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Our Take

| 3 minute read

Trump Tariff Tracker -- May 28

In a stunning turn of events for the Trump Administration’s trade policy, today, May 28, the Court of International Trade vacated President Trump's reciprocal tariffs and trafficking-related tariffs on China, Canada and Mexico, all of which were issued under the International Emergency Economic Powers Act (“IEEPA”).  The court held that the retaliatory tariffs "exceed any authority granted to the President by IEEPA to regulate importation by means of tariffs" and that the trafficking tariffs on China, Canada and Mexico "fail because they do not deal with the threats set forth in those orders."  The CIT’s three-judge panel was unanimous in its ruling, declaring that the tariffs imposed by the Trump Administration would be vacated.  This decision vacates the tariffs entirely and permanently enjoins the government from enforcing them.

The Trump Administration has filed an appeal with the U.S. Court of Appeals for the Federal Circuit.  While the government is seeking to overturn the CIT decision, the tariffs remain vacated unless the higher court issues a stay.  Until the Court of Appeals issues a ruling, the CIT’s decision not only impacts the current tariffs issued under IEEPA, but also undercuts the President’s ability to impose new tariffs under the guise of IEEPA. 

Note, the CIT’s ruling does not impact the tariffs that have been imposed pursuant to Section 232 Investigations or which are still subject to ongoing Commerce Department investigations.  For interested parties, the comment period for the Commerce Department’s Section 232 Investigation on imports of commercial aircraft and jet engines, and parts for commercial aircraft and jet engines remains open until June 3, 2025. 

Keeping track of all of the tariffs that have been promulgated or proposed during the Trump Administration continues to be a head-spinning task.  To help follow the proliferation of tariffs in the Trump Administration, I have put together the following list of each of the tariff measures that have been implemented, pending, or proposed since January 20, 2025. 

Here is the developing landscape of U.S. tariffs as of May 28, 2025:

CountryU.S. Tariff MeasureStatus

Global 

[Canada & Mexico Exempt]

Reciprocal tariffs – 10% ad valorem duty

China-specific 54% ad valorem duty on de minimis valued imports, other country-specific duties suspended 

Certain goods excluded

VACATED 5/28/2025

Revised 5/12/2025

Implemented 4/2/2025

Presidential Memorandum

Executive Order Establishing Tariffs

Executive Order Revising Tariffs

CBP Bulletin on Excluded Electronics

Executive Order Reducing China Tariff Rates

CIT Ruling Slip Op. 25-66

ChinaChinese Vessels – Port Entry Fees on Chinese owned or built vessels, and foreign-built car carriers.

Implemented: 4/17/2025

USTR Fed Reg Notice 

USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing

GlobalAutomobiles – 25% ad valorem duty on imports of automobiles (with certain allowances for USMCA-qualifying autos) and certain automobile parts (with limited tariff offsets) 

Implemented 4/3/2025 (effective 5/3/2025 for automobile parts)

Proclamation on Sec. 232 Duties

Proclamation with HTS Amendments

Proclamation Establishing Tariff Offsets on Parts

Executive Order Removing “Stacking” of Tariff Programs

Global All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed

Implemented 4/2/2025  

Executive Order 

 

GlobalSteel – 25% ad valorem duty on imports of steel articles and derivative products with no exemptions or exclusions

Implemented: 3/12/2025

Proclamation on Sec. 232 Duties

Commerce Fed Reg Notice

Executive Order Removing “Stacking”  of Tariff Programs

GlobalAluminum – 25% ad valorem duty on imports of aluminum articles and derivative products with no exemptions or exclusions

Implemented: 3/12/2025

Proclamation on Sec. 232 Duties

Commerce Fed Reg Notice

Executive Order Removing “Stacking” of Tariff Programs

Canada

10% ad valorem duty on non-USMCA-qualifying energy and potash 

25% ad valorem duty on all other non-USMCA-qualifying products of Canada

VACATED 5/28/2025

Implemented: 3/4/2025; 

4/2/2025 (updated) 

CIT Ruling Slip Op. 25-66

Executive Order Update

Executive Order Suspending 

CBP Fed Reg Notice

Executive Order

Mexico25% ad valorem duty on all non-USMCA-qualifying products of Mexico

VACATED 5/28/2025

Implemented:  3/4/2025; 

4/2/2025 (updated) 

CIT Ruling Slip Op. 25-66

Executive Order Update

Executive Order Suspending

CBP Fed Reg Notice 

Executive Order

China20% ad valorem duty on all products of China 

VACATED 5/28/2025

Implemented: 3/4/2025

CIT Ruling Slip Op. 25-66

CBP Fed Reg Notice 

Increase Executive Order

GlobalAircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

 

GlobalCritical Minerals  – potential tariffs on imports of processed critical minerals and derivative products

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

Executive Order

GlobalMedium & Heavy Duty Trucks – potential tariffs on imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts. 

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

GlobalSemiconductors – potential tariffs on imports of semiconductors, SME, and derivative products

Pending: Section 232 Investigation 

DOC Initiation and Request for Public Comments

GlobalPharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

GlobalCopper – potential tariffs on imports of copper and derivative products

Pending: Section 232 Investigation

Executive Order Initiating Investigation 

DOC Request for Public Comments

GlobalLumber – potential tariffs on imports of timber, lumber, and their derivative products

Pending – Section 232 Investigation

Executive Order Initiating Investigation

DOC Request for Public Comments

Global 100% tariff on movies produced outside of the United StatesProposed:  5/4/2025, announced by President Trump on Truth Social
E.U.25% ad valorem duty on all products of the E.U. Proposed:  2/26/2025, superseded by Reciprocal Tariffs

This list will be updated weekly as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.