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.
The U.S. Trade Representative (USTR) has announced an additional 10% tariff on 6,031 tariff subheadings covering approximately $200 billion worth of imports. The proposal constitutes a new round of tariffs separate from the prior 25% tariff actions taken by the USTR. The complete Federal Register notice and tariff list can be found here.
On July 6, the U.S. Trade Representative (USTR) announced details of the process by which importers can request product exclusions from the 25% duties assessed against China. The USTR's press release stipulates that exclusion requests must be made on a product basis and be submitted prior to October 9, 2018. If granted, the exclusion requests will be retroactive to July 6th and remain in effect for one year. At this time, there is no indication of how long the USTR will take to process the requests.
The Office of the U.S. Trade Representative (USTR) has published the final list of Chinese products subject to additional 25% tariffs pursuant to its Section 301 investigation into unfair trade practices. The tariffs apply to a list of 818 tariff designations covering $34 billion in goods. The tariffs will be collected starting July 6, 2018.
Today, President Trump signed a presidential memorandum directing a range of actions against China in response to practices involving the unfair and harmful acquisition of U.S technology. This action paves the way for the government to impose tariffs of approximately $50 to $60 billion on imports from China. While the details of products potentially covered by the tariffs are set to be published this coming week, any companies doing business with China should take steps now to evaluate their position and options for moving forward.
President Trump is preparing to impose a package of $60 billion in additional tariffs against China as early as this week. These tariffs come on the heels of the recent announcement of duties imposed on steel and aluminum. The new tariffs are expected to cover more than 100 commodities, potentially including apparel, footwear, furniture, and toys. The Washington Post is reporting that the duties may be assessed as early as this Friday.
The President’s announcement yesterday to impose a 25% tariff on steel, and 10% tariff on aluminum imports, has left his advisers divided on implementation. Overseas trading partners are also contemplating retaliation on U.S. exports. The tariffs will impact production costs for U.S. producers, and potentially result in offshore production for items that include steel and aluminum.
CBP has postponed the January 14, 2017 migration of all reconciliation entry transmissions to the Automated Commercial Environment (ACE). CBP made the announcement after receiving considerable feedback concerning the complexity of this transition, as well as the impact to other programs slated for ACE deployment. The agency is expected to provide a new effective date for the reconciliation transition to ACE in the near future.
On October 14, the U.S. International Trade Commission (ITC) will start accepting petitions from companies seeking duty reductions or suspensions under the Miscellaneous Tariff Bill (MTB). The MTB provides temporary relief from ordinary import duties on goods that are not produced domestically to improve the competitiveness of U.S. companies. U.S. importers interested in having one or more of its products potentially included in the MTB will have a limited window of time to file a petition.
On August 22, 2016, U.S. Customs and Border Protection (CBP) published long-awaited interim regulations implementing the procedures for conducting investigations of alleged antidumping (AD) or countervailing duty (CVD) evasion. These new investigatory procedures were enacted to address ongoing concerns by U.S. producers that AD/CVD duties have been illegally avoided.
The complicated relationship between the U.S. and Iran continued to evolve after a flurry of events over this past weekend. The U.S. lifted sanctions on targeted sectors of the Iranian market as part of implementing a key part of a multi-lateral agreement concerning Iran’s nuclear enrichment program, while new sanctions were imposed on persons and entities involved in ballistic missile testing from last December. The sanctions relief opens up a new potential market for billions of dollars in trade, but also presents a reminder to those looking to do business in Iran that vigilance over the complex web of sanctions and export controls is essential.
The U.S. and 11 partner nations have reached an agreement on the Trans-Pacific Partnership (TPP). The agreement will lower trade barriers and set commercial rules for the participants, which make up 40% of the global economy.
The U.S. Trade Representative and international counterparts concluded negotiations on Monday over several contentious issues, including the opening of U.S. agricultural markets in Japan and Canada, and the tightening of intellectual property rules for pharmaceuticals and technology.
