Trump Administration Announces Reciprocal Tariffs

On the first day of the Trump Administration, the President issued the America First Trade Policy. Among other priorities, the policy outlined the intention of the Administration to review trade agreements to ensure reciprocal and mutually advantageous free trade agreements with partner countries.

On February 13, 2025, President Trump issued a memorandum titled “Reciprocal Trade and Tariffs” instructing several agencies to investigate the harm to the United States from any non-reciprocal trade arrangements.

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. As a result, a universal 10% tariff will be imposed on all imports from ALL countries, effective 12:01 a.m. EDT on April 5, 2025.

Additional country-specific tariffs will also apply. Goods from countries listed in Annex I of the Executive Order will face higher, country-specific ad valorem rates, as detailed in annex I. (See the table below for the full list.)

The country-specific tariffs will take effect on April 9, 2025 at 12:01 a.m. EDT and will remain in effect until the President determines that the economic harms identified in the order have been addressed or mitigated.

If a country is not included in Annex I, the standard 10% duty will apply.

The following goods are not subject to the additional tariffs (see Annex II of the Executive Order for the full list):

• all articles that are encompassed by 50 U.S.C. 1702(b);
• (ii) all articles and derivatives of steel and aluminum subject to the duties imposed in Proclamation 9704 of March 8, 2018 (Adjusting Imports of Aluminum Into the United States), as amended, Proclamation 9705 of March 8, 2018 (Adjusting Imports of Steel Into the United States), as amended, and Proclamation 9980 of January 24, 2020 (Adjusting Imports of Derivative Aluminum Articles and Derivative Steel Articles Into the United States), as amended, Proclamation 10895 of February 10, 2025 (Adjusting Imports of Aluminum Into the United States), and Proclamation 10896 of February 10, 2025 (Adjusting Imports of Steel into the United States);
• all automobiles and automotive parts subject to the additional duties imposed in Proclamation 10908 of March 26, 2025 (Adjusting Imports of Automobiles and Automobile Parts Into the United States);
• other products enumerated in Annex II to this order, including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products;
• all articles from a trading partner subject to the rates set forth in Column 2 of the Harmonized Tariff Schedule of the United States (HTSUS); and
• all articles that may become subject to duties pursuant to future actions under section 232 of the Trade Expansion Act of 1962.

Mexico and Canada

All goods of Canada or Mexico under the terms of general note 11 to the HTSUS, as related the United States of America, United Mexican States, and Canada (USMCA), continue to be eligible to enter the U.S. market under these preferential terms.  However, all goods of Canada or Mexico that do not qualify as originating under USMCA are presently subject to additional ad valorem duties of 25 percent.

Articles imported from Canada or Mexico under the previous executive orders imposing 25% tariffs are not subject to additional tariffs under this new order.

Energy, energy resources, and potash from Canada (non-USMCA) will have a 10% tariff.

The $800 de minimis threshold for commercial imports still applies.

China

President Trump signed a second Executive Order and issued a Fact Sheet ending duty-free de minimis treatment for covered goods from the People’s Republic of China (PRC) and Hong Kong starting May 2, 2025 at 12:01 a.m. EDT.

Imported goods sent through means other than the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties.

Finally, the order states that if any trading partner retaliates against the United States in response to this action, the Administration may increase or expand the duties imposed in the order.

The rates of duty established by this order are in addition to any other duties, fees, taxes, exactions, or charges applicable to such imported articles, except as provided in subsections (d) and (e) of the order.

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