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Our Take

| 6 minute read

Trump Tariff Tracker -- September 25

This evening, President Trump announced on Truth Social a series of new tariffs that will be imposed on pharmaceuticals, heavy trucks, and furniture and cabinets.

For pharmaceuticals, President Trump said in a Truth Social posting that the U.S. will be imposing a 100% tariff on imported brand-name or patented pharmaceutical products starting October 1, unless a manufacturer of the subject pharmaceuticals commits to building or expanding manufacturing plants in the U.S.  According to the President’s post, “[t]here will, therefore, be no Tariff on these Pharmaceutical Products if construction has started.”  This new tariff announcement did not mention imposing tariffs on imported generic pharmaceuticals.  Additionally, there was no reference to releasing a final report in the Section 232 investigation targeting pharmaceuticals.

Regarding heavy trucks, President Trump announced in a Truth Social post that “[i]n order to protect our Great Heavy Truck Manufacturers from unfair outside competition, I will be imposing, as of October 1st, 2025, a 25% Tariff on all ‘Heavy (Big!) Trucks made in other parts of the World.”  The posting did not address the details of the tariff, such as whether the 25% tariff would apply to all heavy-duty trucks or only those that do not comply with the USMCA.  While these products have also been subject to a Section 232 investigation by the Commerce Department, there was no mention of a final report being released. 

For certain furniture and cabinets, the President announced broad tariffs on various household products, stating that the U.S. “will be imposing a 50% Tariff on all Kitchen Cabinets, Bathroom Vanities, and associated products, starting October 1st, 2025. Additionally, we will be charging a 30% Tariff on Upholstered Furniture.”  As with the posting on heavy trucks, there was no indication whether these new tariffs on furniture and cabinets would apply across the board or whether USMCA compliant goods from Mexico and Canada would be exempt.  Similar to today’s other announcements on products that have been subject to Section 232 investigations, there was no indication that a final report on the Section 232 investigation on lumber and derivative products (which includes wooden cabinets and furniture) would be forthcoming now that tariffs are being imposed. 

With the announcement of these new tariffs related to their respective Section 232 investigations, President Trump appears to be bolstering his tariff policy with measures that would likely survive any actions that the Supreme Court may take on the IEEPA-based reciprocal and fentanyl-related tariffs later this year.

The Commerce Department has announced two new Section 232 investigations – one into imports of personal protective equipment, medical consumables, and medical equipment, including devices; and the second into imports of robotics and industrial machinery.  For both investigations, interested persons may submit comments on the investigations to the Commerce Department by October 17, 2025. 

As announced last week, the period for submitting written comments on the USMCA to the USTR remains open until November 3, 2025.  USTR will also be holding a public hearing on the operation of the USMCA on November 17, 2025.  Persons wishing to participate in the public hearing must submit a request to appear and a summary of testimony by November 3, 2025.

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 25, 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

Implementing Elements of EU Framework Agreement

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 Personal Protective and Medical Equipment – potential tariffs on imports of personal protective equipment, medical consumables, and medical equipment, including devices

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

 

Global Robotics and Industrial Machinery – potential tariffs on imports of robotics and industrial machinery

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

 

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

international trade, robotics, industrial machinery, protective equipment, medical equipment, heavy trucks, pharmaceuticals, furniture, cabinets, tariffs, usmca