On April 2, President Donald Trump issued a series of executive orders (EOs) to impose reciprocal tariffs on select countries and revoke China’s eligibility for the de minimis exemption. The long-previewed actions fulfill a key campaign promise and build on the president’s efforts to reform U.S. trade policy to address trade imbalances and unfair trade practices.
The revocation of China’s eligibility for the de minimis trade privilege ends the previously imposed pause on the action, and the EO outlines a structure for the imposition of duties on impacted shipments from China.
Executive Order Imposing Reciprocal and Baseline Tariffs (Executive Order, Fact Sheet)
- Imposed Under IEEPA. The president invoked the International Emergency Economic Powers Act (IEEPA, 50 U.S. Code § 1701) to levy the reciprocal tariffs, citing “conditions reflected in large and persistent annual U.S. goods trade deficits.” IEEPA was also the mechanism used to impose the existing fentanyl- and immigration-based tariffs levied on Mexico, Canada and China in February.
- Initial 10% Tariff. Starting on April 5 at 12:01 a.m. EDT, the EO imposes a baseline across-the-board 10% tariff on all countries; as noted below, these are imposed on top of all existing duty rates with the exception of goods from Mexico and Canada.
- Country-Specific Tariff Rates. Starting on April 9 at 12:01 a.m. EDT, a country-specific reciprocal tariff regime will replace the baseline 10% tariffs for certain countries. The reciprocal tariffs regime effectively identifies a tariff charged to the United States by a specific country that includes “currency manipulation and trade barriers”; that rate is halved to determine the “discounted reciprocal tariff” that the United States will impose on the country on April 9. Country-specific rates are outlined in Annex I.
- After the EO’s release, the White House later confirmed that the reciprocal tariffs are based on the large trade deficits these countries run with the United States; trade analysts argue that the formula is simply the trade deficit with a specific country divided by the country’s exports to the United States. The Office of the U.S. Trade Representative (USTR) subsequently released a methodology for calculating reciprocal tariffs, indicating that “the tariff rates that would drive bilateral trade deficits to zero were computed.”
- Canada and Mexico are not subject to reciprocal tariffs. For both nations, the existing fentanyl-based tariffs —and United States-Mexico-Canada Agreement (USMCA)-based exemptions — continue to apply. The EO also includes a series of sector-specific exemptions outlined in Annex II, including for steel and aluminum, which are already subject to standalone tariffs imposed by the Trump administration.
- Layering Existing Tariffs. The reciprocal tariffs will be applied in addition to all existing duty rates on foreign imports. For example, a 20% tariff is in effect on all goods imported from China. Thus, the minimum duty rate applied to Chinese imports on April 9 will be 54%. Select Chinese goods are also subject to Section 301 tariffs, which will further increase duty rates.
- The secretary of commerce and USTR can recommend additional action if the tariffs are not considered effective in resolving the “emergency conditions,” and the tariffs can also be altered by the president via additional executive actions.
Initial Analysis
The list of countries facing reciprocal tariffs is much more expansive than anticipated, far exceeding the top 10 to 15 countries with which the United States has the largest trade deficit.
As indicated above, there are notable exemptions to the reciprocal tariffs. Canada and Mexico will not be subject to reciprocal tariffs but will remain subject to tariffs related to the influx of fentanyl importations. On March 6, President Trump signed an executive order temporarily exempting goods that satisfy USMCA rules of origin or that claim and qualify for USMCA preference, and that exemption also remains in effect.
As noted above, select products that are subject to or expected to face separate tariffs are also exempt from the reciprocal duty rate: steel, aluminum, automobiles and related parts, copper, pharmaceuticals, semiconductors and lumber.
President Trump’s latest actions mark a shift in global trade relations. The imposition of broad tariffs along with record-high duty rates increases the likelihood of retaliatory action. The reciprocal tariff EO notes that President Trump may modify the tariff rates based on targeted nations’ retaliatory actions. Several countries have already indicated that they plan to target U.S. services through such action, which could threaten a range of sectors.
Executive Order Revoking De Minimis Treatment for Chinese Goods (Executive Order, Fact Sheet)
- Previous Revocation. President Trump initially revoked China’s de minimis eligibility in a Feb. 1, 2025 executive order (EO) but later paused the revocation, citing the absence of “adequate systems.” The secretary of commerce has notified the president that “adequate systems are now in place to process and collect tariff revenue.”
- Effective Date. Chinese goods, excluding articles sent through the international postal network, valued up to $800 will no longer be able to enter the United States duty-free on May 2, 2025 at 12:01 a.m. EDT.
- Tariff Rates. A tariff amounting to 30% of the value of Chinese goods will be applied. At a minimum, a $25 import fee will be applied per postal item entered for consumption on or after 12:01 a.m. EDT on May 2, 2025. The fee will increase to $50 on or after 12:01 a.m. EDT on June 1, 2025.
- Layering Existing Tariffs. The tariffs will apply in addition to all existing duties on Chinese goods.
Initial Analysis
The revocation of China’s de minimis eligibility is a long-awaited action. There is bipartisan consensus that de minimis treatment is used to evade tariffs and export illicit goods to the United States. Unlike the reciprocal tariffs, which may evolve over the next several months, this EO is likely to remain in effect in the long term.
Outlook for Tariff Actions
Today’s executive actions do not mark the end of tariff announcements, and the duties outlined in the chart below may shift in response to negotiations between the United States and impacted companies over the coming days and weeks. On March 24, President Donald Trump issued an executive order (EO) to direct the secretary of state, in consultation with other agency heads, to impose a 25% tariff on all goods from countries that import Venezuelan oil “directly or indirectly.” The imposition of tariffs will be based on an investigation conducted by the secretary of commerce; however, the secretary of state is granted the authority to impose tariffs “in his discretion.” The tariffs will go into effect on or after April 2, leaving the door open for increased duties.
In addition, President Trump has indicated he will announce sector-specific tariffs intended to force manufacturers to shift production of targeted goods to the United States. These tariffs will target specific goods or industries, like pharmaceuticals and semiconductors, and are expected in the coming months. The sector-specific tariffs will likely be levied under Section 232 of the Trade Expansion Act of 1962 and either amend an existing tariff or direct a Commerce Department investigation.
Below outlines the tariffs charged by each country on U.S. goods and the reciprocal tariffs levied by the United States, as displayed by President Trump during his announcement:
