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Our Take

| 5 minute read

Trump Tariff Tracker – October 10

On Monday, President Trump announced in a Truth Social post that "[b]eginning November 1st, 2025, all medium and heavy-duty trucks coming into the United States from other countries will be tariffed at the rate of 25%."   This announcement expands the coverage of the tariffs that the President previously stated would only apply to heavy trucks; and it delays implementation of those tariffs by a month.  A proclamation formally imposing these tariffs has not been released by the White House. 

While we await the Supreme Court’s review of the combined challenges to the legality of tariffs imposed under the International Emergency Economic Powers Act, seven Senators have introduced legislation to end the national emergency that President Trump declared on April 2, 2025, in Executive Order 14257, which imposed the reciprocal tariffs.  This legislation, S.J. Res. 88, would terminate the national emergency and thus the reciprocal tariffs initiated in EO 14257, based on Congress’s authority under section 202 of the National Emergencies Act.  Because this is considered a privileged bill, this resolution must receive a vote on the Senate floor.    

Even with the federal government shutdown, deadlines still loom for interested persons to participate in ongoing trade investigations and reviews. The deadline is October 17, 2025, for interested persons to submit comments on the Section 232 investigations into imports of personal protective and medical equipment, and robotics and industrial machinery.  The period for submitting written comments on the USMCA to the USTR or requesting to participate in the USTR’s public hearing on the USMCA remains open until 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 October 10, 2025:

CountryU.S. Tariff MeasureStatus
Global

Lumber – 10% ad valorem duty on imports of softwood timber and lumber 

25% ad valorem duty on imports of certain upholstered wooden products

25% ad valorem duty on imports of kitchen cabinets and vanities

Reduced tariffs on subject imports from U.K., the E.U., and Japan

Implemented 9/29/2025 (effective 10/14/2025)

Executive Order Initiating Sec. 232 Investigation

DOC Request for Public Comments

Proclamation on Sec. 232 Duties

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 

Global 100% tariff on movies produced outside of the United StatesProposed: 5/4/2025 and 9/29/2025, announced by President Trump on Truth Social
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
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, usmca, sj res 88, international trade, heavy trucks, medium trucks