Dear Friends,
I am back from two weeks of meetings in China. It was a productive trip with many interesting conversations about what is happening in the United States, the future of U.S. trade policy, and the likely impact on the global economy.
In advance of President Trump’s big tariff announcement later this week, I thought it might be helpful if I circulated an updated (unofficial) “Trump Tariff Tracker”
(1) a 25% additional tariff imposed on steel, aluminum, and derivative articles went into effect on March 12, 2025. This tariff was imposed on national security grounds under Section 232 of the Trade Expansion Act of 1962 during Trump’s first administration and just recently revised. This list of derivative articles covered by the tariffs can be expanded by the Secretary of Commerce.
(2) a 20% additional tariff imposed on products of China. This tariff was imposed on national emergency grounds under the International Emergency Economic Powers Act (IEEPA) based on fentanyl imports. The action originally included a prohibition on Chinese-origin products being eligible to be imported under the de minimis provision of U.S. customs law, but that provision was suspended until the Secretary of Commerce confirms that the government is ready to administer this prohibition.
(3) a 25% additional tariff imposed on products of Mexico and on products of Canada (except potash, which got a 10% tariff, and Canadian “energy” products, which also got a 10% tariff). These tariffs were also imposed on national emergency grounds under IEEPA based on migration concerns and fentanyl imports. Articles that meet the applicable rules of origin under the United States-Mexico-Canada Agreement (USMCA) are exempt from these additional tariffs as of March 7, 2025.
(4) a 25% additional tariff imposed on automobiles and on auto parts. The additional tariff on automobiles goes into effect April 3, 2025, and the additional tariff on auto parts goes into effect no later than May 3, 2025. USMCA-originating automobiles may be eligible to pay the tariff on only the non-U.S. content. These tariffs are being imposed on national security grounds under Section 232 based on a report from Trump’s first term.
(5) a 25% additional tariff may be imposed on goods of any country that imports Venezuelan oil, whether directly or indirectly. These so-called “secondary tariffs” are being imposed under IEEPA and may take effect on or after April 2, 2025, based on a determination by the Secretary of State. China is a leading purchaser of Venezuelan oil.
In addition to these actions, there is also the on-going Section 301 investigation into China’s Targeting of the Maritime, Logistics and Shipbuilding Sectors for Dominance in which the administration has proposed imposing significant fees on Chinese vessel operators and on Chinese-built vessels that enter at U.S. ports; it also proposes adopting a scheduling requiring certain percentages of U.S. exports (by ocean) be carried on U.S.-flagged, U.S.-built vessels (a decision on the remedy to be imposed is expected to be announced in the coming weeks); the on-going Section 301 investigation into China’s policies regarding legacy semiconductors; the Section 232 investigation into copper and derivative articles; and the recent threat to impose secondary tariffs on countries that purchase Russian oil (similar to those imposed on Venezuela) over the war in Ukraine.
This is all in addition to the big announcement coming on “Liberation Day” (April 2, 2025), when President Trump is expected to unveil his “reciprocal tariffs.” These tariffs are expected to target jurisdictions, including the EU, China, India, Canada, Mexico, Vietnam, and others. More on this to follow.
We are assisting many clients trying to navigate this tumultuous period (e.g., developing mitigation strategies to deal with what is likely to be a higher U.S. tariff rate environment going forward). If you have any questions about these issues, or if we can otherwise help, please let us know.
Best regards,
Ted
