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Our Take

| 5 minute read

Trump Tariff Tracker -- September 18

The Supreme Court has announced that it will hold oral argument on the morning of November 5, 2025, in the combined challenges to the legality of tariffs imposed under the International Emergency Economic Powers Act.  If the Court upholds the lower court decisions and strikes down the IEEPA-based tariffs, the baseline and country-specific reciprocal tariffs as well as fentanyl-related tariffs would be eliminated.  The Court’s ruling would not likely impact those tariffs that have been based on Section 232 investigations at the Commerce Department or Section 301 investigations at the USTR. 

The USTR has published its request for comments and notice of public hearing regarding the 2026 review of the USMCA by Canada, Mexico, and the U.S.  The USTR is seeking public comments on the operation of the USMCA in advance of the joint review of the USMCA by the parties on July 1, 2026.  The deadline for submission of written comments is November 3, 2025.  USTR will also be holding a public hearing on the operation of the USMCA on November 17, 2025.  Any persons wishing to participate in the public hearing must submit a request to appear and a summary of testimony by November 3, 2025.

While this joint review of the USMCA will not have an immediate impact on tariffs, the Trump Administration has indicated that it will take this opportunity to renegotiate those terms in the USMCA that may be seen as unfavorable to the U.S., such as tightening the rules of origin for preferential treatment of goods under the Agreement.  If this were to happen, goods that currently qualify for USMCA preferential treatment might no longer qualify.  For those goods that would otherwise be subject to Section 232 tariffs but for USMCA preferential treatment, a loss of USMCA preferential status would mean importers would need to start paying the Section 232 tariffs on imports of those goods from Canada and Mexico.

Keeping track of all 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 18, 2025:

CountryU.S. Tariff MeasureStatus

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 9/5/2025

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

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

Executive Order Extending China Tariff Rates

Executive Order Implementing US-Japan Trade Deal

Executive Order Modifying Reciprocal Tariff Coverage

GlobalCopper – 50% ad valorem duty on imports of semi-finished copper products and intensive copper derivative products

Implemented: 7/30/2025

Executive Order Initiating Investigation 

DOC Request for Public Comments

Proclamation on Sec. 232 Duties

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

Commerce Fed Reg Notice

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

CBP Guidance on Additional Steel Derivative Products

Commerce Notice of Inclusion of Additional 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

Commerce Fed Reg Notice

Executive Order Removing “Stacking” of Tariff Programs

Proclamation Increasing Tariff Rate

Executive Order Implementing US-UK Trade Deal

Commerce Notice of Inclusion of Additional Products

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

USTR Request for Comments on Proposed Modification

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

Executive Order Removing “Stacking” of Tariff Programs

Executive Order Implementing US-UK Trade Deal

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 

 

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) 

Executive Order

CBP Fed Reg Notice

Executive Order Suspending

Executive Order Update

CIT Ruling Slip Op. 25-66

Fed. Circuit Administrative Stay

Fed. Circuit Order Granting Motion to Stay

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

In Effect Pending Court Resolution

Implemented:   3/4/2025; 

4/2/2025 (updated) 

Executive Order

CBP Fed Reg Notice 

Executive Order Suspending

Executive Order Update

CIT Ruling Slip Op. 25-66

Fed. Circuit Administrative Stay

Fed. Circuit Order Granting Motion to Stay

China20% ad valorem duty on all products of China

In Effect Pending Court Resolution

Implemented: 3/4/2025

Executive Order

CBP Fed Reg Notice 

CIT Ruling Slip Op. 25-66

Fed. Circuit Administrative Stay

Fed. Circuit Order Granting Motion to Stay

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

 

BrazilBrazil'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

USTR Fed Reg Notice 

Public Hearing Transcript

 

GlobalUnmanned Aircraft Systems – potential tariffs on imports of unmanned aircraft systems (UAS) and their parts and components

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

Global  Polysilicon – potential tariffs on imports of polysilicon and its derivatives

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

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

Executive Order

DOC Initiation and Request for Public Comments

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 

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% ad valorem duty as “secondary tariffs” on countries that do business with Russia.Proposed: 7/14/2025, announced by President Trump.
Global200% 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 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. 

Tags

reciprocal tariffs, supreme court, ieepa, ustr, usmca, section 232 tariffs, international trade