Trump Tariffs 2.0: The Tariff Tracker

As President-elect Trump continues to shape his economic plan with significant tariff policies, it’s crucial for businesses to stay informed about the potential risks and opportunities his announcements may bring.

We anticipate that any official tariff announcements made on January 20 and within the first 100 days via Executive Order (EO) or otherwise will merely mark the administration’s initial trade policy, which will evolve over the next four years.

In this rapidly changing trade environment, we understand the importance of staying ahead. The ArentFox Schiff Customs Team is closely tracking the tariff announcements and their implications. To ensure companies remain informed, we have created this tariff tracker that will be updated and published as new developments arise as of, and after, January 20, 2025.

TT - Targeted Tariffs of various duty ranges on specific products, industries or countries. Contact us for additional details.
TBD - To Be Determined if a tariff increase will be implemented by administration.

Tariff Mitigation

The tariffs have introduced a great deal of uncertainty for many companies. Companies will need a multifaceted approach to mitigating the impact of tariff increases and be prepared to pivot quickly. The ArentFox Schiff Customs team has extensive experience in advising and representing companies in these matters. We have developed a wide array of bespoke tariff mitigation strategies that can help companies navigate this uncertain trade environment.

UPDATES

1/22/25:

The Trump administration continues to announce possible additional tariffs that will be applied to specific country targets. For example, on January 22, Trump raised possible tariff increases on Russia in connection with the war in Ukraine. On January 21, he also announced possible increases of 10% on China and 25% on Mexico and Canada as early as February 1. To date, no official action to implement tariff increases has taken place.

1/20/25:

Additional tariffs have yet to be imposed, but an America First Trade Policy executive order (EO) was issued on President Trump’s first day in office, outlining various administrative agency investigations and potential reorganizations as summarized further below. Many of the investigatory reports are due in April 2025, however, other sources indicate that additional tariffs may be announced as early as February 2025 in relation to these policy developments.

1. Investigation of Trade Deficits: The Administration is investigating the causes of persistent trade deficits, with potential measures such as global tariffs being considered.
2. Establishment of an ERS: The feasibility of creating an External Revenue Service (ERS) to manage tariffs and trade-related revenues is being explored, potentially impacting how duties are collected.
3. Review of Unfair Trade Practices: The US Trade Representative (USTR) is tasked with identifying unfair trade practices and recommending actions, which may include tariffs.
4. USMCA Review and Public Consultation: A public consultation process will begin for the 2026 review of the United States–Mexico–Canada Agreement (USMCA), assessing its impact on American stakeholders and considering the United States’ continued participation.
5. Currency Manipulation: Measures against currency manipulation are under review, potentially impacting international trade dynamics.
6. Trade Agreements: USTR shall review existing trade agreements to recommend revisions to achieve or maintain appropriate level of reciprocal and mutually advantageous concessions, as well as identify countries for negotiation of new agreements.
7. AD/CVD Review: Policies regarding Antidumping and Countervailing Duties (AD/CVD) laws are being reviewed to ensure compliance and address transnational subsidies.
8. De Minimis Exemption Review: The impact of the $800 duty-free de minimis exemption on tariff revenues and public health will be assessed, with potential modifications to protect US interests.
9. Section 301 Tariffs on China: USTR shall assess the Section 301 Four-Year Review Report from May 14, 2024, and recommend actions necessary to remediate any issues.
10. Additional China Focused Reviews: The memorandum outlines other initiatives to review with respect to China, including the trade relations under the Economic and Trade Agreement between the United States and China (indicating a potential of tariffs or other measures as needed), legislative proposals regarding Permanent Normal Trade Relations with the People’s Republic of China (PRC), the status of US intellectual property rights conferred upon PRC persons is being assessed to ensure reciprocal and balanced treatment.
11. Section 232 Tariffs on Aluminum and Steel: Review of the effectiveness of the exclusions, exemptions, and other import adjustments on steel and aluminum as imposed under the Section 232 tariffs.
12. Unlawful Migration and Fentanyl Flows: Commerce and DHS to assess unlawful migration and fentanyl flows from Canada, Mexico, the PRC, and other relevant jurisdictions to recommend appropriate measures to resolve such emergency issues.
13. Additional Reviews: Examining extraterritorial taxes, World Trade Organization, and Federal Procurement agreements in connection to Buy America, export control authorities and national security, and recent rule from BIS covering the Information and Communication Technology and Services on Connected Vehicles.

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