The future of the IEEPA-based fentanyl-related and reciprocal tariffs remains in limbo as the cases against these tariffs continue their slog through the federal courts. On August 29, the Court of Appeals for the Federal Circuit (the “Fed. Circuit”) agreed with the Court of International Trade’s (“CIT”) holding that IEEPA does not authorize the President to impose the fentanyl-related and reciprocal tariffs. In its ruling, the Fed. Circuit also affirmed the CIT’s grant of declaratory relief while vacating the CIT’s permanent injunction. The Fed. Circuit stayed its ruling pending an appeal by the government.
Yesterday, September 3, the Trump Administration petitioned the U.S. Supreme Court to overturn the lower court decision that found his IEEPA-based tariffs illegal; and to make its determination on an expedited schedule. The government has proposed that the Supreme Court decide on its petition for a writ of certiorari by September 10, 2025, and, upon a grant of certiorari, undertake expedited consideration of the merits with the oral argument in the first week of November. The businesses and states challenging the IEEPA tariffs have agreed to this schedule.
Today, President Trump signed an executive order implementing the U.S.'s trade deal with Japan. According to the White House, the order locks in 15% tariff rates on most imports from Japan, “alongside separate sector-specific treatment for automobiles and automobile parts; aerospace products; generic pharmaceuticals; and natural resources that are not naturally available or produced in the United States."
Persons interested in the Section 232 investigation into imports of wind turbines and their parts and components have until September 9, 2025 to file comments with the Commerce Department’s Bureau of Industry and Security.
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 September 4, 2025:
| Country | U.S. Tariff Measure | Status |
Global [Canada & Mexico Exempt] | Reciprocal tariffs – 10% ad valorem duty Country specific duty rates of 15% to 50% ad valorem Certain goods excluded.
| In Effect Pending Court Resolution Revised 7/31/2025 Implemented 4/2/2025 Executive Order Establishing Tariffs Executive Order Revising Tariffs CBP Bulletin on Excluded Electronics Executive Order Reducing China Tariff Rates Fed. Circuit Administrative Stay Fed. Circuit Order Granting Motion to Stay Executive Order Implementing US-UK Trade Deal Executive Order Extending Effective Date of Country-Specific Tariffs Executive Order Suspending Duty-Free de minimis Treatment Executive Order on Brazil Tariffs Executive Order Modifying Reciprocal Tariffs Executive Order on India Tariffs |
| Global | Copper – 50% ad valorem duty on imports of semi-finished copper products and intensive copper derivative products | Implemented: 7/30/2025 Executive Order Initiating Investigation |
| Global | Steel – 50% ad valorem duty on imports of steel articles and derivative products with no exemptions or exclusions
25% ad valorem duty on imports of steel articles and derivative products from the United Kingdom. Certain aerospace products from the United Kingdom exempt. | Revised 6/4/2025 Implemented: 3/12/2025 Proclamation on Sec. 232 Duties Executive Order Removing “Stacking” of Tariff Programs Proclamation Increasing Tariff Rate Executive Order Implementing US-UK Trade Deal Commerce Fed Reg Notice Adding Derivative Products |
| Global | Aluminum – 50% ad valorem duty on imports of aluminum articles and derivative products with no exemptions or exclusions
25% ad valorem duty on imports of aluminum articles and derivative products from the United Kingdom. Certain aerospace products from the United Kingdom exempt. | Revised 6/4/2025 Implemented: 3/12/2025 Proclamation on Sec. 232 Duties Executive Order Removing “Stacking” of Tariff Programs Proclamation Increasing Tariff Rate |
| China | Chinese Vessels – Port Entry Fees on Chinese owned or built vessels, and foreign-built car carriers. | Implemented: 4/17/2025 USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing |
| Global | Automobiles – 25% ad valorem duty on imports of automobiles (with certain allowances for USMCA-qualifying autos) and certain automobile parts (with limited tariff offsets).
Import quota and reduced tariffs for automobiles and automobile parts from the United Kingdom. | 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 |
| Global | All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed | Implemented 4/2/2025
|
| 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 | In Effect Pending Court Resolution Implemented: 3/4/2025; 4/2/2025 (updated) |
| Mexico | 25% ad valorem duty on all non-USMCA-qualifying products of Mexico | In Effect Pending Court Resolution Implemented: 3/4/2025; 4/2/2025 (updated) |
| China | 20% ad valorem duty on all products of China | In Effect Pending Court Resolution Implemented: 3/4/2025 CBP Fed Reg Notice |
| Global | Wind Turbines – potential tariffs on imports of wind turbines and their parts and components | Pending: Section 232 Investigation DOC Initiation and Request for Public Comments Comments due Sept. 9, 2025 |
| Brazil | Brazil's Acts, Policies, and Practices Related to Digital Trade and Electronic Payment Services; Unfair, Preferential Tariffs; Anti-Corruption Enforcement; Intellectual Property Protection; Ethanol Market Access; and Illegal Deforestation | Pending: Section 301 Investigation
|
| Global | Unmanned Aircraft Systems – potential tariffs on imports of unmanned aircraft systems (UAS) and their parts and components | Pending: Section 232 Investigation |
| Global | Polysilicon – potential tariffs on imports of polysilicon and its derivatives | Pending: Section 232 Investigation |
| Global | Aircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts | Pending: Section 232 Investigation |
| Global | Critical Minerals – potential tariffs on imports of processed critical minerals and derivative products | Pending: Section 232 Investigation |
| Global | Medium & 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 |
| Global | Semiconductors – potential tariffs on imports of semiconductors, SME, and derivative products | Pending: Section 232 Investigation |
| Global | Pharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products | Pending: Section 232 Investigation |
| Global | Lumber – potential tariffs on imports of timber, lumber, and their derivative products | Pending: Section 232 Investigation |
| Global | 100% ad valorem duty as “secondary tariffs” on countries that do business with Russia. | Proposed: 7/14/2025, announced by President Trump. |
| Global | 200% ad valorem duty on imports of pharmaceuticals (currently subject to Sec. 232 investigation) | Proposed: 7/8/2025, announced by President Trump at cabinet meeting |
| Global | 100% tariff on movies produced outside of the United States | Proposed: 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.
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