On April 2, 2025, President Trump announced long-awaited reciprocal tariffs on imports of foreign goods into the United States. This action follows the President’s recent announcement on March 26, 2025, of a 25% tariff on imports of automobiles and automobile parts.
President Trump implemented the reciprocal tariffs via Executive Order (the “E.O.”) and pursuant to the International Emergency Economic Powers Act (“IEEPA”), which grants the President the authority to implement economic measures in response to “an unusual and extraordinary threat” to U.S. national security. In his “Liberation Day” speech, President Trump emphasized that the new tariffs are a response to the threat presented by disparate trade relationships with foreign counterparties and will help to bolster U.S. domestic manufacturing.
The following points outline the new tariffs imposed pursuant to the Executive Order.
- Base Line Tariff: On April 5, 2025, a blanket 10% tariff will go into effect on all imports of foreign-made goods. The 10% blanket tariff will not be applied to countries listed in Annex I of the E.O. that are subject to the country-specific tariffs described below.
- Country Specific Tariffs: On April 9, 2025, increased, country-specific tariffs will go into effect on imports from countries listed in Annex I of the E.O. The country-specific tariffs range from 11% to 50% including, for example, a 34% tariff on Chinese imports, 20% on imports from the European Union, and 24% on Japanese imports.
- Tariff Exemptions: Goods listed in Annex II of the E.O. will be excluded from the scope of the reciprocal tariffs. These include (1) articles subject to 50 USC 1702(b); (2) steel/aluminum articles and autos/auto parts already subject to Section 232 tariffs; (3) copper, pharmaceuticals, semiconductors, and lumber articles; (4) all articles that may become subject to future Section 232 tariffs; (5) bullion; and (6) energy and other certain minerals that are not available in the United States.
- USMCA Goods: Goods qualifying for preferential tariff treatment under the United States-Mexico-Canada Agreement (“USMCA”) are also exempt from the reciprocal tariffs.
In addition to the reciprocal tariff announcement, on April 2nd, President Trump also issued a separate E.O. titled “Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports” (the “China E.O.”). The China E.O. announces the elimination of duty-free de minimis treatment for covered goods imported from China, effective May 2, 2025. Goods imported from China via means other than the “international postal network,” a term that has not yet been expressly defined, will be subject to all applicable duties despite whether they qualify for the de minimis exemption under 19 U.S.C. 1321(a)(2)(C). Goods that are eligible for the de minimis exemption and are sent via the international postal network will be subject to a duty rate of either 30% of their value or $25 per item (increasing to $50 after June 1, 2025) but will otherwise be exempt from other duties on Chinese goods (including the reciprocal tariffs).
