On April 2, 2025, President Trump signed an executive order announcing the imposition of a blanket 10% tariff on imported products from all countries. Additionally, Annex I to the executive order sets forth separate increased country-specific reciprocal tariff rates for countries that are considered “worst offenders” and are the largest contributors to the U.S. trade deficit. Countries that are subject to a reciprocal tariff shall not also be subject to the blanket 10% tariff. The U.S. will impose reciprocal tariffs on products originating from those countries at roughly half the rate those countries impose on U.S. products. USMCA-compliant goods from Canada and Mexico are exempt from both the blanket 10% tariffs and the country-specific reciprocal tariffs.

As we reported last week, on March 19, 2025, U.S. Customs and Border Protection (CBP) issued guidance regarding the additional 10% tariff on Canadian energy and energy resources applicable as of March 4, 2025, except for USMCA-eligible products as of March 7, 2025. The March 19 guidance included a spreadsheet listing products/HTS codes falling under the scope of energy and energy resources.

As we previously reported, President Trump introduced an additional 25% tariff on products of Canada and Mexico effective March 4, 2025 (with an exception of USMCA-eligible products exempted as of March 7, 2025). For Canadian energy and energy resources, the additional tariff rate is 10% (likewise with the exception of USMCA-eligible products).

On March 11, 2025, CBP released after-hours updated guidance announcing start dates of steel and aluminum derivative products outside of Chapters 73 and 76. CBP announced that the 25% Section 232 tariffs on new steel and aluminum derivative products that fall outside of Chapters 73 and 76 take effect at 12:01 a.m. Eastern Daylight Time on March 12, 2025. CBP confirmed that the 25% tariff on such derivative products is based upon the value of steel or aluminum content.

On March 11, 2025, President Trump announced a series of new tariff actions targeting various products of Canada.

U.S. Customs and Border Protection has issued additional guidance concerning the new tariffs against products of Canada and Mexico effective March 4, 2025. However, de minimis entry processing will remain in effect for those countries until further notice.

On February 25, 2025, the United States Trade Representative (USTR) issued a request for comments to assist in reviewing and identifying non-reciprocal trade practices. This request asks the public to identify other countries’ policies and practices that may affect American global competitiveness. Specifically, the USTR seeks information about countries covering 88% of the goods trade with the United States. Public comments to the USTR are due March 11, 2025, however, the USTR welcomes comments after that period.

On February 25, 2025, President Trump signed an executive order calling for an investigation into the national security impact of copper imports under Section 232 of the Trade Expansion Act (fact sheet). The investigation includes copper “in all forms.” Specifically, it will include copper and copper products such as raw mined copper, refined copper, alloys, copper concentrates, scrap, and derivative products made with copper. This development comes from the Trump administration’s national and economic security concerns, including China’s role as a major producer of copper, despite few imports to the United States. The commerce secretary, Howard Lutnick, has 270 days from the date of the order to submit his findings to Trump.

On February 13, 2025, President Donald Trump announced a plan to instate reciprocal tariffs (fact sheet). The “Fair and Reciprocal Plan” is intended to encourage companies to bring manufacturing back to the United States, potentially for increased exportation abroad. Its goal is to reduce trade deficits and increase American competitiveness globally. The announcement also criticizes the digital services taxes levied against U.S. companies doing business in Canada and Europe. At this stage, U.S. trading partners are mostly attempting to negotiate with the Administration to avoid negative effects. On February 24, 2025, Trump doubled down on tariffs against products from Canada and Mexico, stating that they will be implemented “on time”; this appears to signal a general willingness to follow through on tariff threats made to allies.

On February 14, 2025, President Trump revealed two pre-published executive orders containing additional details being made to his February 10, 2025, proclamations that reinstated a 25% tariff on steel imports and an increase of aluminum tariffs from 10% to 25%. These orders now include annexes that describe the Harmonized Tariff Schedule of the United States (HTSUS) codes of additional derivative steel and aluminum articles that will be subject to Section 232 duties.

On February 10, 2025, President Trump announced the reinstatement of a 25% tariff on steel imports and an increase of aluminum tariffs (fact sheet) from 10% to 25% including products of Canada, Mexico, and China. This action aims to protect U.S. steel and aluminum industries from unfair trade practices and global overcapacity. The new tariffs are imposed by virtue of the elimination of quota arrangements, exemptions, and product exclusions that are removed on March 12, 2025. This affects imports of steel and steel derivatives from Argentina, Australia, Brazil, Canada, Japan, Mexico, South Korea, the U.K., Ukraine and the EU. These measures are in follow-up to prior tariffs imposed pursuant to Section 232 of the Trade Expansion Act of 1962.

Additional details concerning the new tariffs assessed by the new Administration are now forthcoming. The White House just announced an implementation of "a 25% additional tariff on imports from Canada and Mexico and a 10% additional tariff on imports from China. Energy resources from Canada will have a lower 10% tariff." This information can be found here. The Executive Orders pertaining to the tariffs for Canada and Mexico can be found here (Canada EO, Mexico EO). The White House explained that tariffs are being implemented because of "[t]he extraordinary threat posed by illegal aliens and drugs, including deadly fentanyl, [which] constitutes a national emergency under the International Emergency Economic Powers Act (IEEPA)." The effective date for all the tariffs will be February 4th, 2025 (excluding items already in transit).

On December 18, 2024, the American Active Anode Material Producers (“AAAMP”), a trade association of domestic manufacturers, filed a petition to impose antidumping and countervailing duties (“AD/CVD”) on U.S. imports of active anode material from China, stating that the imports are dumped and unfairly subsidized. Depending on the outcome of this petition, there may be significant consequences for a variety of battery manufacturers and consumers.

On December 23, 2024, The U.S. Trade Representative (“USTR”) announced it has initiated a Section 301 investigation into China’s acts, policies, and practices related to targeting of the semiconductor industry. Depending on the results of this investigation, which will be reported in early 2025, President Trump will have the option to assess additional tariffs on commodities within the industries mentioned below, and potentially others as well. This investigation will provide the statutory framework for separate tariffs to be assessed after the notice and comment periods of the investigation conclude.

The Office of the United States Trade Representative (“USTR”) announced tariff increases under Section 301 for imports from the People’s Republic of China of certain tungsten products, wafers, and polysilicon. The USTR also confirmed that these modifications conclude Section 301 4-year statutory review.

On November 25, 2024, President-elect Trump announced his intention to impose an additional 25% tariff on goods imported into the U.S. from Mexico and Canada and an additional 10% tariff on goods imported into the U.S. from China. These additional tariffs could go into effect as early as January 20, 2025.

On November 14, 2024, Chairman John Moolenaar (R-MI) of the House Select Committee on the Chinese Communist Party announced the introduction of the Restoring Trade Fairness Act (“RTFA” or “Act”), a bill that would revoke China’s Permanent Normal Trade Relations (“PNTR”) status with the U.S., a designation that has facilitated favorable trade terms since 2000, increase the rates of duty applicable to goods from China, and end de minimis imports from China.

The Office of the United States Trade Representative (USTR) has announced that it opened an electronic portal on October 15, 2024, establishing a process by which interested persons may submit requests for temporary exclusion from Section 301 China tariffs for particular machinery used in domestic manufacturing classified within Chapters 84 and 85 of the Harmonized Tariff Schedule of the United States (HTSUS). The subheadings eligible for consideration of temporary exclusion under the machinery exclusion process are set forth in Annex E of another USTR notice published on September 18, 2024. Exclusion requests will be accepted through March 31, 2025.

The Biden Administration announced today that it is pursuing significant regulatory actions, including a proposal to exclude goods subject to major trade actions, such as Section 301 tariffs, from de minimis entry and require additional information for each de minimis entry that remains eligible. Since the de minimis entry exemption is used to import most e-commerce shipments, this proposed action would prohibit any Chinese merchandise subject to Section 301 tariffs from utilizing the de minimis exemption.

The Office of the United States Trade Representative (USTR) today announced final modifications concerning the statutory review of the tariff actions in the Section 301 investigation of the People’s Republic of China’s (China) Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation. In this announcement, the USTR is following up on prior tariff modifications as reported earlier this year following a statutorily mandated review of the Section 301 tariffs on imports from China.