Trump Tariffs 2.0: The Tariff Tracker

UPDATES

3/12/25

Yesterday, Commerce issued a pre-inspection notice for certifying the value system for collecting tariffs on the additional derivatives outside of HTS. 73 and 76, which was followed by CBP CSMS messages informing that tariffs on these additional derivatives starts on March 12, 2025, at 12:01 AM EDT. The updated guidance mirrors the CBP guidance from last Friday, which informs that if the value of the steel/aluminum content for these additional derivatives is not known, then the full value of the content should be reported. It similarly provides details on the Ch. 99 reporting requirements for the entry filing to break out the steel or aluminum content. For questions on how to determine the value of the steel and aluminum content in situations where it does not represent the full value of the product, please contact us for additional details. Please find links to the updated CBP guidance below:

• CSMS # 64384423 - UPDATED GUIDANCE: Import Duties on Imports of Steel and Steel Derivative Products
• CSMS # 64384496 - UPDATED GUIDANCE: Import Duties on Imports of Aluminum and Aluminum Derivative Products

03/07/25

Canada and Mexico IEEPA tariffs and de Minimis treatment: On Thursday, March 6, President Trump exempted Canadian and Mexican products that qualify for the USMCA and claim the USMCA at entry from the IEEPA tariffs. In order to receive this exemption, the imported goods must qualify under the USMCA Rules of Origin criteria under HTSUS General Note 11, and have a valid USMCA certification at the time the claim is made. The IEEPA tariffs will still apply to all other Mexican and Canadian goods that do not qualify for the USMCA, which is set at 25% for all goods, except that it is set at 10% for Canada-origin energy resources and Canada- or Mexico-origin potash. These exemptions are in effect on March 7 at 12:01 eastern standard time. The current guidance does not address whether post-importation USMCA claims will be covered, and while there are news reports of an April 2 termination of the USMCA exemption, the Executive Orders do not have a termination date for the USMCA exemption. 

The Federal Register Notices that were issued today also align with the Executive Orders from yesterday:

• CBP Amendment to Notice of Implementation of Additional Duties on Products of Canada Pursuant to the President’s Executive Order 14193 
• CBP Amendment to Notice of Implementation of Additional Duties on Products of Mexico Pursuant to the President’s Executive Order 14194

03/05/25:

Canada and Mexico IEEPA tariffs One Month Exemption on Autos Eligible for USMCA: On March 5, 2025, President Trump issued a one-month exemption from the 25% IEEPA tariffs on autos imported under the US Mexico Canada Agreement (USMCA).

03/04/25:

Canada and Mexico IEEPA tariffs:  On March 4, 2024, the 25% IEEPA tariffs that had been delayed for one month were imposed on Mexico and Canada (other than certain energy products at 10%) origin products (as determined by substantial transformation rules or 19 CFR Part 102). Drawback is not allowed, there is no temporary exemption for goods in transit, and Canada and Mexico products entering an FTZ must be admitted in privileged foreign status. For the time being, the de minimis program remains available until the Department of Commerce develops a system to collect the tariffs.  Certain Ch. 98 provisions also remain applicable, though on a case-by-case basis depending on the Ch. 98 provision at issue. Specific Ch. 99 provisions must be used at entry for any goods subject to the IEEPA tariffs as well as for the very limited applicable exclusions to the tariffs.

We have heard some reports that these broad tariffs may be tempered in some way in the coming days, but that remains to be seen.

• White House Canada and Mexico Fact Sheet

Canada

• Canada Executive Order
• Canada pre-publication Federal Register Notice
• CSMS # 64297449 - GUIDANCE: Additional Duties on Imports from Canada

In response to the IEEPA tariffs, Canada announced 25% retaliatory tariffs on $155B of US goods. These had originally been announced a month ago when the Canada IEEPA tariffs were originally scheduled. The Canada retaliatory tariffs will apply immediately to $30B of products effective today. In three weeks, Canada will impose additional tariffs on $125B of US goods, subject to public consultation to determine the final list of covered products. The contemplated products are listed here. The tariffs will be imposed until the US withdraws its tariffs on Canadian goods. The list of products that may be covered by the tariffs includes a broad array of goods including textiles, autos, agricultural products, liquors and beverages, consumer goods, lumber, etc. In addition, specific provinces have also planned retaliatory measures, including prohibiting the sale of certain US products. President Trump has indicated that he may increase the tariffs based on these actions.

Mexico

• Mexico Executive Order
• Mexico pre-publication Federal Register Notice
• CSMS # 64297292 - GUIDANCE: Additional Duties on Imports from Mexico

Mexico has not announced specific reciprocal tariffs yet, however reports indicate that they may be coming later this week.

China IEEPA Tariffs Increased to 20%:

On March 4, 2024, the China IEEPA tariffs increased from 10% to 20%. The same import restrictions will apply. Specific Ch. 99 provisions for the China IEEPA tariffs and any applicable limited exclusions must be declared at the time of importation. Goods in transit on February 1, 2025 must arrive by March 7, 2025 to be exempt from the IEEPA duties.

• China Executive Order
• CSMS # 64299816 - UPDATE – Additional Duties on Imports from China and Hong Kong
• China pre-publication Federal Register Notice

China retaliated with 10-15% duties on various US agricultural and food products. In addition, China took other measures such as adding several US companies to the unreliable entity list.

03/03/25:

Sec. 232 tariffs on Steel and Aluminum Derivatives in Ch. 73 and 76 effective March 12, 2025- The steel and aluminum Federal Register Notices will be published on March 5.

• Original steel and aluminum products and derivatives: Section 232 tariffs of 25% will be effective March 12.
• New derivatives classified in Chapter 73 or Chapter 76: Section 232 tariffs of 25% will be effective March 12.
• New derivatives classified outside Chapter 73 or Chapter 76: Effective date is still TBD pending “public notification of the Secretary of Commerce”.

The 232 tariffs on derivative products will apply solely to the value of the aluminum or steel content of the derivatives; we expect further guidance from CBP regarding determination of this value. Very limited exceptions apply for the new list of derivative products that undergo early-stage processing in the United States.

Russian origin aluminum products or products composed of any primary aluminum smelted or cast in Russia will be subject to 200% duties.

USTR Issues Trump’s Trade Agenda: The USTR’s release of the President’s Trade Policy Agenda aligns largely with the White House’s America First Trade Policy. Of note, the Agenda states that the administration will specifically review China trade practices. See the report at: USTR 2025 Trade Policy Agenda and 2024 Annual Report.

03/01/25:

Lumber Sec. 232 Investigation - President Trump instructed the Department of Commerce to initiate a Section 232 investigation on timber, lumber, and their derivative products, focusing on the effects of imports on national security. This includes products such as paper products, furniture, and cabinetry. The investigation will assess US demand and capacity, the feasibility of increasing domestic production, and identify the countries primarily supplying these products to the US. It will also examine the impact of foreign government subsidies and trade practices on the competitiveness of the US wood products industry, among other trade-related factors. The investigation aims to determine whether current trade policies adequately protect national security or if additional measures, such as tariffs or quotas, are necessary. Recommendations for actions the administration should consider are due within 270 days (December 5, 2025). This action could result in Section 232 duties on timber, lumber, and their derivative products.

2/28/25:

Yesterday, President Trump reaffirmed that the IEEPA tariffs on Canada and Mexico will proceed on March 4, 2025, unless the flow of fentanyl is significantly curtailed. Concurrently, the President announced that tariffs on Chinese imports will increase from 10% to 20%. These announcements follow confusion earlier in the week regarding the implementation date, initially mentioned as April 2.  

As we previously observed between January 31 and February 4, a lot can still change within the next few days.

2/27/25:

Proposed Actions on Section 301 Shipbuilding

Following the USTR’s Section 301 investigation into China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance that found China’s practices are unreasonable and burden US commerce, the USTR has proposed actions including the imposition of fees on Chinese maritime transport operators and those using Chinese-built vessels, with fees reaching up to $1,500,000 per vessel entrance to US ports. The USTR is seeking public input on the proposed actions’ effectiveness and appropriateness, including a hearing scheduled for March 24, and the submission of written comments by March 24.

2/25/25:

Copper Sec. 232 Investigation

President Trump instructed the Department of Commerce to initiate a Section 232 investigation on Copper Products covering the effects of imports on national security of various copper products, including raw mined copper, copper concentrates, refined copper, copper alloys, scrap copper, derivative products, and copper in all other forms. It is unclear what the possible tariff rates contemplated may be. The investigation will include a review of US demand and capacity and the feasibility of increasing domestic production and will study which countries primarily supply copper products to the United States, impact of foreign government trade practices on US industry competitiveness, amongst other trade information. Based on the study, recommendations regarding actions for the administration to consider are due within 270 days (November 22, 2025).This action could result in Section 232 duties on copper products.

2/24/25:

Canada and Mexico IEEPA Tariffs

During a joint press release with French President Emmanuel Macron, President Trump appeared to indicate that the tariffs will proceed, as scheduled on March 4.

2/21/25:

Reciprocal Tariffs

In connection with the Trump Administration’s Presidential Memorandum on Reciprocal Trade and Tariffs, the USTR issued a public request for comments to assist the agency’s review of other countries unfair trade practices and in investigating harm from non-reciprocal trade arrangements. Commenters must identify the foreign country and unfair trade practice or arrangement and its harm on US interests, and include the quantified harm or cost to American entities. In particular, the United States appears to be interested in the G20 countries as well as countries with large trade deficits with the United States. Comments are due by March 11.

Digital Services Taxes (DST)

President Trump issued the Defending American Companies and Innovators From Overseas Extortion and Unfair Fines and Penalties memorandum that discusses actions other countries take that affect US companies. The memo instructs the USTR to revive the Section 301 DST investigation that he initiated in his first term, and specifically referencing France, Austria, Italy, Spain, and other EU countries, Turkey, UK, and Canada.

The previous investigations covered various countries including Brazil, Czech Republic, France, Austria, Italy, Spain, India, Indonesia, Turkey, and the UK, and temporarily imposed duties on certain products and countries like French champagne. The administration also issued a fact sheet titled “President Donald J. Trump Issues Directive to Prevent the Unfair Exploitation of American Innovation focuses on the practices of the European Union and United Kingdom.” The fact sheet states that foreign government impose DST and collect billions from US companies each year, while also engaging in other unfair practices.

2/19/25:

President Trump announced plans to impose 25% tariffs on auto imports, semiconductors, and pharmaceuticals starting April 2. The timeline aligns with the various agency reports that are due by April 1 under the America First Trade Policy Memorandum. Open questions remain about the scope of the tariffs, particularly whether they will apply to all countries or exempt those under existing trade agreements like USMCA, or whether they relate to ongoing investigations for actions such as the Reciprocal Tariffs.

2/18/25:

On April 2, President Trump reportedly will announce tariffs of approximately 25% on imported vehicles, pharmaceuticals, and semiconductors. The tariffs may escalate if companies do not shift production to the United States.

2/17/25:

Last week was… eventful. Various announcements were made regarding increases in the Section 232 Tariffs on Aluminum and Steel, as well as Reciprocal Tariffs.

Steel and Aluminum

On February 14, the Section 232 Federal Register Notices (FRN(s)) on Steel and Aluminum were issued for publication on February 18. These FRNs mirrored the EOs that were published earlier last week and apply 25% tariffs to steel and products (that were already subject to the historical 232 actions) from all countries, effective March 12. As reported in our monthly newsletter, the Proclamations terminate all existing special tariff arrangements, quotas, and exemptions with countries like Australia, Argentina, Brazil, Canada, the European Union, Japan, Mexico, South Korea, Ukraine, and the United Kingdom and terminates the product exclusion program.  All pending exclusions are deemed denied. Generally Approved Exclusions will expire on March 12, while previously granted product specific exclusions will remain valid until their expiration or until the specified volume is imported. Only a very limited exception applies to certain products that undergo early-stage processing in the United States.

The FRNs also issued Annexes that include a list of the additional steel derivatives (see Annex I) and additional aluminum derivatives (see Annex I) that will be subject to the Section 232 tariffs. These additional derivatives cover various HTSUS subheadings within Ch. 66, 73, 76, 83, 84, 85, 87, 88, 90, 94, 95, 96, and will be effective after the US Department of Commerce develops a system to collect tariffs on these imports. This could be weeks, or it could be months (very unlikely - March 12). For certain products, the 232 tariffs will only apply to the steel or aluminum content, which will involve additional value reviews and recordkeeping.  

Please contact us for additional information in relation to these effective dates, products covered by the 232 duties, value to declare, or for other questions on the available exemption, FTZ, USMCA, customs valuation, drawback, and Ch. 98 programs.

Reciprocal Tariffs

On February 13, the Trump Administration announced the initiation of a review process intended to apply reciprocal tariffs on countries at the same levels that they assess duties on US products. In theory, this could result in customized duty rates for each country.

The White House published a Reciprocal Tariffs and Trade Memorandum, along with a  Fact Sheet and additional information.  To date, the government has not identified the legal authority, tariff rate or calculation, application methodology (e.g., product specific or country specific, in addition to MFN tariffs an increase in MFN tariffs), or effective date for these reciprocal tariffs.  Rather, President Trump has directed various agencies to investigate the tariffs assessed by each country and issue their findings and recommendations in a report due to the president on April 1 per the America First Trade Policy Memorandum. The Office of Management and Budget (OMB) must also assess the fiscal impact of the actions and provide a written assessment to the president by August 12.   

While there is no immediate or specific effect from the following references at this time, the Reciprocal Tariffs memorandum and related documentation released by the White House, noted that part of the government’s assessment would consider value-added taxes imposed by foreign countries, as well as non-tariff barriers. Examples of cited unfair trade practices included ethanol trade with respect to Brazil and ethanol, agricultural products and motorcycle trade with respect to India, cars and shellfish with respect to the EU, and digital service taxes with respect to Canada and France.

We are assessing the possible impact on imports from various countries, particularly those where tariffs or the US trade deficit are high. Contact us for more information regarding how these actions could impact your imports.

2/11/25:

The Executive Order increasing Section 232 tariffs on aluminum products and derivatives was issued today, confirming the increase from 10% to 25% on these products from all countries as reported yesterday, except from Russia which would still be subject to a 200% tariff, and also a potential exemption from tariffs for aluminum smelted and cast in the United States.

As reported yesterday, both the Section 232 tariffs on the steel and aluminum imports are effective as of March 12 with previous country exemptions and quotas, as well as product exclusions being eliminated. The March 12 effective date applies to steel and aluminum derivatives currently existing under the Section 232 tariffs, while the effective date for new derivatives is pending establishment of system to collect tariffs on these imports. The Federal Register Notice with additional implementation guidelines and the list of steel and aluminum derivatives covered by the Section 232 tariffs is forthcoming.

2/10/25:

On February 10, President Trump reportedly signed Executive Orders on steel and aluminum (the aluminum EO has not been published yet) and invoked Section 232 of the Trade Expansion Act of 1962 to increase aluminum tariffs from 10% to 25%, and effectively apply 25% tariffs on certain aluminum and steel products from all countries, as of March 12, 2025 (pending aluminum EO details). This action will cover products subject to the existing Section 232 tariffs and reportedly other downstream products such as structural steel, aluminum extrusions, and steel strand for pre-stressed concrete, but an exemption may apply to steel products melted and poured in the United States. Please contact us for additional details on the covered products. The Executive Order also eliminates all country exemptions and quotas (e.g., Argentina, Australia, Brazil, Canada, EU countries, Japan, Mexico, South Korea, Ukraine and the United Kingdom), Generally Approved Exclusions (GAE), and product specific exclusions. Please contact us for information on the timing of when these exemptions and exclusion will be eliminated. President Trump also announced plans to announce additional tariffs on specific products as well as reciprocal tariffs later this week.

2/7/25:

As IEEPA 10% tariffs on China have been ongoing this week, a February 5 EO Amendment that was publicly announced and released on February 7 extends use of De Minimis (Low Value) while pending Commerce review, but ongoing questions remain on Low Value shipments entered before this announcement, as well as Customs Bonds, FTZs, and Customs Valuation, among other issues. In response to the tariffs, China retaliated with series of tariffs starting February 10, including 15% on coal and LNG, and 10% on crude oil, agricultural machinery, and certain vehicles. Meanwhile, US and EU tariff escalation reports continue, and reports of President Trump potentially issuing an EO on reciprocal tariffs as early as today or next week.

2/4/25:

Escalated negotiations with Mexico and a Canada have led to a pause in the tariff implementation for 30 days. Reports indicate that talks between the United States and China are occurring within the next 24 hours.

2/3/25:

The Executive Orders for China and Mexico have been posted on the White House website and align with our 2/1 report. However, today Mexican President Claudia Sheinbaum and President Trump announced via social media that the two countries agreed to delay implementation of the tariff increases on Mexico products by one month - March 3, 2025. Mexico agreed to take steps to prevent the inflow of fentanyl and migrants into the United States, including sending soldiers to the border. We are closely watching developments on the China and Canada front for possible implementation delays. It has been reported that Trump is speaking with Canadian Prime Minister Justin Trudeau this afternoon.

2/1/25:

After fluctuating reports yesterday between a February 1 and March 1 date for initiation of the tariffs, President Trump signed three executive orders (EOs) today, said to implement 25% additional tariff on Mexico and Canada (except 10% for Canadian energy resources), and a 10% additional tariff on China, effective Tuesday, February 4 at 12:01am ET. Goods in final transit to the United States before 12:01 am ET on February 1 are exempt from these tariffs. While only the Canada EO and the White House Fact Sheet covering the tariffs have been officially released, various details on the China and Mexico EOs have been reported and unofficial copies have been circulated that have not been made publicly available at the time of this posting. This update is based on this latest intel, but as we have seen over the last few weeks, a lot can change in 24 hours, and more so in a little more than two days before the effective date.  

The President is invoking the International Emergency Economic Powers Act (IEEPA) to impose tariffs due to the national emergency posed by illegal drugs, including fentanyl, and illegal immigration. These tariffs, targeting all goods from Canada, Mexico, and China, would be in addition to existing duties, such as Section 301 tariffs, and would remain until the crisis is resolved. The orders include retaliation clauses to counter measures such as retaliatory tariffs from Canada, Mexico and China, as well as information on the applicability of de minimis, free trade zones (FTZ), drawback. We expect US Customs and Border Protection (CBP) or other US agencies to provide additional guidance to the trade community on the governance of these tariff implementations (e.g., clarity on HTSUS codes, Ch. 98 provisions, USMCA application, FTZ, bonds, goods on water, etc.).

Canada

The Canada EO defines the “Energy Resources” subject to the tariffs as including: crude oil, natural gas, lease condensates, natural gas liquids, refined petroleum products, uranium, coal, biofuels, geothermal heat, kinetic movement of flowing water, critical minerals.

In response to the tariff announcements, Canada has also announced retaliatory tariffs of 25% on a wide variety of American goods on this list including certain beverages, perfume, clothing, shoes, consumer products, limber and plastic products, etc., enacted in two stages:

• February 4: tariffs on $30 billion of US products
• February 21: tariffs on $125 million of US products

Canada and certain provinces are also considering other retaliatory measures.

We expect action from Mexico and China as well.

1/30/25:

From the Oval Office this evening, President Trump announced that 25% tariffs on Canada and Mexico are starting February 1, and deciding whether oil will be exempt from tariffs. These increases are pending issuance of an Executive Action or similar official documentation, which if issued, may not come until February 1.

1/26/25:

On January 26, President Trump announced plans to impose tariffs starting at 25% and potentially increasing to 50% in one week, alongside treasury, banking, and financial sanctions, as well as specific travel and immigration measures. These actions were a response to Colombia’s initial refusal to accept migrants deported from the United States. However, within hours of the announcement, the White House released a statement indicating that Colombia had agreed to accept the migrants, thereby averting the imposition of these measures, including the tariffs. The draft orders related to these tariffs issued under the authority of International Emergency Economic Powers Act (IEEPA),  and other measures will remain unsigned unless Colombia fails to uphold its agreement. This situation underscores President Trump’s readiness to swiftly implement tariffs as a tool in international relations to ensure compliance with US terms. It appears IEEPA may be the authority employed to implement immediate tariffs.

1/22/25:

The Trump Administration continues to announce possible additional tariffs that will be applied to specific country targets. For example, on January 22, Trump raised possible tariff increases on Russia in connection with the war in Ukraine. On January 21, he also announced possible increases of 10% on China and 25% on Mexico and Canada as early as February 1. To date, no official action to implement tariff increases has taken place.

1/20/25:  

Additional tariffs have yet to be imposed, but an America First Trade Policy executive order was issued on President Trump’s first day in office, outlining various administrative agency investigations and potential reorganizations as summarized further below. Many of the investigatory reports are due in April 2025, however, other sources indicate that additional tariffs may be announced as early as February 2025 in relation to these policy developments. 

1. Investigation of Trade Deficits: The Administration is investigating the causes of persistent trade deficits, with potential measures such as global tariffs being considered.
2. Establishment of an ERS: The feasibility of creating an External Revenue Service (ERS) to manage tariffs and trade-related revenues is being explored, potentially impacting how duties are collected.
3. Review of Unfair Trade Practices: The US Trade Representative (USTR) is tasked with identifying unfair trade practices and recommending actions, which may include tariffs.
4. USMCA Review and Public Consultation: A public consultation process will begin for the 2026 review of the United States–Mexico–Canada Agreement (USMCA), assessing its impact on American stakeholders and considering the United States’ continued participation.
5. Currency Manipulation: Measures against currency manipulation are under review, potentially impacting international trade dynamics.
6. Trade Agreements: USTR shall review existing trade agreements to recommend revisions to achieve or maintain appropriate level of reciprocal and mutually advantageous concessions, as well as identify countries for negotiation of new agreements.  
7. AD/CVD Review: Policies regarding Antidumping and Countervailing Duties (AD/CVD) laws are being reviewed to ensure compliance and address transnational subsidies.
8. De Minimis Exemption Review: The impact of the $800 duty-free de minimis exemption on tariff revenues and public health will be assessed, with potential modifications to protect US interests.
9. Section 301 Tariffs on China:  USTR shall assess the Section 301 Four-Year Review Report from May 14, 2024, and recommend actions necessary to remediate any issues.  
10. Additional China Focused Reviews:  The memorandum outlines other initiatives to review with respect to China, including the trade relations under the Economic and Trade Agreement between the United States and China (indicating a potential of tariffs or other measures as needed), legislative proposals regarding Permanent Normal Trade Relations with the People’s Republic of China (PRC), the status of US intellectual property rights conferred upon PRC persons is being assessed to ensure reciprocal and balanced treatment.
11. Section 232 Tariffs on Aluminum and Steel: Review of the effectiveness of the exclusions, exemptions, and other import adjustments on steel and aluminum as imposed under the Section 232 tariffs.
12. Unlawful Migration and Fentanyl Flows: Commerce and DHS to assess unlawful migration and fentanyl flows from Canada, Mexico, the PRC, and other relevant jurisdictions to recommend appropriate measures to resolve such emergency issues.
13. Additional Reviews: Examining extraterritorial taxes, World Trade Organization, and Federal Procurement agreements in connection to Buy America, export control authorities and national security,  and recent rule from BIS covering the Information and Communication Technology and Services on Connected Vehicles.