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Our Take

| 6 minute read

Trump Tariff Tracker – October 31

The hot and cold nature of the U.S.’s trade relationship with China turned hot with yesterday’s announcement of a trade deal between China and the U.S. that will lower U.S. tariffs on Chinese goods while getting cooperation from the Chinese government on a broad array of trade concerns.  In Busan, South Korea, President Trump announced he and President Xi Jinping agreed to the U.S. reducing tariffs on China in exchange for China cracking down on the illicit fentanyl trade, resuming U.S. soybean purchases and allowing rare earth mineral exports.  Under the announced agreement, the fentanyl related tariffs on Chinese imports will be cut to 10% (down from 20%).  This reduces the overall tariff rate on Chinese imports to around 47%. 

Bilateral trade agreements with other Asian trading partners abounded during President Trump’s trip to Asia. The U.S. reached sweeping trade agreements with Cambodia and Malaysia.  Under these agreements, tariffs on U.S. goods would the eliminated (in the case of Cambodia) or greatly reduced (in the case of Malaysia) while the U.S. will maintain a reciprocal tariff rate of 19% for imports from Cambodia and Malaysia, except for products identified in the agreements that will receive a 0% reciprocal tariff rate.  The U.S. also reached frameworks for trade agreements with Thailand and Vietnam.  Notably, in the trade and framework agreements, each trading partner went beyond commitments related to duty rates, and committed to measures relating to collaborating on regulatory practices, combating tariff evasion, and implementing export controls.

On October 28, the USTR published a notice in the Federal Register for the initiation of a Section 301 investigation into China's apparent failure to comply with the 2020 Economic and Trade Agreement Between the Government of the United States of America and the Government of the People's Republic of China (Phase One Agreement).  The Section 301 Committee will be holding a public hearing on this investigation on December 16, 2025.  Interested persons may submit written comments and requests to appear at the hearing by December 1, 2025.

The USTR is continuing to accept comments on three open proceedings: (i) for the 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; (ii) for the investigation into ship-to-shore cranes and certain cargo handling equipment of China, the comment period is until November 10, 2025; (iii) for the investigation into Nicaragua, written comments on the proposed actions to be taken by may be submitted by November 19, 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 31, 2025:

       U.S. Tariff MeasureStatus
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

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

ChinaSection 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

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

ChinaSection 301: China's failure to comply with the 2020 Phase One Agreement

Pending: Section 301 Investigation

USTR Fed Reg Notice

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

Pending: Section 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

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

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

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

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, china, cambodia, malaysia, section 301, fentanyl tariffs, ustr investigations, international trade