As the U.S. tariff landscape continues to shift following the Supreme Court striking down the IEEPA-based tariffs, U.S. trading partners are showing varying degrees of response to the still existing and proposed tariffs that are under investigation.

After significant debate, the EU Parliament has approved a set of provisions on the EU's trade deal with the U.S. that will implement major tariff cuts, while providing for the ability to suspend the agreement if President Trump raises tariffs or introduces new tariffs on EU products.  The trade deal is conditioned on the U.S. not increasing the rate of its global tariff regime to 15 percent for all EU products, as this would result in the total tariffs on certain EU products subject to MFN and other tariffs to be above the agreed upon 15 percent cap.  The approved provisions also notably allow for the expiration of reductions to EU tariffs on U.S. steel, aluminum and related products unless the U.S. also reduces its tariffs to a maximum 15 percent on certain EU products.  The agreement is now pending approval from all 27 member states of the EU.  No timeline for final approval has been announced. 

Taking a more aggressive response to U.S. tariffs than the Europeans, China has initiated two investigations into U.S. trade practices, indicating the country’s intent to respond to the newly initiated U.S. investigations into Chinese trade practices.  In a statement released on March 27, the Chinese Ministry of Commerce said that it was launching these investigations to protect the interests of affected Chinese industries and in “firm opposition” to the two Section 301 investigations initiated against multiple countries, including China.  The Chinese investigations will assess (i) U.S. trade barriers against green-energy product exports from China; and (ii) U.S. policies that prevent Chinese products from entering the U.S. and restrict exports of advanced technology to China.

On March 27, the Court of International Trade (CIT) issued an order to address IEEPA tariff refunds for finally liquidated entries.  This is in addition to earlier court orders addressing unliquidated and reliquidated entries.  This most recent order requires that "[a]ny liquidated entries for which liquidation is final shall be reliquidated without regard to the IEEPA duties."  However, the order remains suspended pending CBP development of a refund system.  In response to this recent order, CBP has filed a declaration with the court noting that it is still working on developing phase 1 of the Consolidated Administration and Processing of Entries (CAPE) system to address those entries that are “either unliquidated or for which the 90-day voluntary reliquidation period under 19 U.S.C. § 1501 has not expired.”  CBP noted that it will provide a process for refunds of finally liquidated entries but only “in a subsequent phase of development” of CAPE.

In a bi-partisan effort, US Senators Tammy Baldwin (D-Wis.) and Bernie Moreno (R-Ohio) have requested the Commerce Department launch a Section 232 investigation into heavy construction and agricultural equipment imports from Mexico.  In a letter sent to the Commerce Secretary on March 26, Senators Baldwin and Moreno argue that U.S. trade measures, including the USMCA, have rewarded U.S. heavy equipment manufactures for moving their production to Mexico, without suffering any meaningful tariff consequences when importing the finished equipment back into the U.S. duty free under the USMCA.  The senators specifically note that the Section 232 investigation should include imports of “agricultural implements, construction and mining equipment, forestry and logging equipment, heavy machinery, their respective parts, and their derivative products.”

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 April 1, 2026:

This list will be updated as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.