risks
  • Mar. 24, 2025: President Trump signed an executive order granting the Secretary of State discretion to impose a 25% tariff on imports of goods from any country that directly or indirectly purchases Venezuelan oil, effective April 2, 2025. Unless terminated earlier, the tariffs will expire on year after the last date on which the country imported Venezuelan oil. “Venezuelan oil” means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.
  • Mar. 11, 2025: The Commerce Department initiated Section 232 investigations into imports of copper and timber and lumber. The deadline to submit comments is April 1, 2025.
  • Mar. 3, 2025: The following Federal Register notices implementing the following tariffs were made available for public inspection: (1)  adjusted Section 232 tariffs on steel imports; (2) adjusted Section 232 tariffs on aluminum imports; (3) tariffs on imports of Canadian-origin goods; and (4) tariffs on imports of Mexican-origin goods.
  • Feb. 25, 2025: The USTR is seeking public comments, on a country-by-country basis, about any unfair trade practice or non-reciprocal trade arrangement. The deadline to submit comments is March 11, 2025.
  • Feb. 17, 2025: The EU released a Q&A document on the United States’ reciprocal tariff policy. The document does not outline specific countermeasures the EU intends to implement but does indicate that the EU remains open to negotiations with the U.S. on balanced trade.
  • Feb. 11, 2025: Trump adjusts steel and aluminum tariff; directs Customs to increase enforcement
  • Feb. 4, 2025: U.S. and China in tariff tit for tat; Canadian and Mexican tariffs delayed
  • Feb. 3, 2025: U.S. imposes tariffs on Canada, China, and Mexico; retaliation promised
  • Jan. 28, 2025: Key investigations and enforcement trends: Top takeaways for 2025
  • Nov. 6, 2024: International trade in a second Trump presidency

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  1. Scope is based on products’ country of origin unless noted. ↩︎
  2. The BRICS members are Brazil, China, Egypt, Ethiopia, India, Indonesia, Iran, the United Arab Emirates, Russia, and South Africa. ↩︎
  3. “Column 1 Duty Rate” means the ad valorem (or ad valorem equivalent) rate of duty under “Column 1 – General” of the HTSUS. ↩︎

The European Union has politically agreed on the most ambitious overhaul of its customs framework since the customs union was established in 1968. Across the Channel, the United Kingdom is pursuing its own, though earlier-stage, customs modernisation agenda, the first since its withdrawal from the EU. Together, these reforms will reshape how goods move across Europe’s borders.

This briefing is the second in our Customs Reform Unpacked series. The new Union Customs Code (the Code) and implementing laws (together, the EU Customs Reform or the Reform) fundamentally change who is responsible for goods crossing the EU’s external border and what that person is responsible for. The traditional declarant-centred model is replaced with direct obligations on importers, exporters, and customs representatives, and a new Trust and Check Trader status is introduced alongside the existing Authorised Economic Operator scheme. At the institutional level, the Reform creates the EU Customs Authority, a new EU body tasked with coordinating risk management, enforcement, and controls across all 27 EU Member States.

Continue Reading New roles and responsibilities: redefining accountability at the EU border

The European Union has politically agreed on the most ambitious overhaul of its customs framework since the customs union was established in 1968. Across the Channel, the United Kingdom is pursuing its own, though earlier-stage, customs modernisation agenda, the first since its withdrawal from the EU. Together, these reforms will reshape how goods move across Europe’s borders.

This is the introductory briefing in our Customs Reform Unpacked series. In the Q&As below, we have gathered frequent questions about the EU and UK reforms and their objectives. Each answer provides a high-level overview; subsequent briefings in this series will take a deeper dive into the specific topics that matter most to your business.

Continue Reading Your questions answered on the EU and UK customs reforms

On August 7, 2026, the Committee on Foreign Investment in the United States (“CFIUS”) released its annual report to Congress for calendar year 2025. The report covers 347 covered transactions, consisting of 207 written notices and 140 declarations, that were filed for CFIUS review last year.

CFIUS is an interagency committee authorized to review certain transactions involving foreign investment in the United States and the effect of those transactions on U.S. national security. The Committee is required to provide an annual report to Congress containing specific, cumulative, and trend information related to transaction filing.

Continue Reading CFIUS annual report for 2025: Key takeaways

Overview

On August 26, 2026, President Trump signed Executive Order 14420 (EO), declaring a national emergency to secure the U.S. bulk-power system and restrict procurement and installation of a broad array of foreign-produced equipment used in the U.S. electric power industry that is linked to “Covered Foreign Entities,” a list of entities that notably includes China. Implementing regulations are expected within 120 – 180 days.

Continue Reading Executive Order 14420 Restricts Foreign Equipment in the U.S. Bulk-Power System

Overview

On 24 August 2026, the United States took coordinated action across its Syria and Iran sanctions programmes. Secretary of State Marco Rubio rescinded Syria’s State Sponsor of Terrorism (SST) designation after the 45-day Congressional notification period, and Hay’at Tahrir al-Sham (HTS) was delisted as a Specially Designated Global Terrorist (SDGT) organisation and removed from the Specially Designated Nationals and Blocked Persons (SDN) List. In Iran, the Treasury Department launched “Operation Economic Outcast”, made five sectoral determinations under E.O. 13902, designated nearly 60 entities, individuals and vessels across multiple jurisdictions, and suspended Iran General Licences F and G. It issued General Licences AA and BB, published an alert on Strait of Hormuz passage risks, and designated Singapore-based Wellbred Capital and affiliated entities linked to Mohammad Hossein Shamkhani.

Continue Reading U.S. sanctions update – Syria SST rescission, Operation Economic Outcast, and Iran sanctions developments

The Council adopted its 21st package of restrictive measures against Russia on 23 July 2026. The instruments entered into force on 24 July 2026 (the day following publication in the Official Journal). The principal instruments are Regulation (EU) 2026/1848; Regulation (EU) 2026/1844; and Implementing Regulation (EU) 2026/1843 (amending and implementing Regulation (EU) No 269/2014).

Continue Reading EU’s 21st Sanctions Package: Banks, Barrels, and a Bigger Blacklist

On July 7, 2026, OFAC revoked Iran General License X (GL X) and replaced it with General License X1 (GL X1). The waiver, which had been due to run until August 21, lasted barely two weeks. GL X1 is not a continuation; it is a narrow wind-down authorization that expires on July 17, 2026.

What changed

Three tankers were attacked in the Strait of Hormuz on July 7 and  Washington pulled GL X immediately, a warning of the consequences for Iran’s alleged actions in the strait. Oil prices jumped, and one struck vessel, an LNG carrier, was reportedly at risk of explosion.

GL X had temporarily authorized transactions relating to the production, sale, delivery, and offloading of Iranian-origin crude oil, petrochemicals, and petroleum products. See our previous post on GL X here. The critical point now is that GL X is no longer available, and OFAC can revoke any general license at any time. Parties should structure transactions accordingly.

Continue Reading OFAC Revokes Iran General License X: Only a Short Wind-Down Remains

Background

In our publication of 9 April 2026, we analysed the key implications of the proposed EU steel tariff-rate quota (TRQ) regime at a time when interinstitutional (trilogue) negotiations between the European Parliament, the Council, and the Commission were still ongoing.

On 24 June 2026, Regulation (EU) 2026/1384 of the European Parliament and of the Council, addressing the negative trade-related effects of global overcapacity on the Union steel market, was published in the Official Journal of the European Union. This Regulation replaces the existing EU steel safeguard measures, which are due to expire on 30 June 2026. The new regime enters into force on 25 June 2026 and applies from 1 July 2026.

However, a key issue remains unresolved. The quarterly administration and country-specific distribution of tariff quotas, including allocations to Free Trade Agreement (FTA) partners, have not yet been determined. It has been reported that the quarterly and country-level quota allocations will only be published on 30 June, just one day before they take effect. The uncertainty for importers is considerable: while steel prices are expected to rise, the precise impact will only become clear when the quotas – and how they are divided between different products and supplier countries – are published.

In this publication, we summarise the key features of the final EU steel measures, set out the staggered application dates, explain the tariff quota allocation framework (noting that the country-specific and quarterly allocation regime is yet to be confirmed), detail the melt-and-pour traceability requirements, and identify the key future deadlines and practical steps stakeholders should take now.

Key features of the published Regulation

The following is a summary of the substantive outcomes of the legislative process:

  • The out-of-quota duty has been raised from 25% to 50% ad valorem and the total annual tariff quota volume is set at 18,345,922 tonnes, roughly half of current levels, broken down per product category and administered on a quarterly basis. With this structural tightening, importers should expect significantly more shipments to fall outside quota limits, triggering the higher duty rate.
  • Melt-and-pour has been adopted as a transparency and traceability requirement only and does not serve as a basis for quota allocation at this stage. From 1 October 2026, importers must provide evidence (e.g., a mill test certificate) of the country where the steel was originally melted and poured. However, as early as 1 October 2027, the Commission will take melt-and-pour data into account for the country distribution of tariff quotas. By 30 June 2028, the Commission must assess whether melt-and-pour should become the full basis for quota allocation.
  • Carryover of unused quotas is allowed during the first yearly period (1 July 2026–30 June 2027). After the first year, the Commission will decide, by implementing act, whether carryover continues, taking into account import pressure, average quota utilisation (especially where above 80%), and supply availability.
  • The Commission must take into account the Union interest, including availability of supply and price increases affecting downstream industries, when adjusting quotas via delegated acts within defined floor and ceiling limits.
  • Product scope reviews are staggered: by 31 December 2026, the Commission must assess whether to extend the product scope to cover specific CN codes not currently listed; by 30 June 2027, it must assess whether the scope should also cover products made of, or containing, a significant amount of steel (including downstream iron and steel products). Both of these assessments are directed at potentially expanding the product scope. From 30 June 2029 and every two years thereafter, the Commission must conduct further assessments of the product scope, which may result in either an expansion or a reduction, taking into account the wider situation of Union competitiveness and of the Union steel industry (including upstream and downstream actors and SMEs), as well as the Union’s common security and defence policy.
  • Imports from Iceland, Liechtenstein, and Norway) are excluded from the tariff quota regime, while imports from Russia and Belarus are excluded from quota calculation as they remain subject to EU import bans.

Entry into force and staggered application dates

The Regulation enters into force on the day following its publication in the Official Journal, that is, 25 June 2026. Different provisions apply from different dates. The staggered application timeline is as follows:

25 June 2026 (entry into force)

  • The Commission’s power to adopt implementing acts determining the type of evidence importers must provide to prove the country of melt-and-pour applies immediately.
  • The elements the Commission must take into account when laying down the country distribution of tariff quotas are established.
  • The Commission is empowered to adopt implementing acts on country distribution and, where appropriate, to apply bilateral safeguard measures.

1 July 2026 (general application)

  • Tariff quotas are opened and the 50% out-of-quota duty applies.
  • First yearly period: 1 July 2026–30 June 2027.

1 October 2026

  • Importers must provide evidence of the country of melt-and-pour.

1 October 2027

  • The Commission takes melt-and-pour data into account for the country distribution of tariff quotas.

Tariff quota allocation: Global and yearly

The quotas set out in Annex II to the Regulation are yearly and global, broken down per product category. No quarterly breakdown or country-specific allocation appears in the Annex itself, and no specific FTA partner quotas are provided at this stage.

Until the Commission adopts implementing acts establishing the country distribution and quarterly breakdown, quotas will be administered as published, on a yearly and global basis. Given that quarterly administration is expressly provided for in Article 3(2), the Commission is expected to publish the implementing act before 1 July 2026.

We understand that the EU is offering FTA partners more time beyond 1 July to formalise bilateral arrangements (for which parliamentary approval is required). The Commission has reportedly devised a three-column system:

  • Column 1: grants all World Trade Organisation members 30% of historical import volumes.
  • Columns 2 and 3: individual and competitive pool quotas available to FTA partners if they waive their FTA rights or pledge not to challenge the EU’s measures.

However, it remains unclear how this system will operate during the interim period, pending formal agreement with FTA partners.

Melt-and-pour traceability requirements

A separate implementing act will follow, setting out the specific documentary evidence importers must provide to demonstrate the country of melt-and-pour. Key points:

  • A public consultation is currently running, with a deadline of 2 July 2026. Stakeholders can participate via the following link: EC consultation on melt-and-pour evidence.
  • The first implementing act on the type of evidence required must be adopted by 31 August 2026.
  • The obligation for importers to provide this evidence applies from 1 October 2026.

Key future dates

The Regulation establishes the following key milestones:

  • 1 July 2026: stakeholder consultation on product scope.
  • 31 August 2026: first implementing act on melt-and-pour evidence.
  • 31 December 2026: assessment of amendments to product scope (specific CN codes).
  • 30 June 2027: assessment of a broader product scope (downstream iron and steel products).
  • 30 June 2028: assessment of melt-and-pour as a basis for quota allocation; first implementation report.
  • From 30 June 2029, and every two years: further product scope assessments.
  • From 30 June 2029, and every three years: effectiveness evaluation.

What to do next

With the Regulation now published, stakeholders – particularly importers – should:

  • Verify product classification. Ensure correct CN code classification of your goods to determine whether they fall within scope, support any post-clearance claims, or establish that your product may be excluded from the regime.
  • Assess origin correctly. Determine the non-preferential origin of your steel products, taking into account whether any processing operations in intermediary countries qualify as a sufficient change of origin. This is critical for understanding which country-specific quota your imports will draw from.
  • Map melt-and-pour origins. Identify the country of melt-and-pour across your product portfolio and ensure suppliers can provide the required evidence (e.g., mill test certificates) from 1 October 2026.
  • Participate in the public consultation on melt-and-pour evidence. The deadline is 2 July 2026; this is an opportunity to shape the implementing act on what evidence importers must provide.
  • Build in-quota vs. out-of-quota cost models. With the duty gap now at 50%, the financial impact of falling outside quota is substantial.
  • Stay tuned for the quarterly allocation implementing regulation, which is expected to be adopted imminently and will determine how quotas are distributed by country and by quarter in practice.

Reed Smith’s international trade team continues to monitor developments closely. Please do not hesitate to reach out to our team for tailored advice on how these measures affect your operations.

On 21 June 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License X (“GL X”), authorising certain transactions relating to the production, sale, delivery and offloading of Iranian-origin crude oil, petrochemical products and petroleum products. This represents a remarkable — if temporary — departure from the comprehensive United States sanctions framework that has constrained Iranian energy trade for decades. Clients need to be aware that there are still significant Iranian sanctions restrictions in place by the European Union and the United Kingdom, that may still prevent parties from taking advantage of GL X. This alert summarises the key features of GL X and the practical considerations for clients.

Overview of the General Licence

Scope and authorised activities. GL X authorises all transactions ordinarily incident and necessary to the production, sale, delivery or offloading of Iranian-origin crude oil, petrochemical products and petroleum products, including transactions involving vessels blocked under the relevant authorities. Covered ancillary activities expressly include safe docking and anchoring; crew health and safety; emergency repairs; environmental mitigation; vessel management, crewing, bunkering, piloting, registration, flagging, insurance, classification and salvage.

Importation into the United States. Notably, GL X extends to the importation into the United States of Iranian-origin petroleum products where such importation is ordinarily incident and necessary to the authorised sale, delivery or offloading.

Payments. Payments owed to Iran, the Government of Iran or any blocked person for the purchase of authorised products may be made in U.S. dollar-denominated funds.

Key exclusions and limitations. GL X does not authorise transactions involving persons located in, or organised under the laws of, North Korea, Cuba, the Covered Regions of Ukraine (as defined by Executive Order (“EO”) 14065), or the Crimea Region of Ukraine (as defined by EO 13685). It does not authorise any transactions prohibited by Executive Orders or regulations not expressly referenced in the licence. Clients should note that this is not a wholesale lifting of Iran sanctions; it is a targeted, time-limited authorisation confined to the petroleum sector.

Who may rely on it. GL X is issued under multiple sanctions programmes (including 31 CFR parts 560, 544, 561, 562, 587, 589 and 594, and Executive Orders 13846, 13876, 13902 and 13949). Any U.S. person, and any non-U.S. person complying with the terms and conditions of GL X, may rely on the licence to the extent the transaction falls within its terms.

Non-US clients should independently assess:

  • the feasibility of banking, insurance and logistics arrangements; and any applicable EU, UK or other local sanctions regimes which may not provide equivalent relief;
  • contractual restrictions (including sanctions-related representations and warranties).

Duration and expiry

GL X expires at 12:01 a.m. Eastern Daylight Time on 21 August 2026. There is no automatic renewal, and the license can be withdrawn at any time before then. Clients engaged in transactions authorised by the licence must plan for wind-down well in advance of this deadline. Any transaction not completed by that time will no longer benefit from the authorisation and could give rise to sanctions liability.

We recommend that clients monitor OFAC guidance closely for any extension, amendment or revocation and ensure that contractual arrangements incorporate appropriate conditionality linked to the licence’s validity.

Conclusion — a remarkable turnaround

The issuance of GL X is extraordinary by any measure. For the first time in over a decade, OFAC has authorised — albeit temporarily — the broad production, sale and delivery of Iranian-origin petroleum products, including their importation into the United States and payment in U.S. dollars. This marks a significant, if carefully circumscribed, easing of the maximum-pressure posture that has defined U.S. Iran sanctions policy in recent years.

Clients should approach this development with both commercial interest and caution. The licence is temporary, narrowly drawn and subject to exclusions. The broader sanctions architecture remains in place. Parties contemplating reliance on GL X should conduct thorough due diligence, take specialist legal advice and ensure robust compliance frameworks are in place to manage the residual risks that attend any dealings with Iranian-origin products, particularly if they have an EU or UK nexus.

The Reed Smith sanctions team is available to assist clients in assessing the implications of GL X for their operations and to advise on structuring compliant transactions within its scope.