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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Country-specific tariffs  |  Product-specific tariffs  |  Section 122 tariff exemptions  | Tariff stacking |   Updates and relevant publications

Country-specific tariffs

🔔 Updated: February 22, 2026 at 2:05 PM ET

Litigation update (Feb. 20, 2026): The Supreme Court ruled that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs. As a result, all tariffs issued under IEEPA are invalid. The Court’s ruling does not address the question of importer refunds.

CountryType & StatusAd Valorem Rate 1Exemptions & NotesAnnounced Countermeasures
All Section 122:
Implemented
(effective Feb. 24, 2026)		10%See exemptions below

🔔 Rate increase to 15%:
Threatened
(Feb. 21, 2026)

Ends at 12:01 a.m. (ET) on July 24, 2026
Details   ▸
    De minimis exemption suspended (effective Aug. 29, 2025; continued Feb. 20, 2026):
    With the exception of shipments sent through the international postal network, which are subject special duty rates, shipments that would have otherwise qualified for the de minimis exemption are subject to all applicable duties and tariffs.

    References:
    Proc. 11012
    (Feb. 20, 2026)
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.
Austria Additional (DSTs):
Threatened
(Feb. 21, 2025) 		TBD
Details   ▸
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)
 Additional (dairy and lumber):
Threatened
(Mar. 7, 2025) 		250%
Additional (aircraft):
Threatened
(Jan. 29, 2026)		50%
China
Trade Deal
Sec. 301 Invest.
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%
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   ▸
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))

Back to top

Worldwide, product-specific tariffs

🔔 Updated: January 27, 2026 at 10:50 AM ET

ProductStatus Ad Valorem Rate ScopeExemptions & Notes
Agricultural products Threatened
(Mar. 3, 2025) 		TBDTBD
Aluminum articles and derivative products Implemented
(effective Mar. 12, 2025; increased June 4, 2025; amended June 16, 2025) 		UK-origin products: 25%

Russian-origin products: 200%

All other countries: 50% 		See Note 19, Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification

Expanded
Includes additional derivative products (effective Aug. 18, 2025) 		See stacking explanation below

Calculation:
(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)

Exemptions:
(a) UK aerospace exemption
(effective June 23, 2025)
(b) EU aerospace exemption
(effective Sept. 1, 2025)
(c) Japan aerospace exemption
(effective Sept. 16, 2025)

Details   ▸

    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:


    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)

Automobiles Implemented
(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

🔔 South Korea rate:
Threatened increase to 25%
(Jan. 27, 2025)

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 parts Implemented
(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, 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(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)


    Proclamation
    (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   ▸
Copper Implemented
(effective Aug. 1, 2025) 		50% See Note 36, Subchapter III, Chapter 99, HTSUS

Applies to semi-finished copper products and intensive copper derivative products by HTSUS classification 		See stacking explanation below

Calculation:
(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)

Exemptions:
(a) EU aerospace exemption
(effective Sept. 1, 2025)
(b) Japan aerospace exemption
(effective Sept. 16, 2025)

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)

iPhones Threatened
(May 23, 2025) 		25%TBD
Lumber, timber, and derivative products Softwood 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-, and South Korea-origin products:
(EU and Japan rate effective Oct. 14, 2025; South Korea rate effective Nov. 14, 2025; modified Dec. 31, 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%

All other countries:
  • 25% (Oct. 14–Dec. 31, 2025)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-, and South Korea-origin products:
(EU and Japan rate effective Oct. 14, 2025; South Korea rate effective Nov. 14, 2025; modified Dec. 31, 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%

All other countries:
  • 25% (Oct. 14–Dec. 31, 2025)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 equipment Intermodal 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   ▸
Movies Threatened
(May 4, 2025) 		100%All foreign-produced moviesPresident Trump authorized Commerce and the USTR to initiate an investigation to implement these tariffs.
Oil and gas Threatened 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) 		TBD TBD
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. 		Threatened to start Oct. 1
(Feb. 18, 2025; threatened rate announced July 8, 2025) 		100% Announced on Truth Social (Sept. 25, 2025): all branded or patented pharmaceutical products Exemption announced on Truth Social (Sept. 25, 2025): products produced by companies building a manufacturing facility in the United States, including facilities where a company has broken ground

Details   ▸

    On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of pharmaceuticals, pharmaceutical ingredients, and derivative products.


    References:



    90 Fed. Reg. 15951
    (Apr. 16, 2025)



Polysilicon and its derivatives
Sec. 232 Invest. 		Threatened
(July 14, 2025) 		TBDTBD
Details   ▸
    On July 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of polysilicon and its derivatives.

    References:
    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)		TBDTBD🔔 The 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:



    Proclamation (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) 		TBD TBD
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:
Proclamation (Jan. 14, 2026)
90 Fed. Reg. 15950 (Apr. 16, 2025)
Steel articles and derivative products Implemented
(effective Mar. 12, 2025; increased June 4, 2025; amended June 16, 2025) 		UK-origin products: 25%

All other countries: 50% 		See Note 16, Subchapter III, Chapter 99, HTSUS

Applies by HTSUS classification

Expanded
Includes additional derivative products (effective Aug. 18, 2025) 		See stacking explanation below

Calculation:
(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)

Exemptions:
(a) UK aerospace exemption
(effective June 23, 2025)
(b) EU aerospace exemption
(effective Sept. 1, 2025)
(c) Japan aerospace exemption
(effective Sept. 16, 2025)

Details   ▸

    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.

    Individual exclusions and General Authorized Exclusions are also being revoked.

    References:


    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 parts Medium- 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

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:



    Proclamation
    (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:


    Proclamation
    (Oct. 17, 2025)


    90 Fed. Reg. 17371
    (Apr. 25, 2025)

Unmanned aircraft systems and their parts and components
Sec. 232 Invest. 		Threatened
(July 14, 2025) 		TBDTBD
Details   ▸
    On July 14, Commerce initiated a Section 232 investigation to determine the effects on the national security of imports of unmanned aircraft systems (UAS) and their parts and components.

    References:
    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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Section 122 tariff exemptions

The following foreign-origin items are exempt from the Section 122 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 February 24, 2026 and entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. (ET) on February 28.
  • 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), MHDV parts, lumber, semi-finished copper and intensive copper derivative products, and semiconductors (or the portion of the goods’ value subject to 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.
  • Article of textiles or apparel that qualify for duty-free treatment under CAFTA-DR.
  • The additional articles listed in Annex II to the February 20, 2026 Proclamation, 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.
  • 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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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 122 tariffs.
  • The aluminum and steel tariffs can stack on top of each other if the product is subject to both.
  • The aluminum, steel, copper, lumber, and semiconductor tariffs do not stack on top of any applicable Section 122 tariffs.

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Updates and relevant publications

  • 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. ↩︎