Overview
Provided below is a status update and summary of tariffs that have been implemented since February 1, 2025, and impacts on imports from multiple countries.
IEEPA (Fentanyl) Tariffs
IEEPA tariffs were announced on February 1, 2025 and went into effect on February 4, 2025. The current tariff burden is as follows:
- Goods with Country of Origin China (including Hong Kong) 20%
Tariff rates were originally 10% and then were increased to 20% on March 4, 2025
All goods under all HTS numbers are subject to these tariffs
- Goods with Country of Origin Canada 35%
Tariffs were paused until March 4, 2025 and went into effect on March 4, 2025
Goods qualifying for USMCA treatment are excluded effective March 7, 2025
Goods subject to Section 232 steel and aluminum tariffs or Section 232 automobile and auto parts tariffs are not subject to Canada IEEPA tariffs.
Tariffs were increased to 35% effective August 1, 2025
- Goods with Country of Origin Mexico 25%
Tariffs were paused until March 4, 2025 and went into effect on March 4, 2025
Goods qualifying for USMCA treatment are excluded effective March 7, 2025
Goods subject to Section 232 steel and aluminum tariffs or Section 232 automobile and auto parts tariffs are not subject to Mexico IEEPA tariffs.
Section 232 Duties on Steel and Aluminum Products and Steel and Aluminum Derivative Products
Section 232 duties on all imports of steel and aluminum subject to the HTS numbers identified in the published Federal Register notices went into effect on March 12, 2025. There are no exceptions or exclusions and all steel and aluminum as well as derivative goods are subject to these duties.
Steel and Aluminum duties from all countries were increased to 50% on June 4, 2025. Additionally, on June 4, 2025, in the same Executive Order, a new tariff stacking procedure was announced. Under the new procedure, products subject to Section 232 tariffs on steel or aluminum are no longer exempt from the reciprocal tariff rate if the product is a steel or aluminum derivative. Under the stacking procedure, for derivative products, the 50% tariff rate applies to the steel or aluminum content and the reciprocal tariff rate applies to the remaining value of the product.
Section 232 Duties on Semi-Finished Copper and Copper Derivative Products
On August 1, 2025, Section 232 duties on semi-finished copper and intensive copper derivative products went into effect based on HTS code.
If goods are subject to Section 232 Auto/Auto Parts, then the same good is not subject to Section 232 Steel/Aluminum/Copper duties, IEEPA Canada, or IEEPA Mexico tariffs.
IEEPA Universal/Reciprocal Tariffs
IEEPA Universal tariffs of 10% on imports of all goods from all countries. The tariffs went into effect on April 5, 2025, however, the escalated tariffs on specific list of 83 countries have been paused for 90 days until July 9, 2025. The U.S. and China also agreed to pause the reciprocal tariffs of 125% for 90 days.
- Goods with Country of Origin China (including Hong Kong) 10%
(125% paused for 90 days until August 12, 2025)
- Goods with Country of Origin from All Other Countries 10% to 41%
Tariffs on specific countries were increased on August 1, 2025 and went into effect on August 7, 2025. See Annex I
- Goods with Country of Origin of European Union Countries Capped at 15%
Tariffs are capped at 15% .
If a product specific normal duty is greater than 15% then no additional universal/reciprocal tariffs are applicable.
If a product specific normal duty is less than 15% then the difference in duty rates not to exceed 15% will be assessed on the difference.
- Goods with Country of Origin Brazil 50%
The universal/reciprocal tariffs are not applicable on the following goods which are currently subject to Section 232 duties or will be subject to Section 232 duties as part of ongoing investigations. This exemption is explicitly articulated in Section 2(b) of the Executive Order and enumerated in Annex II announcing the universal/reciprocal tariffs.
- All automobiles and autoparts subject to Section 232 duties
- Certain Pharmaceuticals
- Certain Semiconductors
- Certain Lumber articles
- Certain Critical minerals
- Certain Energy and energy products
The 10% reciprocal tariff rate is similarly not applicable to goods from Mexico or Canada. Mexico is subject to a 25% tariff and Canada is subject to a 35% tariff rate to combat fentanyl entering the US (i.e. the “IEEPA fentanyl” tariffs) except for those products qualify under the USMCA for duty free treatment.
Tariffs and Duties Are Cumulative (Stacked)
The tariffs and duties summarized above are cumulative (i.e. stacked) and are not mutually exclusive. These rates also apply on top of any Section 301, antidumping and countervailing duties, and any normal duty rate. As a result, the duties and tariffs must be calculated as follows:
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