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Our Take

| 8 minute read

Trump Tariff Tracker – March 20, 2026

On March 12, 2026, the United States Trade Representative (USTR) initiated Section 301 investigations into the forced labor import enforcement practices of 60 economies, including China, the European Union, Canada, Mexico, and India.  The investigations aim to determine if other countries' failure to effectively enforce prohibitions on importing forced-labor goods creates unfair cost advantages, burdening U.S. commerce.  They specifically scrutinize whether nations allow forced-labor goods, which would be denied entry into the U.S., to be sold in their own markets, thereby disadvantaging U.S. exports.  USTR has requested consultations with the governments of these economies in connection with these investigations. USTR will hold hearings for these investigations on April 28, 2026. Interested persons may submit written comments, and/or request to appear at the hearing, along with a summary of their testimony, by April 15, 2026. 

CBP continues to make progress in developing its new system, called Consolidated Administration and Processing of Entries (CAPE), for processing refunds of the IEEPA based tariffs. In an updated status report provided to the Court of International Trade (CIT) on March 19, 2026, Brandon Lord, Executive Director, Trade Programs Directorate, Office of Trade for CBP informed the court that CBP was 45% to 80% complete in developing the four components of the CAPE system.  As detailed in its reports to the CIT, CBP’s CAPE system for processing IEEPA refunds will consist of four components:

  1. Claim Portal – the public-facing gateway through which importers and their customs brokers will submit IEEPA refund requests as a “CAPE Declaration.”  CAPE Declarations will be validated for file integrity and to confirm the reported entries exist in CBP records.
  2. Mass Processing – the system will automatically remove the applicable IEEPA-tariff Harmonized Tariff Schedule numbers from each validated entry summary and rerun CBP’s standard duty calculation process to recalculate what duties would have been owed without the IEEPA-tariffs.
  3. Liquidation/Re-liquidation – liquidation or reliquidation of the processed entries will be scheduled, with a window of time built-in for CBP to conduct a manual review if warranted before finalization.
  4. Refund – at the scheduled liquidation or reliquidation date, entries will be routed into a CAPE-specific refund process within CBP’s Automated Commercial Environment.  Refunds will be disbursed electronically to the designated bank account.

According to its latest report to the CIT, CBP has started testing the components of the CAPE program, with the Liquidation component being the most complete segment, at 80 percent complete, and the Mass Processing component being the least complete, at 45 percent complete.

On March 18, U.S. Trade Representative Greer and Mexican Secretary of Economy Ebrard met to begin bilateral technical discussions in advance of the USMCA Joint Review on July 1, 2026.  Each country’s technical teams were instructed to review specific options for increasing U.S. and Mexican production and manufacturing employment, while closing gaps in key North American supply chains, including through increased cooperation on economic security, rules of origin, and complementary trade actions. 

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 March 20, 2026:

       U.S. Tariff MeasureStatus
Global 

10% ad valorem duty on imports into the U.S. pursuant to Sec. 122 of the Trade Act of 1974 

 

Imports of certain specified items excluded 

 

Imports of USMCA-qualifying products of Canada and Mexico excluded

Implemented: 2/20/2026 

Proclamation Imposing Sec. 122 Tariffs

GlobalSemiconductors – 25% ad valorem duty on imports of specified semiconductors and derivative products

Implemented: 1/14/2026 

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: 1/14/2026 

Executive Order

DOC Initiation and Request for Public Comments

Proclamation on Section 232 Action

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

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

60 Countries (see FR Notice)

Section 301: Acts, Policies, and Practices Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor

Pending:  Section 301 Investigation

USTR Fed. Reg. Notice

Bangladesh

Cambodia

China

EU

India 

Indonesia

Japan

Malaysia

Mexico

Norway 

Singapore

South Korea

Switzerland

Taiwan

Thailand

Vietnam 

Section 301: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors

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

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

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments 

Global 

[Canada & Mexico Exempt]

Reciprocal tariffs – 10% ad valorem duty

Country specific duty rates of 15% to 50% ad valorem

Certain goods excluded

 

 

STRUCK DOWN: 2/20/2026

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 

Executive Order Modifying Tariffs on India

Executive Order Ending Tariffs

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 

STRUCK DOWN: 2/20/2026

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

Executive Order Ending Tariffs

 

Mexico25% ad valorem duty on all non-USMCA-qualifying products of Mexico 

STRUCK DOWN: 2/20/2026

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

Executive Order Ending Tariffs

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

STRUCK DOWN: 2/20/2026

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

Executive Order Ending Tariffs

GlobalAll goods imported from a country determined to be directly or indirectly purchasing, importing, or otherwise acquiring any goods or services from Iran, since February 7, 2026 – discretionary variable rate ad valorem duty may be imposed

STRUCK DOWN: 2/20/2026

Implemented: 2/6/2026 

Executive Order

Executive Order Ending Tariffs

 

GlobalAll goods imported from a country determined to have sold/provided oil to Cuba since January 30, 2026 – discretionary variable rate ad valorem duty may be imposed

STRUCK DOWN: 2/20/2026

Implemented: 1/29/2026 

Executive Order

Executive Order Ending Tariffs

 

GlobalAll goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed

STRUCK DOWN: 2/20/2026

Implemented 4/2/2025 

Executive Order 

Executive Order Ending Tariffs

 

CanadaAircraft – potential 50% ad valorem duty on imports from CanadaProposed: 1/29/2026, announced by President Trump on Truth Social

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, walked back on 1/21/2026
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

section 301 investigation, forced labor, ieepa tariff refunds, usmca, cbp, international trade