The U.S. Trade Representative ("USTR") concluded its investigation under Section 301 of the Trade Act of 1974, which was launched during the Biden Administration, regarding China's targeting of the semiconductor industry for dominance, but refrained from imposing immediate tariffs on China. Effective December 23, 2025, the USTR determined that China’s acts, policies, and practices regarding semiconductors are actionable under Section 301. However, the notice from the USTR says that the appropriate responsive action is to wait to impose tariffs in 18 months on June 23, 2027, at a rate to be announced not fewer than 30 days prior to that date. Beijing responded by saying in a statement that it “firmly opposes” this measure taken by the United States.
U.S. trading partners continue to pursue trade agreements with the Trump Administration as a way to minimize the tariff impact on their economies. India’s Ministry of External Affairs announced that it is increasing its negotiations with the U.S. to resolve differences related to tariffs, market access and regulatory concerns under the India–U.S. bilateral trade agreement that was announced in principle earlier this year. Both India and the U.S. have touted the trade agreement as an important step towards increasing bilateral trade and investment, especially in the manufacturing, technology and services sectors.
Indonesia announced that it has concluded material negotiations with the U.S. and is set to sign a trade agreement with the U.S. in January. Under the announced deal, import duties on Indonesian goods entering the U.S. will be set at 19 percent. This is a decrease from the earlier reciprocal tariff rate of 32 percent, but was short of the Indonesian government’s request for zero tariffs.
The U.S. Department of Commerce’s International Trade Administration announced that it will be implementing a process by which interested parties can propose automotive parts to be subject to the Section 232 tariffs. This process will provide for recurring two-week windows in January, April, July, and October, in which parties can make submissions to the Commerce Department requesting additional automotive parts to be added to the list of items subject to the Section 232 tariffs. The first two-week window will begin January 1, 2026, and will last until January 14. 2026. Additional information on this process and the opportunity for public comment can be found in the Department’s Federal Register notice by clicking here.
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 December 26, 2025:
| U.S. Tariff Measure | Status | |
| Nicaragua | Section 301: Acts, Policies, and Practices Related to Labor Rights, Human Rights and Fundamental Freedoms, and the Rule of Law January 1, 2026 - 0% ad valorem duty on all products of Nicaragua not under CAFTA-DR January 1, 2027 – 10% ad valorem duty on all products of Nicaragua not under CAFTA-DR January 1, 2028 – 15% ad valorem duty on all products of Nicaragua not under CAFTA-DR | Implemented: 12/12/2025 (effective 1/1/2026) |
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 11/20/2025 Implemented 4/2/2025 Executive Order Establishing Tariffs Executive Order Revising Tariffs CBP Bulletin on Excluded Electronics Executive Order Reducing China Tariff Rates 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 Executive Order Modifying Reciprocal Tariff Rates for China Executive Order Modifying Reciprocal Tariff Rates on Certain Agriculture |
| 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 |
| 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) Suspended 11/10/2025 |
| 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 |
| 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 |
| 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 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 |
| 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 Executive Order Removing “Stacking” of Tariff Programs Proclamation Increasing Tariff Rate |
| China | Section 301: Chinese Vessels – Port Entry Fees on Chinese owned or built vessels, and foreign-built car carriers. | Implemented: 4/17/2025 Suspended 11/10/2025 USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing |
| 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 |
| Global | All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed | Implemented 4/2/2025
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| 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) |
| 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) |
| China | 10% ad valorem duty on all products of China (reduced from original rate of 20%) | In Effect Pending Court Resolution Implemented: 3/4/2025 CBP Fed Reg Notice Fed. Circuit Administrative 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
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| 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
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| Global | Wind Turbines – potential tariffs on imports of wind turbines and their parts and components | Pending: Section 232 Investigation |
| 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
|
| Global | Unmanned Aircraft Systems – potential tariffs on imports of unmanned aircraft systems (UAS) and their parts and components | Pending: Section 232 Investigation |
| Global | Polysilicon – potential tariffs on imports of polysilicon and its derivatives | Pending: Section 232 Investigation |
| Global | Aircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts | Pending: Section 232 Investigation |
| Global | Critical Minerals – potential tariffs on imports of processed critical minerals and derivative products | Pending: Section 232 Investigation |
| Global | Semiconductors – potential tariffs on imports of semiconductors, SME, and derivative products | Pending: Section 232 Investigation |
| Global | Pharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products | Pending: Section 232 Investigation |
| 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.
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