Tariffs and Trade

On March 26, 2025, President Trump issued a proclamation imposing a 25% tariff on imports of automobiles (effective April 3, 2025) and certain automobile parts (tentatively effective May 3, 2025).

Effective March 7, 2025, imports from Canada and Mexico that meet USMCA rules of origin are exempt from the additional IEEPA duties. Imports that do not satisfy USMCA rules of origin are subject to a 25% tariff rate. Energy products from Canada and potash from Mexico and Canada are subject to a reduced tariff rate of 10%.

Effective March 4, 2025, imports from China are subject to a 20% tariff rate, an increase from a 10% tariff rate that went into effect on Feb. 4, 2025.

Note that many products imported from Canada and Mexico were already duty-free under MFN rates, making USMCA declarations unnecessary. Under the new policy, importers must document and ensure USMCA compliance (if eligible) to be exempt from the IEEPA tariffs. Otherwise, the 25% IEEPA tariff would apply.

On April 1, 2025, President Trump issued an Executive Order under the International Emergency Economic Powers Act (IEEPA) to establish a 10% baseline tariff and country-specific reciprocal tariffs on imported goods.

On April 9, 2025, President Trump issued an order delaying the country-specific reciprocal tariffs effective April 10, 2025. The country-specific reciprocal tariffs originally went into effect on April 9, 2025 and will be suspended for 90-days, after which the country-specific rates in Annex I will apply.

The baseline 10% tariff remains in effect for all products from all countries during this time, except for products that are covered by the exemptions listed in the original order (see below).

However, the 90-day pause does not apply to China due to their retaliatory tariffs on U.S.-origin goods. China's reciprocal tariff rate has increased from the original 34% to 84% and now to 125%. This applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EDT on April 10, 2025.

As of March 12, 2025, the expanded Section 232 tariffs on steel and aluminum are now in effect. All imports of steel and aluminum are subject to a 25% tariff, and previous country exemptions and tariff-rate quotas have been eliminated.

The tariffs also apply to certain derivative products based on the steel and aluminum content. The product exclusion process has been terminated, meaning previously approved exclusions are no longer valid.

The Section 301 China tariffs implemented in 2018-2019 remain in effect, with most tariff rates unchanged since their initial implementation. While some product exclusions have been extended, the majority have expired, except for a limited set scheduled to expire on May 31, 2025.

Additionally, a new 20% tariff on imports from China was imposed under IEEPA, taking effect on Mar. 4, 2025.