Multiple Trade Updates – Section 321, India, Brazil, South Korea and Copper
Please see the following important trade news that happened today, Wednesday, July 30.
Section 321
Effective August 29, imported goods sent through means other than the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties. Here is the Executive Order issued by the White House this afternoon.
India
The President announced that goods from India will be subject to a 25% tariff effective on August 1. The President said that India would face additional penalties for trading with Russia – but he didn’t elaborate on this, and no official documentation has been posted by the White House.
Brazil
The White House did post an executive order that officially imposes an additional 40% tariff (under IEEPA) on imports from Brazil. This will be in addition to the 10% IEEPA, bringing the overall tariff rate on items from Brazil to 50%. There are exceptions listed in an annex at the end of the order. The 40% will not be applied to goods that are subject to Section 232 duties. See the fact sheet for Brazil here.
Copper
A new 50% tariff will be imposed on imports of semi-finished copper products and intensive copper derivative products. This tariff is in addition to all other duties. The tariff is only imposed on the copper value and strict compliance is advised as there will be penalties. See the fact sheet for copper here.
South Korea
President Trump announced about 50 minutes ago on Truth Social that the U.S. and South Korea have reached a trade agreement. The White House has not posted official documentation.
If you have any questions, please contact our office at compliance@iab-sd.com.
Trade Deal Update - July 29, 2025
Please see the following summary by Accelerate Strategies.
It’s been a newsy few days on the trade front. Here is a rundown of what has happened since Friday afternoon:
- Trade Agreement with EU: The President announced a trade agreement with the European Union that would have the EU eliminate duties on U.S. exports while imports of EU products into the U.S. would be subject to a 15% tariff. Details of the agreement, which the Administration says also includes purchase agreements and other concessions made by the EU, have not been made public. The agreement with the EU follows agreements with the UK, Vietnam, Indonesia, Philippines and Japan, although negotiations with each of these countries is ongoing.
- China Negotiations: The U.S. and China are holding high-level trade talks in Stockholm this week.
- Jamieson Greer, the U.S. Trade Representative (USTR) downplayed the possibility of a major breakthrough in talks with China and Treasury Secretary Scott Bessent said the main goal of this week’s talks is to extend the current deadline beyond August 12, which is when tariffs on Chinese imports are currently scheduled to ramp up.
- Tariffs currently being imposed on Chinese imports include the 10% across the board IEEPA tariff and the 20% fentanyl tariffs + all other tariffs assessed on Chinese imports, including Section 301 tariffs, Section 232 tariffs, and Most Favored Nation tariffs. Tariffs on Chinese imports had been as high as 145% (IEEPA tariffs + fentanyl tariffs), not counting Section 301, Section 232 and MFN.
- Tariff Ramp-Up Day is Upon Us: Friday is August 1, which is the date tariffs are expected to increase. Below is a chart that summarizes the new tariff rates we expect to go into effect, based on the rates initially set on April 2, the rates that were announced in letters President Trump sent to select countries, or the rates that were negotiated between the Trump Administration and select countries.
- Possible Tariff Rebate Checks: On Friday afternoon, President Trump suggested the White House could use tariff revenue to send rebate checks to individuals. He made the comments to the press in response to a question from a reporter.
- Recall the President suggested several weeks ago that Americans might receive a rebate check using money that was saved by the Department of Government Efficiency (DOGE), but that plan never materialized.
- Tariffs on Russian Trading Partners: On Monday, President Trump reiterated his threat to impose secondary tariffs of 100% on countries that trade with Russia, saying the new deadline for countries to end their trade relationship with Russia would be in “10 to 12 days”, instead of 50 days as he announced earlier this month. Legislation is pending in the House and Senate that would impose a 500% tariff on any nation that purchases Russian oil, uranium or natural gas; however, Congressional leaders have said they will hold off on advancing the bill to give President Trump room to negotiate.
- Section 232 Tariffs: A senior U.S. official told reporters over the weekend that sector-based tariffs on semiconductors and pharmaceuticals could be imposed within three weeks. Seven other 232 investigations remain ongoing, and additional 232 investigations are expected in the coming weeks.
- IEEPA Litigation: Oral arguments are scheduled for this Thursday before the U.S. Court of Appeals for the Federal Circuit on V.O.S. Selections v. Trump. The two sides will argue the legality of Trump’s use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs by declaring trade deficits a national emergency. We fully expect this to go to the Supreme Court, regardless of what happens in the U.S. Court of Appeals.
- Section 321 / De Minimis: The U.S. Court of International Trade rejected a request to reinstate the de minimis exception for imports from China. The ban on the use of de minimis for packages from China and Hong Kong took effect on May 2. The judges signaled the court could not step into this dispute until the case brought by V.O.S. Selections is decided.
If you have any questions, please contact our office.
Trade Deals Update - July 24, 2025
(Update courtesy of Accelerate Strategies.)
As many of you have seen, and as we discussed on yesterday’s call, President Trump announced trade deals this week with Japan, Indonesia and Philippines. You can find the fact sheet for the Japan deal here and the fact sheet for the Indonesia deal here. We are waiting for additional details on the Philippines deal.
President Trump announced a deal with Vietnam earlier this month, but neither side has released any details. There is still confusion about this deal – while Vietnam thought they had agreed to an 11% tariff rate, President Trump announced a 20% tariff rate for items produced in Vietnam and a 40% tariff rate for items transshipped through Vietnam.
U.S. Trade Representative Jamieson Greer briefed Republicans on the Senate Finance Committee and the House Ways and Means Committees this week. While many Republican members had positive things to say about the meeting, it’s not clear what will happen between now and August 1, when tariffs are currently scheduled to ramp up for most countries.
We will keep you updated. If you have questions, please contact compliance@iab-sd.com.
Tariff Updates - July 14, 2025
Please see the following summary by Accelerate Strategies in D.C. from Saturday, July 12, regarding the current tariff situation.
President Trump posted two more letters on Truth Social today, addressed to Mexico and the European Union. In them, he threatened to impose 30% tariffs on each if they fail to reach acceptable trade agreements with the Administration. The letters also caution against retaliation, warning that the U.S. will respond with equivalent tariffs to match any retaliatory measures.
This brings the total number of countries receiving letters over the past week to 25.
Below my signature is a chart that shows where we stand with each country. The chart includes countries that did not receive a letter from President Trump this week, but are scheduled to face increased tariff rates on August 1, as initially announced on April 2 under the reciprocal tariff plan. Countries not listed in the chart are expected to remain subject to the existing 10% across-the-board tariff.
A few other things to note about the bi-lateral negotiations happening between the U.S. and other countries:
Anonymous White House officials have told the press the Administration plans to impose the additional Canada tariffs only on goods that do not comply with the USMCA, although they pointed out the ultimate details will be up to President Trump.
Presumably, the Mexico tariffs announced today would only apply to goods that are not eligible for USMCA preference.
Canada has imposed a 25% tariff on U.S. steel and aluminum and was threatening to increase the retaliatory tariff to 50%. Canada backed off that threat after receiving the letter from President Trump but could choose to ramp up tariffs on U.S. steel and aluminum on August 1.
China still faces an August 12 deadline to strike a deal with the United States and avoid additional tariffs.
There has been reporting on the Vietnam agreement that indicates that U.S. and VN negotiators were closing in on an 11% tariff rate before the President announced the agreement includes a 20% rate for goods produced in Vietnam.
This reporting matches things we are hearing in conversations we are having here in DC. We’re being told the two sides are still working to finalize the deal; however, it’s not clear at this point what the final tariff rate will be (or if tariff rates will differ across HTS lines).
Also note that we are still trying to get clarity on whether / to what extent the Administration is going to tie tariff rates to the level of China content in goods produced in Vietnam. We remain concerned the Administration is conflating “transshipment” with China content and that higher levels of China content above a threshold level could result in a higher tariff rate.
Several Section 232 investigations are still underway, which means we should expect additional sectoral tariffs to be announced in the coming months.
Finally, it is worth noting that President Trump also said this week that a 50% tariff on copper imports will go into effect on August 1. President Trump also said a 200% tariff on pharmaceuticals imported into the U.S. could be coming “very soon.”
Reference
Here are the tariff rates we currently expect to be in place on August 1 for any country that doesn’t reach an acceptable trade agreement with the Administration. Countries listed in red are those which have received letters from President Trump. Countries not listed in the chart are expected to remain subject to the existing 10% across-the-board tariff.
| COUNTRY | RATE |
| Algeria | 30% |
| Angola | 32% |
| Bangladesh | 35% |
| Bosnia & Herzegovina | 30% |
| Botswana | 38% |
| Brazil | 50% |
| Brunei | 25% |
| Cambodia | 36% |
| Cameroon | 12% |
| Canada | 35% |
| Chad | 13% |
| China | 34% |
| Côte d`Ivoire | 21% |
| Democratic Republic of the Congo | 11% |
| Equatorial Guinea | 13% |
| European Union | 30% |
| Falkland Islands | 42% |
| Fiji | 32% |
| Guyana | 38% |
| India | 27% |
| Indonesia | 32% |
| Iraq | 30% |
| Israel | 17% |
| Japan | 25% |
| Jordan | 20% |
| Kazakhstan | 25% |
| Laos | 40% |
| Lesotho | 50% |
| Libya | 30% |
| Liechtenstein | 37% |
| Madagascar | 47% |
| Malawi | 18% |
| Malaysia | 25% |
| Mauritius | 40% |
| Mexico | 30% |
| Moldova | 25% |
| Mozambique | 16% |
| Myanmar | 40% |
| Namibia | 21% |
| Nauru | 30% |
| Nicaragua | 19% |
| Nigeria | 14% |
| North Macedonia | 33% |
| Norway | 16% |
| Pakistan | 30% |
| Philippines | 20% |
| Serbia | 35% |
| South Africa | 30% |
| South Korea | 25% |
| Sri Lanka | 30% |
| Switzerland | 32% |
| Syria | 41% |
| Taiwan | 32% |
| Thailand | 36% |
| Tunisia | 25% |
| Vanuatu | 23% |
| Venezuela | 15% |
| Vietnam | 46% |
| Zambia | 17% |
| Zimbabwe | 18% |
If you have any questions, please contact us at compliance@iab-sd.com.
Reciprocal Tariffs Extended
Please see the following Executive Order regarding the time extension for Reciprocal Tariffs to be modified to August 1, 2025 instead of July 9, 2025.
If you have any questions, please contact our office.
United States and Vietnam Trade Deal
Please see the following message from Ted Murphy at Sidley Austin LLP.
As you have likely heard, President Trump announced on social media yesterday that the United States has agreed to a trade deal with Vietnam. According to the social media post, the terms of the deal are (1) Vietnamese-origin goods will be subject to a base line tariff of 20% upon import into the United States; (2) Vietnamese-origin goods considered to be “Transhipping” goods will be subject to a 40% U.S. tariff; (3) Vietnam will reduce its tariffs on U.S.-origin goods to 0%. While the text of the agreement has not been made public (and is likely still be negotiated, so it may not be available for some time), I wanted to provide a few thoughts based on what we (think we) know about the deal thus far.
First, the U.S. tariffs. While it is not clear what “Transshipping” will be defined to mean exactly, it is clear that it will mean Vietnamese-origin product with some amount of Chinese content (it may say “third country content”, but this provision is undoubtedly aimed at Chinese-origin content). In other words, this agreement creates a new rule of origin for the application of tariffs. Prior to this agreement, if you produced a good that was last substantially transformed in Vietnam under the U.S. customs rules, the good would be subject to the tariff applicable to products of Vietnam. If the good was not last substantially transformed in Vietnam, and the essence imparting component was Chinese origin, the good would be subject to the tariffs applicable to products of China. This agreement creates a new category — goods last substantially transformed in Vietnam under the traditional U.S. customs rules, but that contain a certain amount of Chinese content. This new category of goods will be subject to the 40% rate. This is a big change and could impact a significant percentage of product depending on where the threshold for Chinese content is set.
Second, will this new type of rule of origin apply to other countries that benefitted from the shift in production out of China based on the Section 301 China tariffs from President Trump’s first term? Thailand, Cambodia, Malaysia, Mexico?
Third, does the new base line tariff replace the current MFN/NTR rates of duty, or be in addition to the MFN/NTR rates? So, will the rates be 20% + the existing MFN/NTR rate, or just 20% (for Vietnamese origin goods that do not meet the “transshipping” threshold)?
Finally, what is the President’s legal authority for entering into a trade agreement of this type? A trade agreement that imposes tariffs and adopts a new rule of origin would seem to require Congressional approval. If the Administration seeks to rely on delegated authority under the International Emergency Economic Powers Act (which was the cited legal basis for imposing the reciprocal tariffs in the first place), this issue will certainly be litigated.
The Vietnam deal is the first of a series of (framework) agreements we expect the Administration to announce in the coming week. What has been disclosed thus far raises some important questions that go well beyond just trade with Vietnam.
If you have any questions, please contact our office.