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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Threatened to start on or after Apr. 2 (Mar. 24, 2025)
Threatened “secondary tariffs” (Mar. 30, 2025)
10% baseline (unless replaced by a country-specific rate below)
25%
25–50%
All products (see exceptions below)
All products from any country that imports Venezuelan oil
All products from any country that imports Iranian or Russian oil
See related publications below For trading partners with a country-specific rate below: Under the current language of the executive order, it appears the country-specific rate was in effect on April 9. Further guidance on this point may be forthcoming. Effective April 10, the country-specific rate for all countries, except China, is suspended until July 9. During this time, imports from those trading partners will be subject to the 10% baseline reciprocal tariff rate.
Effective May 14, China’s country-specific rate will also be suspended until August 12. During this time, imports from China will be subject to the 10% baseline reciprocal tariff rate.
Effective Apr. 9, 2025: (a) 25% ad valorem tariffs on (a) non-USMCA compliant fully assembled vehicles; and (b) non-Canadian and non-Mexican content of USMCA-compliant fully assembled vehicles imported from the United States
Effective Mar. 13, 2025: 25% ad valorem tariffs on CAD $29.8 billion worth of U.S.-origin goods
The Ontario government suspended its 25% surcharge on all electricity exports to the United States (Mar. 11, 2025)
Effective Mar. 4, 2025: 25% ad valorem tariff on $30 billion worth of U.S.-origin goods
Effective date expected Apr. 2: 25% ad valorem tariff on $125 billionworth of additional goods
Chad
Reciprocal tariff: Delayed until July 9 (effective Apr. 10, 2025)
Effective May 14, 2025: additional 10% ad valorem tariff on all U.S.-origin goods
Effective Apr. 10, 2025; to be removed by May 14: additional 125% ad valorem tariff on all U.S.-origin goods
Effective Mar. 10, 2025: (a) 15% ad valorem tariffs on U.S.-origin chicken, cotton, corn, and wheat (b) 10% ad valorem tariffs on U.S.-origin aquatic products, beef, dairy products, fruit, pork, sorghum, soybeans, and vegetables
Effective Mar. 4, 2025: imports of U.S.-origin logs suspended
Effective Feb. 10, 2025: (a) 15% ad valorem tariffs on supercooled natural gas and coal from the U.S. (b) 10% ad valorem tariffs on U.S.-origin crude oil
Effective Feb. 4 (modified Apr. 4; rare earth controls to be removed by May 14): export controls on tungsten; tellurium; bismuth; molybdenum; indium products; and seven categories of medium and heavy rare earth-related items, including samarium, gadolinium, zirconium, dysprosium, lutetium, scandium, and yttrium
Colombia
Threatened and rescinded (Jan. 26, 2025)
25%
All products
Côte d’Ivoire
Reciprocal tariff: Delayed until July 9 (effective Apr. 10, 2025)
21%
All products (see exceptions below)
Cuba
Reciprocal tariff exemption: imports not subject to reciprocal tariffs at this time
Democratic Republic of Congo
Reciprocal tariff: Delayed until July 9 (effective Apr. 10, 2025)
11%
All products (see exceptions below)
Dominican Republic
Threatened to start Apr. 2 (Mar. 24, 2025)
25%
All products
Purchaser of Venezuelan oil, which may trigger additional tariffs
Equatorial Guinea
Reciprocal tariff: Delayed until July 9 (effective Apr. 10, 2025)
13%
All products (see exceptions below)
EU
Reciprocal tariff: Delayed until July 9 (effective Apr. 10, 2025)
Threatened (Feb. 26, 2025)
Threatened (Mar. 13, 2025)
20%
25%
200%
All products (see exceptions below)
TBD
Alcohol products, including champagne and wine
During a cabinet meeting on February 26, President Trump said the announcement will be made “very soon.”
Reciprocal tariff exception: aluminum and derivative products subject to Section 232 tariffs are not subject to the reciprocal tariffs
“Stacking” exception: 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 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.
Increases the tariff rate from 10% to 25%. Expands the list of derivative products subject to the tariffs (effective Mar. 12, 2025).
Reciprocal tariff exception: automobiles subject to Section 232 tariffs are not subject to the reciprocal tariffs
“Stacking” exception: automobiles subject to Section 232 tariffs are not subject to (a) the tariffs on Canadian- and Mexican-origin goods, (b) any applicable Section 232 tariffs on aluminum and derivative products, or (c) any applicable Section 232 tariffs on steel and derivative products
For automobiles that qualify for preferential treatment under the USMCA, the tariff will apply to the non-U.S. content.
Reciprocal tariff exception: automobile parts subject to Section 232 tariffs at the time of import are not subject to the reciprocal tariffs
“Stacking” exception: automobile parts subject to Section 232 tariffs are not subject to (a) the tariffs on Canadian- and Mexican-origin goods, (b) any applicable Section 232 tariffs on aluminum or derivative products, or (c) any applicable Section 232 tariffs on steel or derivative products
Parts that qualify for preferential treatment under the USMCA will initially be exempt. The Commerce Department will establish a process for applying the tariff exclusively to the value of the non-U.S. content in these parts and then publish notice of that process in the Federal Register.
By June 24, 2025, the Commerce Department will establish a process for including additional parts within the scope of this tariff.
See semiconductors, semiconductor equipment, and derivative products below
On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of legacy chips, leading-edge chips, & microelectronics.
Lumber, timber, and derivative products
Threatened (Mar. 3, 2025)
25%
TBD
Commerce initiated a Section 232 investigation. A report is due to the President by November 26, 2025.
Containers, chassis, and chassis parts (HTSUS 8609.00.00, 8716.390090, 8716.90.30, 8716.90.50)
Ship-to-shore gantry cranes (HTSUS 8426.19.00)
As part of the USTR’s Section 301 investigation into China’s targeting of the maritime, logistics, and shipbuilding sectors, President Trump directed the USTR to consider tariffs on (a) ship-to-shore cranes manufactured, assembled, or made using Chinese-origin components, or manufactured anywhere in the world by a company owned, controlled, or substantially influenced by a Chinese national; and (b) other cargo handling equipment.
The USTR is accepting comments on the proposed tariffs until May 19. The proposed tariffs cover both products of China, as well as STS cranes manufactured anywhere in the world using Chinese-origin components or by a company owned, controlled, or substantially influenced by a Chinese national.
Trump authorized Commerce and the USTR to initiate an investigation to implement the tariffs.
Oil and gas
Threatened to start Feb. 18, 2025 (Jan. 31, 2025)
TBD
TBD
Pharmaceuticals, pharmaceutical ingredients, and derivative products
Threatened (Feb. 18, 2025)
25% or higher
TBD
See related publications below
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.
Processed critical minerals and derivative products
Threatened (Apr. 15, 2025)
TBD
TBD
See related publications below
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.
“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).
Semiconductors, semiconductor manufacturing equipment, and derivative products
Threatened (Feb. 18, 2025)
25% or higher
TBD
See related publications below
On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of semiconductors; semiconductor manufacturing equipment; and derivative products, including downstream products that contain semiconductors.
Steel
Implemented (effective Mar. 12, 2025)
25%
See HTSUS Chapter 99, notes 16(j), 16(l)-(m)
See related publications below
Reciprocal tariff exception: steel and derivative products subject to Section 232 tariffs are not subject to the reciprocal tariffs
“Stacking” exception: 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.
Expands the list of derivative products subject to the tariffs (effective Mar. 12, 2025).
On Aril 22, Commerce initiated a Section 232 investigation to determine the effects on the national security of imports of medium-duty trucks, heavy-duty, trucks, and medium- and heavy-duty truck parts, and their derivative products.
The reciprocal tariffs do not apply in the following circumstances:
Goods loaded onto a vessel at the port of loading and in transit on the final mode of transport before the reciprocal tariffs take effect will not be subject to the baseline or country-specific ad valorem tariffs (as applicable).
Articles and derivatives of steel and aluminum that are already subject to Section 232 tariffs are excluded.
Automobiles and automobile parts that are subject to Section 232 tariffs at the time of import are excluded.
Additional articles listed in Annex II to the executive order, including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products, are excluded. On April 11, President Trump expanded Annex II to include additional Harmonized Tariff Schedule of the United States (HTSUS) headings and subheadings covering smartphones, computers, and other electronics.
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: U.S. Customs and Border Protection (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. 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.
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. 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.
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