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Our Take

| 7 minute read

Trump Tariff Tracker – January 19

While we await the Supreme Court’s decision in the IEEPA tariff cases, the Trump Administration continues to charge forward with new tariffs to address issues of national security and foreign policy.

President Trump has threatened that the U.S. will impose tariffs on eight European allies that are seen as working against his goal of obtaining Greenland for the U.S.  In a Truth Social post on Saturday, January 17, President Trump announced that effective February 1, 2026, duties of 10 percent will be imposed on imports from Denmark, Norway, Sweden, France, Germany, the United Kingdom, the Netherlands, and Finland.  The tariff will be increase to 25 percent on June 1, 2026. According to President Trump, these tariffs will remain in effect “until such time as a Deal is reached for the Complete and Total purchase of Greenland.”  No formal legal action has been taken to implement these announced tariffs.   

On January 14, President Trump issued a proclamation imposing tariffs on imports of certain semiconductors pursuant to the Commerce Department’s Section 232 investigation. Based on the Commerce Department’s finding that semiconductors, semiconductor manufacturing equipment, and their derivative products are being imported into the U.S. in such quantities as to threaten to impair the national security of the U.S., President Trump has imposed a 25 percent ad valorem duty on imports of certain advanced computing chips and certain derivative products described in the Annex to the proclamation.  These covered products include logic integrated circuits, or articles that contain a logic integrated circuit, which meet the technical parameters around total processing performance and DRAM bandwidth detailed in the Annex.  Exceptions to these duties are made for covered products used in data centers or by start-ups in the U.S., for repairs or replacements, for research and development in the U.S. involving these chips, and for use in civil industrial or public sector applications in the U.S.  Products covered by this proclamation will not be subject to other Section 232 tariffs or the IEEPA reciprocal tariffs.

Also on January 14, President Trump issued a proclamation to address national security concerns with imports of processed critical minerals and their derivative products (“PCMDPs”) as identified in the Commerce Department’s Section 232 investigation of PCMDPs.  Unlike other recent proclamations relating to Section 232 investigations, President Trump did not impose immediate tariffs on imports.  Rather, pursuant to Section 232, he directed the USTR and other officials to enter into negotiations with trading partners to adjust the imports of PCMDPs.  The President reserved the right to impose tariffs at a later date if the negotiations are not successful in addressing the national security impact of imports of PCMDPs.

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 January 19, 2026:

       U.S. Tariff MeasureStatus

Denmark

Finland

France

Germany

Netherlands

Norway

Sweden

U.K. 

10% ad valorem duty on imports from designated countries relating to Greenland, to be effective Feb. 1, 2026 with increase to 25% on June 1, 2026 Proposed: 1/17/2026, announced by President Trump on Truth Social
GlobalSemiconductors – 25% ad valorem duty on imports of specified semiconductors and derivative products

Implemented: 1/14/2025 

DOC Initiation and Request for Public Comments

Proclamation on Sec. 232 Duties

GlobalCritical  Minerals – trade negotiations directed regarding  imports of processed critical minerals and derivative products

Implemented: 1/14/2025 

Executive Order

DOC Initiation and Request for Public Comments

Proclamation on Section 232 Action

Global 25% ad valorem duty on imports from countries found to be trading with Iran Proposed: 1/12/2026, announced by President Trump on Truth Social
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)

USTR Fed Reg Notice

USTR Fed Reg Notice of Action

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

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

Executive Order Modifying Reciprocal Tariff Rates for China

Executive Order Modifying Reciprocal Tariff Rates on Certain Agriculture

Executive Order Modifying the Scope of Tariffs on Brazil 

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 

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) Suspended 11/10/2025

USTR Fed. Reg. Notice

USTR Fed. Reg. Notice of Proposed Suspension

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

Proclamation Delaying Duty Increase

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 Suspended 11/10/2025

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

USTR Fed. Reg. Notice of Proposed Suspension

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

China10% ad valorem duty on all products of China (reduced from original rate of 20%)

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

Executive Order Reducing Tariff Rate

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

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

semiconductor tariffs, critical minerals, greenland tariffs, ieepa tariffs, international trade