Tariffs and Trade Deals

Latest Developments in Tariff Policy:

SUPREME COURT CASE UPDATE: On February 20, 2026, the Supreme Court issued its opinion in Learning Resources, Inc., et al. v. Trump, ruling that IEEPA does not authorize the president to impose tariffs. Read more about the litigation here.

Mexico & Canada Tariffs under IEEPA
Status: Mexico 25% took effect March 4, 2025
Canada 35% took effect August 1, 2025
CBP suspended collection February 22, 2026 pursuant to the Supreme Court IEEPA decision

On February 1, 2025, President Trump first issued a fact sheet and thereafter signed two executive orders imposing new tariffs on imports from Canada and Mexico:

• 25% tariff on imports from Canada
• 25% tariff on imports from Mexico

The tariffs on imports from Canada and Mexico were initially set to take effect February 4, 2025, but were delayed by one month following commitments made by both countries to secure the border and stop the flow of drugs into the United States.

On March 5, 2025, the Administration announced a temporary one-month pause on automobile tariffs for Mexico and Canada. Subsequently, on March 6, 2025, President Trump temporarily suspended tariffs on certain goods from Canada and Mexico that meet the United States-Mexico-Canada Agreement (USMCA) requirements, effective March 7, 2025. The Federal Register Notice for Canada can be found here, the Federal Register Notice for Mexico can be found here. Customs and Border Protection (CBP) issued guidance on the additional tariffs on imports from Canada and Mexico and China. The official CBP statement can be accessed here.

On March 11, 2025, two Federal Register Notices were issued, amending the Notice of Implementation of Additional Duties on Products of Mexico Pursuant to Executive Order 14194 and the Notice of Implementation of Additional Duties on Products of Canada Pursuant to Executive Order 14193. These Federal Register amendments notices can be accessed [here for Mexico] and [here for Canada]. Both notices reduced the duty on potash from 25% to 10%.

Energy resources from Canada will have a lower 10% tariff. President Trump also signed two executive orders preserving de minimis treatment for Canada and Mexico until “adequate systems are in place” collect tariff revenue from these shipments.

On July 31, 2025, President Trump signed an Executive Order increasing tariffs on Canada from 25% to 35%. The same day, CBP published CSMS #65798609 regarding the additional duties.. Effective August 1, 2025, except for energy goods, goods covered by the USMCA, and other exempted goods, imports from Canada are subject to a 35% IEEPA  Fentanyl Tariff. Transshipment of Canadian goods will be subject to a 40% tariff.  

China Tariffs under IEEPA
Status: CBP suspended collection February 22, 2026 pursuant to the Supreme Court IEEPA decision.

On February 1, 2025, President Trump first issued a fact sheet and thereafter signed an executive order imposing a new 10% tariff on imports from China and Hong Kong.

On March 3, 2025, a further amendment was issued via executive order, increasing the tariff rate on imports from China from 10% to 20%. The corresponding Federal Register Notice can be found here.

The IEEPA tariffs apply in addition to any general rate of duty, Section 301 duty, or Section 232 duty that may be applicable to articles of Chinese origin. A full list of Section 301 China tariff classifications can be found on the HTSUS website administered by the U.S. International Trade Commission.

Brazil Tariffs Under IEEPA
Status: Went info effect, August 6, 2025. CBP suspended collection February 22, 2026 pursuant to the Supreme Court IEEPA decision.

On July 30, President Trump signed an executive order imposing an additional 40% tariff on imports from Brazil. This tariff applies on top of the 10% reciprocal tariff, bringing the total tariff on Brazilian goods to 50%.  The EO declared a new national emergency under IEEPA citing the Brazilian government’s “unusual and extraordinary policies and actions harming U.S. companies, the free speech rights of U.S. persons, U.S. foreign policy, and the U.S. economy.”

On August 1, 2025, CBP published CSMS # 65807735, which implements the updated tariff on imports from Brazil. Effective August 6, 2025, all imports from Brazil enter for consumption or withdrawn from the warehouse for consumption are subject to an additional 40% duty.  

Exceptions: for products covered by the Section 232 Tariffs, the additional 40% duty will not be applied. The EO also excludes an extensive list of items that are not subject to the additional duties. View the full list of HTS codes in Annex I here.

India Tariffs Under IEEPA
Status: Not in effect.
Initially took effect August 27, 2025, ended by Executive Order 14384 February 6, 2026. 

On August 6, 2025, the White House issued an Executive Order imposing an additional 25% tariff on imports from India. Effective August 27, imports from India will be subject to an extra 25% tariff in addition to the 25% India-specific Reciprocal Tariff, raising the total tariff on Indian imports to 50%. Note that goods subject to the current 50% Section 232 Tariff are excluded from the Reciprocal Tariff and this additional tariff on India.

On August 25, 2025, CBP published CSMS # 66027027, which implemented the 25% IEEPA Russian Oil Tariff on India. Effective August 27, 2025, imports from India are subject to this 25% additional Russian Oil Tariff on top of the 25% IEEPA Reciprocal Tariff. Thus, Indian imports not exempted by the Russian Oil Tariff and the Reciprocal Tariff are subject to a total of 50% duty.  

Shipments that are (1) in transit to the U.S. before August 27, 2025, and (2) entered for consumption before September 17, 2025, are exempt from this Russian Oil Tariff. In addition, goods under Annex II of the Reciprocal Tariff EO and Section 232 are also exempt from this Russian Oil Tariff.  

On February 2, 2026, President Trump issued an Executive Order eliminating the additional 25% tariff on imports from India, finding that India had taken significant steps to address the issues identified in the August Executive Order.

Steel and Aluminum Tariffs Under 232
Status: In effect as of March 12, 2025, increase to 50% in effect as of June 4, 2025

On February 11, 2025, President Trump issued two Proclamations imposing enhanced import duties on steel and aluminum products under Section 232 of the Trade Expansion Act of 1962. The orders eliminate certain exemptions from the duties, expand their scope to cover additional products, and raise the duties on covered aluminum goods from 10% to 25%.

On February 18, 2025, two Federal Register Notices were published that included lists of “derivative” products subject to the 25% tariffs on steel and aluminum under Section 232. The Federal Register Notices, which include the specific HTS subheadings for the derivative products in Annex 1 are available here (Proclamation No. 10896 – Steel) and here (Proclamation No. 10895 – Aluminum).

On March 2, 2025, the Department of Commerce (BIS) issued implementation instructions updating the Harmonized Tariff Schedule to reflect the new duty rates. These notices introduced new subheadings—9903.81.xx for steel and 9903.85.xx for aluminum—and confirmed the effective date of March 12, 2025. (See: Implementation of Steel Duties Under Proclamation 10896 and Implementation of Aluminum Duties Under Proclamation 10895)

On March 11, 2025, the Secretary of Commerce certified that CBP had “adequate systems in place to fully, efficiently, and expediently process and collect tariff revenue” for the expanded Section 232 duties on derivative steel and aluminum products—including those classified outside of HTS Chapters 73 and 76. This certification was later published in the Federal Register on March 14, 2025.

Later that evening, CBP issued updated Cargo Systems Messaging Service (CSMS) guidance confirming that all derivative products—including those classified outside of Chapters 73 and 76—would be subject to the 25% duties for entries made on or after 12:01 AM on March 12, 2025. The CSMS message for Steel can be found HERE.  Aluminum HERE.

On June 3, 2025, President Trump signed a Proclamation increasing Section 232 tariffs on steel and aluminum from 25% to 50%. The same day, CBP published CSMS # 65236574, CSMS # 65236645, and CSMS # 65236374, implementing the increase. On June 9, 2025 CBP published additional guidance (CSMS 65289012 & CSMS 65288784) updating the list of steel and aluminum HTS subject to 232 tariffs. Full steel HTS list available here. Full aluminum HTS list available here.

According to CBP’s instructions, all imports of steel and aluminum and their derivative products from all countries (except those from the UK) are subject to the 50% Section 232 Tariffs effective June 4, 2025. CBP’s instructions also include reporting guidance for separately declaring steel/aluminum content and non-steel/aluminum content for derivative products.  

For derivative products classified under HTS Chapters 73 (steel) or 76 (aluminum), the 50% Section 232 tariff applies to the full value of the imported product. For derivatives classified outside of Chapters 73 and 76, the 50% duty applies only to the value of the steel or aluminum content within the product. Importers are encouraged to review CBP guidance on calculating content values (See: Section 232 Tariffs on Steel and Aluminum Frequently Asked Questions).

The additional tariffs apply to all countries. This means that countries that previously had certain exemptions from the 232 tariffs such as Argentina, Australia, Brazil, Canada, the EU, Japan, Mexico, and South Korea are now subject to the 50% tariffs.

With respect to tariff stacking, only the non-steel/aluminum content is subject to the 10% Reciprocal Tariff and the steel/aluminum content is exempted from the Reciprocal Tariff. However, other tariffs still apply to the steel/aluminum content, including Section 301 and IEEPA Fentanyl Tariff.  

Imports of derivative aluminum articles that contain “any amount of primary aluminum used in the manufacture of the derivative aluminum articles is smelted in Russia, or the derivative aluminum articles are cast in Russia,” are subject to a duty of 200%.

On August 15, 2025, CBP published CSMS # 65936570 and CSMS # 65936615. Both CSMS messages implement the Department of Commerce’s inclusion of additional 407 HTS codes to the Section 232 Steel, Aluminum Tariffs.  

See a complete list of additional HTS codes for steel and steel derivative products here.  

See a complete list of additional HTS codes for aluminum and aluminum derivative products here.  

On October 7, the Bureau of Industry and Security  (BIS) of the U.S. Department of Commerce released 95 inclusion requests for the Section 232 Tariff on Steel and Aluminum and their Derivative Products. Interested parties filed the inclusion requests in response to BIS’s Notice of the Opening of the Section 232 Inclusions Process published on September 17, 2025. The release of the 95 inclusion requests starts a two-week comment period for the potential inclusions. Interested parties may comment on these inclusion requests until October 21, 2025. During the last inclusion process, BIS added 407 of the 467 requested HTS to the Section 232 Tariff on Steel and Aluminum.  

Tariffs on Venezuelan Oil under IEEPA & 301
Status: CBP suspended collection February 22, 2026 pursuant to the Supreme Court IEEPA decision

On March 24, 2025, President Trump issued an executive order enabling the Secretary of State to impose 25% tariffs on imports from countries that import oil from Venezuela. The order authorizes the Secretary of State, in consultation with the Secretary of the Treasury, the Secretary of Commerce, the Secretary of Homeland Security, and the United States Trade Representative, to determine whether the tariff of will be imposed on goods from any country that imports Venezuelan oil, directly or indirectly, on or after April 2, 2025.

The additional tariffs are additional to any other duties and would expire one year after the last date on which the country imported Venezuelan oil.

Automobile & Automobile Parts Tariffs under 232
Status:
Automobiles: In effect as of April 3, 2025
Automobile parts: In effect as of May 3, 2025 

On March 26, 2025, President Trump issued a Proclamation imposing a 25% tariff on automobiles and automobile parts

“Automobiles” includes passenger vehicles (SUVs, crossovers, sedans, cargo vans, and light trucks). “Certain automobile parts” includes engines and engine parts, transmissions and powertrain parts, and electrical components. The full list of the subject merchandise can be access through Annex I of this Federal Register Notice. The tariffs on automobiles went into effect on April 3. The tariffs on automobile parts went into effect on May 3.

According to the Fact Sheet, for automobiles that qualify for preferential tariff treatment under the USMCA, importers may submit documentation identifying the amount of U.S. content in each automobile. The importer may then be eligible to apply the new tariff only to non-U.S. content.

The 25% tariff will not apply to automobile parts that qualify for preferential treatment under the USMCA until the Secretary of Commerce establishes a process to apply the tariff exclusively to the value of non-U.S. content of automobile parts.

The Federal Register notice can be found here.

On April 29, President Trump signed a Proclamation reducing duties for automakers that complete final assembly of vehicles in the U.S. These automakers will get a partial credit against the costs of 25% Section 232 tariffs on non-USMCA qualifying parts. Under the measure, carmakers may apply for an “import adjustment offset” equal to 3.75% of the sticker price of all cars assembled in the U.S. from April 3, 2025 through April 30, 2026, and for an amount equal to 2.5% of the retail price from May 1, 2026 through April 30, 2027.

On May 1, 2025, CBP published CSMS # 64913145, implementing the global automobile parts tariff.

The automobile parts tariff took effect May 3, 2025, for all entries enter for consumption or withdrawn from warehouse for consumption.

• For entries of automobile parts without special tariff treatment, 25% duty will apply under HTS 9903.94.05.
• For entries of automobile parts that are (1) eligible for special tariff treatment, g., USMCA or (2) not subject merchandise, there will be no duty under HTS 9903.94.06.
• Not drawback is available for automobile parts tariff.

On September 24, the International Trade Administration (ITA) of the Department of Commerce (DOC) and the U.S. Trade Representative (USTR) jointly published a notice regarding implementing Executive Order 14346, which directed the DOC and USTR to implement frameworks for trade agreements reached between the United States and foreign governments.  

Under this notice, auto and auto parts with a column 1, general duty of at least 15% will not be subject to the IEEPA Reciprocal Tariff. The total duty amount for auto and auto parts with a column 1, general duty of less than 15% will be capped at 15%.  

CBP Compliance

If CBP determines that the importer has declared an inaccurate value of non-U.S. content is, the new 25% tariff will apply to the full value of the automobile.

The new 25% tariff will be imposed retroactively to April 3 for all imports of the same model imported by the same importer until the importer corrects the overstatement and it is verified by CBP.

Now more than ever it is critical for importers to have a USMCA compliance plan to ensure eligibility, keep proper records, and accurately document all non-U.S. content.

Reciprocal Tariffs
Status:
10% baseline tariffs took effect April 5, 2025
Country-specific tariff took effect August 7, 2025
CBP suspended collection February 22, 2026 pursuant to the Supreme Court IEEPA decision

On April 2, 2025, President Trump signed an Executive Order and issued a Fact Sheet declaring a national emergency arising from conditions reflected in large and persistent annual U.S. goods trade deficits.

Effective at 12:01 a.m. (ET) on April 5, 2025, the United States will impose a 10% ad valorem baseline tariff on imports of all foreign-origin goods. This baseline tariff is in addition to any other applicable duties or tariffs.

The Executive Order also imposed country-specific tariff rates on imports from certain trading partners (listed in Annex I of the EO), which apply even if goods were imported under a free trade agreement. These rates include the 10% baseline tariff. View CBP guidance on the 10% tariff and reciprocal tariffs here. The country-specific rates were set to take effect April 9. However, President Trump issued an Executive Order pausing the country-specific tariff rates for 90 days for all countries listed in Annex I, except China.

On July 31, 2025, the White House announced the updated IEEPA Reciprocal Tariff on imports from countries around the globe. The Executive Order reinstated the country-specific IEEPA Reciprocal Tariff with updated tariff rates. Effective August 7, 2025, imports to the U.S. are subject to the country-specific IEEPA Reciprocal Tariff.  

See a Full List of IEEPA Reciprocal Tariff rates here.  

On August 4, 2025, CBP published CSMS # 65829726, which implements the IEEPA Reciprocal Tariff from EO 14257 “Further Modifying the Reciprocal Tariff Rates.”  

Effective August 7, 2025, imports from countries identified in the EO 14257 are subject to each country’s unique HTS code with a specific corresponding tariff rate. However, the IEEPA Reciprocal Tariff on imports from China currently remains at 10%.  

Further, the updated IEEPA Reciprocal Tariff does not apply to goods from Canada and Mexico covered by the USMCA. Goods subject to the Section 232 Tariff are also excluded from the IEEPA Reciprocal Tariff.  If CBP determines that a shipment has been transshipped to evade the IEEPA Reciprocal Tariff, an additional 40% tariff will be applied on top of the Reciprocal Tariff.  

On September 5, 2025, President Trump signed Executive Order 14257 modifying the scope of reciprocal tariffs. On September 6, 2025, CBP published CSMS # 66151866, which implemented the EO, adding and removing certain goods from Annex II. Annex II is a list that covers goods not subject to the IEEPA Reciprocal Tariff.  

China Reciprocal Tariffs

After China imposed retaliatory tariffs on U.S. goods, on April 8, 2025, President Trump issued an Executive Order imposing additional tariffs on Chinese imports. The order amended the Administration’s original reciprocal tariff of 34%, increasing it to 84%. On April 9, 2025, President Trump issued an Executive Order increasing the rate again to 125%. This would have applied on top of the 20% IEEPA tariffs imposed in March, bringing the total tariff on all imports from China to 145%.

However, on May 12, 2025, President Trump signed an Executive Order pausing China reciprocal tariffs for 90 days. CBP subsequently issued guidance implementing the 90-day suspension. View CSMS here. During this time, the 10% baseline tariff and the 20% IEEPA tariff on Chinese goods still applies, bringing the cumulative tariff on Chinese goods to 30%.

On August 11, 2025, President Trump signed an Executive Order suspending China’s specific reciprocal tariff until November 10, 2025. CBP subsequently published CSMS # 65894387, implementing the Executive Order.

On November 1, 2025, the White House released the latest update on the U.S.-China trade negotiations. Effective November 10, 2025, the IEEPA Reciprocal Tariff will decrease from 20% to 10%. The 10% IEEPA Reciprocal Tariff will remain in effect for another year, until November 10, 2026. 

Tariff Stacking Executive Order

On April 29^th, President Trump issued an Executive Order specifying which tariffs “stack” and which do not. The Order aims to avoid the cumulative effect of overlapping tariffs on goods.

The Order outlines how tariffs should be applied:

Section 232 Automobile Tariff

If this tariff applies, then the following tariffs do not apply:

• IEEPA Canada
• IEEPA Mexico
• Aluminum & steel section 232

Canada IEEPA – If this tariff applies, then aluminum and steel 232 tariffs do not apply.

MX IEEPA – If this tariff applies, then aluminum and steel 232 tariffs do not apply.

Steel & Aluminum – If Section 232 steel tariffs apply, aluminum tariffs DO stack. Vice versa – if Section 232 aluminum tariffs apply, steel tariffs DO stack.

The Order is retroactive to March 4, 2025.

Copper Tariffs
Status: In effect as of August 1, 2025

In February 2025, the President signed an Executive Order calling for a 232 investigation into the national security risks arising from the United States’ increasing dependence on imported copper.

On Wednesday, July 9, 2025, President Trump announced that a 50% tariff on copper imports would take effect August 1, 2025. President Trump stated that the tariffs will be imposed to address the national security threat posed by foreign importer copper.

On July 31, 2025, CBP published CSMS #65794272, which officially implements the 50% tariff. 

Effective August 1, 2025, all imports of copper and copper derivative products entered for consumption, or withdrawn from warehouse for consumption, will be subject to HTS code 9903.78.01.  

The full list of copper and copper derivative products HTS codes can be found here.  

De Minimis
Status: De minimis exemption ended August 29, 2025

On July 30, 2025, the White House announced the suspension of the de minimis exemption. Currently, packages valued under $800 can enter the U.S. duty-free. Effective August 29, 2025, all shipments via international postal service valued under $800 entered for consumption, or withdrawn from the warehouse for consumption, must be declared before CBP and subject to all applicable duties. See additional CBP guidance for international mail here. 

The Executive Order contains two methods of duty declaration before CBP, and shipments under $800 are subject to either one of these two methods. First, the shipment can be subject to the applicable ad valorem IEEPA Reciprocal and/or Fentanyl Tariff based on the country of origin. In the alternative, the shipment can be subject to the following tariff rule: 

• Countries with an effective IEEPA tariff rate of less than 16 percent: $80 per item; 
• Countries with an effective IEEPA tariff rate between 16 and 25 percent (inclusive): $160 per item; and 
• Countries with an effective IEEPA rate above 25 percent: $200 per item.

On August 28, 2025, CBP published CSMS #66065494, which officially implemented the end of de minimis shipments. Effective August 29, 2025, goods previously qualified for de minimis treatment, except those outlined in 19 USC 132(a)(2)(C), must be declared before CBP.  

On February 20, 2026, President Trump issued an Executive Order making clear that the suspension of duty-free de minimis treatment for all countries will continue, despite the Supreme Court’s IEEPA decision.

Semiconductor 232 Tariffs
Status: In effect as of January 15, 2026

On January 14, 2026, U.S. Customs and Border Protection (CBP) published CSMS # 67400472, implementing the latest Section 232 Tariff on semiconductors and their derivative products. Effective January 15, 2026, certain semiconductors and their derivative products under HTSUS 8471.50, 8471.80, and 8473.30 are subject to a 25% ad-valorem duty. According to CBP, 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 (TPP) 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 TPP 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. 

Certain semiconductors and their derivative products are excluded, such as semiconductors used for/in data centers, research and development, emerging growth companies, consumer electronics, factory robotics, industrial machinery, and the public sector.  

Cuba IEEPA/NEA Tariffs
Status: Not yet in effect

On Jan. 29, 2026, President Trump issued an Executive Order titled Addressing Threats to the United States by the Government of Cuba and released an accompanying White House Fact Sheet. The Executive Order declared a national emergency with respect to threats posed by Cuba’s government and established a mechanism to impose additional tariffs on imports from countries that supply oil to Cuba.

Under the framework: (1) the secretary of commerce will identify countries that supply oil to Cuba and share findings with the secretary of state; (2) in consultation with the Department of State, the Department of the Treasury, the Department of Homeland Security, and the U.S. trade representative, the secretary of state will recommend tariff levels; and (3) the president may then decide whether — and to what extent — to impose such duties.

Section 122 Tariffs

On February 20, 2026, President Trump announced he would replace the IEEPA tariffs with a tariff based on Section 122. This was initially announced at 10% and took effect on February 24^th. The President has announced that he is increasing it to the lawful maximum of 15%, but the effective date has not yet been set. This tariff would remain in effect for up to 150 days.

Additional Tariffs

Heavy Trucks, furniture, pharmaceutical products
Status: Heavy trucks tariffs took effect November 1, 2025

On Thursday, September 25, 2025, President Trump, via Truth Social, announced his intention to impose tariffs on (1) heavy trucks (25%), (2) certain furniture, including kitchen cabinets & associated products (50%), bathroom vanities & associated products (50%), and upholstered furniture (30%), and (3) branded and patented pharmaceutical products (100%).

On October 17, 2025, President Trump issued a Presidential Proclamation formalizing the tariffs on heavy trucks. The proclamation imposes a 25% tariff on imports of medium- and heavy-duty trucks and truck parts. This includes Class 3 to Class 8 vehicles, like large pick-up trucks, moving trucks, cargo trucks, dump trucks, and tractors for eighteen-wheelers. The Proclamation also imposes a 10% tariff on imports of buses, including school buses, transit buses, and motor coaches.

On October 22, 2024, Proclamation 10984 on subjecting Medium and Heavy Duty Vehicles, Medium and Heavy Duty Vehicles Parts, and Buses to a 25% Section 232 Tariff was published via a Federal Register Notice. According to the Proclamation, this Section 232 Tariff will become effective on November 1, 2025. If Medium and Heavy Duty Vehicles that qualify for USMCA treatment, the importer may submit documentation to identify the amount of U.S. content, and, after the Department of Commerce’s approval, the 25% Section 232 Tariff will only apply to non-U.S. content. 

On December 31, 2025, President Trump issued a proclamation delaying the increase in Section 232 duties on upholstered furniture, kitchen cabinets, and vanities for another year. The current 25% Section 232 duties on upholstered furniture, kitchen cabinets, and vanities will remain in effect for 2026.  

Timber & lumber
Status: In effect as of October 14, 2025

On September 29, 2025, President Trump issued a proclamation imposing a Section 232 Tariff on timber and lumber and their derivative products. Effective October 14, 2025, timber and lumber is subject to a 10% duty, upholstered wooden products are subject to a 25% duty, and kitchen cabinets and vanities are subject to a 25% duty. If no agreement can be reached between the U.S. and foreign governments, beginning January 1, 2026, the duty for upholstered wooden products and kitchen cabinets and vanities will increase to  30% and 50%, respectively.  

The proclamation specifically included that goods subject to (1) IEEPA Reciprocal Tariff, (2) IEEPA Additional Tariff on Brazil, and (3) IEEPA Russian Oil Tariff are not subject to this Section 232 Tariff. Unlike the other Section 232 Tariffs, duty drawback is available for this tariff.  

On December 31, 2025, President Trump issued a Proclamation amending tariffs on timber, lumber, and their derivative products. Effective January 1, 2027, the duty rate on imports of certain upholstered wooden products, as listed in Annex I will increase from 25% to 30% and the duty rate on imports of kitchen cabinets and vanities, as listed in Annex I will increase from 25% to 50%. The increase will continue in effect, except for countries with which the United States reaches an agreement that addresses the threatened impairment of the national security posed by imports of wood products.

Vessel Fees
Status: In effect as of October 14, 2025

On October 3, 2025, CBP published guidance implementing the Section 301 Investigation of China’s Targeting the Maritime, Logistics, and Shipbuilding Sectors, which was published on April 12, 2025, and amended on June 12, 2025. This Section 301 Investigation imposes new fees for vessels owned, operated, or built in China and for all foreign-built vehicle carrier vessels. 

Service fees on Chinese vessel operators and owners began on October 14, 2025 at $50 per net ton. There will be three subsequent fee increases: $80 beginning April 17, 2026; $110 beginning April 17, 2027; and $140 beginning April 17, 2028.

The fee will be charged up to five times per year, per vessel. 

CBP noted that the determination of whether the new fees apply to a vessel rely on the operator, not CBP. 

Agricultural Exemptions
Status: In effect as of November 13, 2025

On November 14, 2025, the White House subsequently announced that certain agricultural products will no longer be subject to the IEEPA Reciprocal Tariff. These products include: 

• Coffee and tea; 
• Tropical fruits and fruit juices;
• Cocoa and spices; 
• Bananas, oranges, and tomatoes;
• Beef; and 
• Additional fertilizers (some fertilizers have never been subject to the reciprocal tariffs). 

On November 14, 2025, CBP published CSMS # 66814923. Effective November 13, 2025, agricultural products described below are also exempted from the IEEPA Reciprocal Tariff.  

• Etrogs (classifiable in subheading 0805.90.01) 
• Tropical fruit, nesoi, frozen, whether or not previously steamed or boiled (classifiable in subheading 0811.90.80) 
• Date palm branches, Myrtus branches, or other vegetable material for religious purposes only (classifiable in subheading 1404.90.90) 
• Bread, pastry, cakes, biscuits and similar baked products, nesoi, and puddings, whether or not containing chocolate, fruit, nuts or confectionery, for religious purposes only (classifiable in subheading 1905.90.10) 
• Bakers’ wares, communion wafers, empty capsules suitable for pharmaceutical use, sealing wafers, rice paper and similar products, nesoi, for religious purposes only (classifiable in subheading 1905.90.90) 
• Acai (classifiable in subheading 2008.99.21) 
• Citrus juice of any single citrus fruit (other than orange, grapefruit or lime), of a Brix value not exceeding 20, concentrated, unfermented, except for lemon juice (classifiable in subheading 2009.31.60) 

View the full list of HTS codes here.

Trade Deals:

Following President Trump’s imposition of country-specific tariffs, the Administration indicated it was open to negotiating individual deals with trading partners. Below is a summary of the China and UK deals that have been agreed to thus far.

China

On May 12, 2025, the White House and the State Council of China jointly published statements putting a pause on escalating tariff rates.

According to the joint statement, China will lower the tariff on American imports to 10% for 90 days beginning May 14, 2025. The U.S. will simultaneously lower the China specific 125% Reciprocal Tariff to 10% for 90 days beginning May 14, 2025.

The 10% IEEPA Reciprocal Tariff on all imports will remain in effect and other duties will continue to apply to Chinese imports, including Section 301 Tariff, Section 232 Tariff, and the IEEPA Fentanyl Tariff.

CBP subsequently issued guidance implementing the 90-day suspension advising filers to replace HTSUS 9903.01.63 with 9903.01.25 to take advantage of the 10% tariff. View CSMS here.

On November 1, 2025, the White House released the latest update on the U.S.-China trade negotiations. Effective November 10, 2025, the IEEPA Reciprocal Tariff will decrease from 20% to 10%. The 10% IEEPA Reciprocal Tariff will remain in effect for another year, until November 10, 2026. Furthermore, the latest BIS 50% rule and the Section 301 investigation into China’s maritime, logistics, and shipbuilding sectors will also be paused for another year, until November 10, 2026.  

UK

On May 8, 2025, President Trump and UK Prime Minister Keir announced a “historic” trade deal aiming to eliminate trade barriers and provide market access for American exports.

Agreement highlights:

• The agreement will not eliminate the 10 percent blanket reciprocal tariff.
• The U.S. will negotiate “alternative arrangements” to its Section 232 tariffs on UK autos, steel, and aluminum.
• Streamlined customs procedures for U.S. exports
• Will establish a UK tariff-rate quota on U.S. ethanol, with a zero duty for imports under the quota
• The UK commits to reduce or eliminate numerous non-tariff barriers

To date, each country has only released fact sheets concerning the agreement’s details. Additional negotiations are expected.

Vietnam

On July 2, 2025 President Trump announced a trade deal with Vietnam. According to the announcement, Vietnam will allow U.S. goods to enter the country duty-free and Vietnamese exports to the U.S. will face a 20% duty rate. The announcement also stated that goods being transshipped through Vietnam will face a 40% duty rate.

Indonesia

On July 15, 2025 President Trump announced via social media that the U.S. and Indonesia had reached a trade deal. Under the deal, Indonesian imports will be subject to a 19% tariff. Exports to Indonesia are to be “tariff and non-tariff barrier free.” Indonesia has also committed to $20B in U.S. investment including $15 billion in U.S. energy, $4.5 billion in American agricultural products, and 50 Boeing jets.

Japan

On July 22, 2025 President Trump announced a trade deal with Japan. A 15% tariff rate will apply to all Japanese imports. According to the White House Fact Sheet, Japan also committed $550B to invest in U.S. industry and will deliver “breakthrough” openings to their markets across key sectors including agriculture and energy.

On September 4, 2025, the White House published “Implementing the United States—Japan Agreement.” Under this agreement, the total general duty and IEEPA Reciprocal tariff for imports from Japan will be capped at 15%. For Japanese autos and auto parts, the total general duty and Section 232 tariff will also be capped at 15%. This new measure will be applied retroactively for imports from Japan since August 7, 2025.  

On September 15, 2025, CBP published CSMS # 66242844, which carried out Executive Order 14345, Implementing the United States – Japan Agreement. For imports from Japan, including automobile and auto parts covered by the Section 232 Tariff, if the general duty is lower than 15%, the general duty plus IEEPA Reciprocal Tariff will be at 15%. If the general duty is at or higher than 15%, the general duty plus IEEPA Reciprocal Tariff will be capped at 15%.  

The Philippines

On July 22, 2025 President Trump announced a trade deal with the Philippines. A 19% tariff rate will apply to all Philippine imports. The Philippines will reportedly open their markets to U.S. imports, tariff-free.

European Union (EU)

On July 27, President Trump announced a trade deal with the EU. A 15% tariff will apply to most EU imports. Some categories of goods are exempt from new tariffs, including aircraft and plane parts, certain chemicals and some agricultural products. The EU also agreed to purchase $750 billion worth of energy from the US, and make an additional $600 billion worth of investments.

On August 21, 2025, the White House published Joint Statement on a United States-European Union Framework on an Agreement on Reciprocal, Fair, and Balanced Trade – The White House. 

Key points:

1. The U.S. is committed to applying the higher of either the column 1 general duty or a 15% duty. Beginning September 1, 2025, only column 1 general duty will apply to the following goods: unavailable natural resources, aircraft and aircraft parts, generic pharmaceuticals and their ingredients, and chemical precursors.
2. Section 232 tariffs on pharmaceuticals, semiconductors, and lumber, combined with column 1 general duty, will not exceed 15%.
3. The U.S. will remove the Section 232 auto and auto parts tariff on EU imports. EU auto and auto parts will be subject only to column 1 general duty or the 15% duty, whichever is higher.  

On September 24, the International Trade Administration (ITA) of the Department of Commerce (DOC) and the U.S. Trade Representative (USTR) jointly published a notice exempting more than 200 HTS codes from the IEEPA Reciprocal tariff on the EU, including natural resources, essential oils, civil aircraft and parts thereof, and pharmaceutical products.  

South Korea

On July 30, President Trump announced a trade deal with South Korea. A 15% tariff will apply to most South Korean imports. South Korea also agreed to invest $350 billion in U.S. projects selected by Trump and to purchase energy products worth $100 billion.

Pakistan

On July 30, President Trump announced a trade deal with Pakistan. A 19% tariff will apply to most imports from Pakistan. The deal will also allow the U.S. to help develop Pakistan’s largely untapped oil reserves.

Cambodia

The U.S.-Cambodia Agreement on Reciprocal Trade was announced on October 26, 2025. The agreement reduces reciprocal tariffs from 49% to 19%. Cambodia agreed to eliminate tariffs on U.S. industrial goods and agricultural products. The U.S. agreed to exempt certain products from the reciprocal tariff including agricultural and food products, raw materials and minerals, chemicals and pharmaceuticals, aircraft and parts, electronics and computing, industrial machinery and equipment, electrical equipment, wood products, textiles and fibers, precision instruments, and some metal products. Cambodia also agreed to work with the U.S. to address nontariff barriers and barriers to digital services trade.

Malaysia

El Salvador

On November 13, 2025, the White House announced a trade deal with El Salvador. The Joint Statement on the U.S.—El Salvador Agreement states that the U.S. will remove the IEEPA Reciprocal Tariff on certain “qualifying exports that cannot be grown, mined, or naturally produced” in the U.S. and certain textiles and apparel products originating under the CAFTA-DR. The U.S. will also “positively consider” El Salvador with respect to the Section 232 Tariff.  

Argentina

On November 13, 2025, the White House announced a trade deal with Argentina. The Joint Statement on the U.S.—Argentina Agreement states that the U.S. will remove the IEEPA Reciprocal Tariff on certain unavailable natural resources and non-patented pharmaceutical articles. The U.S. will “positively consider” Argentina with respect to the Section 232 Tariff.  

Ecuador

On November 13, 2025, the White House announced a trade deal with Ecuador. The Joint Statement on the U.S.—Ecuador Agreement states that the U.S. will remove the IEEPA Reciprocal Tariff on certain “qualifying exports {} that cannot be grown, mined, or naturally produced” in the U.S. 

Guatemala

On November 13, 2025, the White House announced a trade deal with Guatemala. The Joint Statement on the U.S.—Guatemala Agreement states that the U.S. will remove the IEEPA Reciprocal Tariff on certain “qualifying exports that cannot be grown, mined, or naturally produced” in the U.S. and certain textiles and apparel products originating under the CAFTA-DR.  

Switzerland

On November 14, 2025, the White House announced a trade deal between the U.S. and Switzerland, under which the U.S. will lower the IEEPA Reciprocal Tariff on Switzerland to the general duty rate or 15%, whichever is higher. On December 17, 2025, the United States Trade Representative (USTR) announced that the 15% IEEPA Reciprocal Tariff will be retroactively applied, effective November 14, 2025.  This trade deal mirrors the one the U.S. struck with the EU. The December USTR announcement implements the trade deal and retroactively applies the 15% IEEPA Reciprocal Tariff effective November 14, 2025.  

Liechtenstein

On November 14, 2025, the White House announced a trade deal between the U.S. and Liechtenstein, under which the U.S. will lower the IEEPA Reciprocal Tariff on Liechtenstein to the general duty rate or 15%, whichever is higher. On December 17, 2025, the United States Trade Representative (USTR) announced that the 15% IEEPA Reciprocal Tariff will be retroactively applied, effective November 14, 2025.  This trade deal mirrors the one the U.S. struck with the EU. The December USTR announcement implements the trade deal and retroactively applies the 15% IEEPA Reciprocal Tariff effective November 14, 2025.  

Taiwan

On January 15, 2026, the Department of Commerce announced a trade deal between the U.S. and Taiwan. The agreement lowers the reciprocal tariff rate from 32% to “no more than” 15%. The agreement also includes a zero percent reciprocal tariff for generic pharmaceuticals, their generic ingredients, aircraft components, and unavailable natural resources. Finally, Taiwanese semiconductor and technology enterprises agreed to make new, direct investments totaling at least $250 billion to build and expand advanced semiconductor, energy, and artificial intelligence production and innovation capacity in the United States.

India

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