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Our Take

| 6 minute read

Trump Tariff Tracker – October 23

The United States’ trade relations with India may be improving.  Reports this week indicate that the U.S. and India are nearing a deal to cut the U.S. tariffs on India from 50% to 15-16%.  The tariffs were raised on India in August based on U.S. government claims that India was purchasing oil from Russia, which was supporting Russia’s war in Ukraine. This made the tariffs on India the highest on any country in Asia.  On Tuesday, at the White House, President Trump said that he and Prime Minister Modi had spoken on the phone and agreed to reduce India's purchase of Russian oil. Prime Minister Modi acknowledged the call in a post on X but provided no details of the conversation.

On Friday, October 17, President Trump signed a Proclamation pursuant to Section 232 imposing tariffs on imports of medium- and heavy-duty trucks and parts, and buses. Imports of medium- and heavy-duty trucks and truck parts will face 25% tariffs.  For medium- and heavy-duty trucks that qualify for preferential tariff treatment under the USMCA, the tariff will only apply to the value of the non-U.S. content in the truck.  A 10% tariff will be imposed on imports of buses, including school buses, transit buses, and motor coaches. The tariffs in the Proclamation will take effect on November 1, 2025.  

On October 23, the USTR published in the Federal Register a determination under Section 301 of the Trade Act of 1974 that Nicaragua’s acts, policies, and practices related to abuses of labor rights, abuses of human rights and fundamental freedoms, and dismantling of the rule of law are unreasonable and burden or restrict U.S. commerce, and therefore are actionable.  The USTR had begun its investigation into Nicaragua in December 2024.  As a result of the determination that Nicaragua’s acts, policies, and practices are actionable, the USTR has proposed a range of responsive actions, including: (i) suspending some or all CAFTA-DR trade benefits to Nicaragua, and (ii) applying tariffs of up to 100% on some or all imports from Nicaragua.  Interested persons may submit written comments to the USTR on the proposed actions by November 19, 2025.

The public comment periods for two other USTR matters remain open.  In connection with USTR’s review of the USMCA, interested persons have until November 3, 2025, to submit written comments on the USMCA and/or request to participate in the USTR’s public hearing on the USMCA.  In connection with the duties imposed on ship-to-shore cranes and certain cargo handling equipment of China, interested persons may submit written comments on these duties to the USTR until November 10, 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 23, 2025:

       

U.S. Tariff Measure

Status

Global

Medium & Heavy Duty Trucks – 25% ad valorem duty on imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts

 

10%  ad valorem duty on imports of buses and motor coaches

Implemented 10/17/2025 (effective 11/1/2025)

DOC Initiation and Request for Public Comments

Proclamation on Sec. 232 Duties

China

Section 301: Cranes/Cargo Handling Equipment – 100% ad valorem duty on imports of STS cranes and other cargo handling equipment 

Implemented 10/16/2025 (effective 11/9/2025)

USTR Fed. Reg. Notice

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 

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

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 

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

China

Section 301: Chinese 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

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) 

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

China

20% 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

Nicaragua

Section 301: Nicaragua's Acts, Policies, and Practices Related to Labor Rights, Human Rights and Fundamental Freedoms, and the Rule of Law

PendingSection 301 Investigation

USTR Fed Reg Notice

Global 

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

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments

 

Global 

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

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments

 

Global 

Wind Turbines – potential tariffs on imports of wind turbines and their parts and components

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments

Brazil

Section 301: 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

PendingSection 301 Investigation

USTR Fed Reg Notice 

Public Hearing Transcript

 

Global

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

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments

Global  

Polysilicon – potential tariffs on imports of polysilicon and its derivatives

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments

Global

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

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments

Global

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

PendingSection 232 Investigation

Executive Order

DOC Initiation and Request for Public Comments

Global

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

PendingSection 232 Investigation 

DOC Initiation and Request for Public Comments

Global

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

PendingSection 232 Investigation

DOC Initiation and Request for Public Comments 

Global 

100% tariff on movies produced outside of the United States

Proposed: 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

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

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

india, international trade, nicaragua, medium duty trucks, heavy duty trucks, usmca, section 232, tariffs, section 301