Tariffs 2025 Summary
Please see the following summary of the 2025 tariff activity:
If you have any questions, please contact us at compliance@iab-sd.com.
Framework for US-EU Trade Relationship
The US and EU have agreed on a framework for the trade agreement announced on July 27, 2025. The joint statement can be found here.
The key terms to the agreement are:
- The EU intends to eliminate tariffs on all US “industrial goods” and will provide “preferential market access” to a range of US seafood and agricultural products.
- For purposes of the normal (MFN/NTR) tariff rate and the IEEPA/Reciprocal rate, the US will apply a tariff of 15% on EU Originating goods. If the MFN/NTR rate is higher than 15% the IEEPA/Reciprocal rate will be 0% and the new rate is capped at 15%. If the MFN/NTR rate is lower than 15%, then the MFN rate plus the IEEPA/Reciprocal rate will max out at 15%.
- On September 1, 2025, the US will only apply the MFN/NTR rate (no IEEPA or Reciprocal) to the following EU Originating goods: unavailable natural resources including cork, all aircraft and aircraft parts, generic pharmaceuticals and their ingredients and chemical precursors.
- The US will ensure that the MFN/NTR rate plus any Section 232 tariffs on pharmaceuticals, semiconductors and lumber does not exceed 15%. The US will also reduce the tariffs applicable to automobiles and auto parts once the EU announces legislation for number 1.
- The US and EU agree to negotiate “the rules of origin that ensure that the benefits of the Agreement on Reciprocal Trade accrue predominantly to the United States on the European Union.”
Please contact us at compliance@iab-sd.com if you have any questions.
Trade News Updates - August 20, 2025
Please see the following message from Ted Murphy of Sidley Austin LLP regarding the newest round of steel and aluminum tariffs.
This past Friday at 4:15 pm, the Department of Commerce filed with the Office of the Federal Register a notice extending the Section 232 steel and aluminum tariffs to hundreds of additional tariff classifications. The notice (which was published in the Federal Register today) imposed the additional 50% tariff on the steel and aluminum content in these articles effective Monday (so, yes, the notice was made available Friday afternoon, imposed significant additional tariffs effective Monday, but was not actually published until Tuesday).
Specifically, the notice adds 407 tariff subheadings to the list of articles considered to be steel and/or aluminum derivative articles and, therefore, subject to the 50% Section 232 tariffs on the steel and aluminum content.
We have attached the two CSMS messages, one each for steel derivatives and aluminum derivatives, that identify the new subheadings subject to these tariffs:
- CSMS # 65936570 - Section 232 Additional Steel Derivative Tariff Inclusion Products
- CSMS # 65936615 - Section 232 Additional Aluminum Derivative Tariff Inclusion Products
These additions result from Commerce’s Section 232 inclusion process for steel and aluminum derivative articles. The Section 232 inclusions process allows interested parties to request that additional articles be added to the list of derivative articles subject to the Section 232 steel and aluminum tariffs. Requests to include additional articles may be submitted three defined periods each year. It is clear that Commerce does not feel compelled to provide the public with any advance notice before subjecting additional articles to these meaningful tariffs, so companies should be following the inclusion process closely.
It is also clear that, the inclusion process is going to be used extensively, not only by domestic steel and aluminum producers, but also by domestic producers of articles that contain steel and aluminum (i.e., derivative articles). When President Trump increased the tariffs on steel and aluminum to 50%, we suggested that this would lead to additional tariffs being imposed on many more derivative products. Imagine you are a U.S. manufacturer of a finished product that contains steel or aluminum. As a result of these tariffs, you source your steel or aluminum domestically – and most likely at higher prices. This means that the cost of your finished product will go up due to the increased material costs.
Your non-U.S. competitors, however, do not utilize U.S. steel or aluminum. If the non-U.S. competitors’ products are not currently on the list of derivative articles subject to the Section 232 tariffs, the U.S. manufacturer is now at a significant competitive disadvantage. In order to protect itself, the U.S. manufacturer needs to request that the finished products be added to the list of derivative articles subject to the Section 232 steel and aluminum tariffs. This is likely at least part of what is happening here.
Many companies were blindsided by this action. Unfortunately, there is no “on the water” exemption or exclusion process for these tariffs.
If you have any questions, please contact our office.
URGENT NOTICE: New 50% Tariffs on 407 Products & Mandatory Reporting Rules
Dear Valued Client,
This is an urgent notice regarding a major U.S. trade action. The U.S. government has announced a significant expansion of the Section 232 tariffs to include 407 new HTS (Harmonized Tariff Schedule) codes. The complete HTSUS lists for both steel and aluminum derivative products are attached to this email for your review:
These new tariffs are effective today, Monday, August 18, 2025. There is no grace period for goods already in transit. All cargo containing these goods and entered for consumption on or after this date will be subject to these new duties.
What You Need to Know
- Tariff Rate: The additional duty rates are now officially confirmed:
- For most countries, the rate is 50% on the value of the steel or aluminum content.
- For goods from the United Kingdom, the rate is 25%.
- A punitive 200% tariff applies to the entire value of any goods containing aluminum that is a product of Russia, or where the aluminum was smelted or cast in Russia.
- Tariff Calculation: Except for products with Russian aluminum, the tariff applies only to the value of the steel and/or aluminum content within an imported product. The value of the non-metal portion of the goods will be subject to its normal duty rate.
- Affected Products: The list of affected goods is broad and includes many items not typically considered steel or aluminum derivatives, such as certain dairy products, food preparations, articles of plastic, perfumery, chemicals, articles of stone, mechanical and electrical parts, Etc., etc.
IMMEDIATE ACTION REQUIRED: New Invoicing & Reporting Rules
To comply with this mandate and avoid customs clearance delays, you must immediately instruct your suppliers to update their commercial invoices and provide new data for all affected products.
1. Mandatory Invoice & Data Requirements
The following information is now required for U.S. Customs entry filing:
- Value Breakdown: The commercial invoice must clearly separate the product's value into three components:
- Value of the base product (non-steel and non-aluminum content).
- Separate value of any steel content.
- Separate value of any aluminum content.
- Origin Declarations: The invoice must include statements declaring the country of origin for the metals:
- For steel, a declaration stating where the primary steel was "melted and poured."
- For aluminum, a declaration stating where the primary/secondary aluminum was smelted and most recently cast.
- CRITICAL - Country of Smelt/Cast for Aluminum: You must report the specific country of smelt and cast for all aluminum products. If this information is unknown and reported as 'UN', CBP will automatically assess the 200% Section 232 duties for Russia on the entry.
2. Recommended Best Practices to Ensure Compliance
To support the mandatory requirements above, we strongly recommend you take the following steps:
- Use Bills of Materials (BOMs): A product's BOM is the best source for obtaining the required value breakdown.
- Obtain Mill & Foundry Certificates: Request and retain copies of mill certificates for steel and/or foundry certificates for aluminum to verify the "melted and poured" and "smelted and cast" origin declarations.
- Verify Your Data: Double-check the values listed in your BOMs to ensure they are accurate and consistent with your commercial invoices.
- Keep Costs Current: Update your cost data regularly to reflect current material sourcing and pricing. This ensures compliance and helps minimize duty exposure.
We understand these sudden and complex changes create significant operational challenges. Please review your product lines immediately and ensure your supply chain partners are prepared to meet these new requirements.
For your reference, we have attached the lists of all HTSUS numbers affected by these changes and the Federal Register Notice:
To read the Spanish version of this notice, see the following attachment:
Our team is ready to assist you. Please contact us at compliance@iab-sd.com.
Trade News Updates - August 18, 2025
Please see the important message from Ted Murphy of Sidley Austin LLP.
As you know, the litigation challenging the additional tariffs the Trump administration has imposed under the International Emergency Economic Powers Act (IEEPA) (i.e., the fentanyl tariffs imposed on China, Canada and Mexico; and the “reciprocal” tariffs imposed on just about everyone) continues to move through the courts. The first case (V.O.S. Selections, et al. v. Trump, et al.) is currently pending at the U.S. Court of Appeals at the Federal Circuit. Other cases are pending at the U.S. Court of Appeals for the D.C. Circuit and in other district courts.
I previously brought to your attention the letter the Department of Justice sent the Federal Circuit arguing that the IEEPA tariffs should not be struck down because of all the good the tariffs have done/will do for the country (a remarkable ‘the ends justify the means’ argument for DOJ) and all the harm that will befall the country if the tariffs are struck down (e.g., a 1929-type depression). Copy attached. Given that letter, we are recommending that all clients take steps now to ensure that they have in their possession the information necessary to substantiate the tariffs paid to date. More specifically, we recommend that clients download the appropriate import report from the Automated Commercial Environment (ACE) to demonstrate the amount of IEEPA tariffs paid since they went into effect earlier this year.
If the IEEPA tariffs are ultimately struck down, the government may be ordered to refund the tariffs directly to the importers. It is also possible, however, that the court allows the government to require that importers affirmatively file for refunds. In this latter case, the government may try to require importers to identify the amount of the refund owed. While this information is currently available in ACE, we should not assume that will always be the case. As a precaution, we recommend that clients download the relevant ACE report now and every month hereafter until there is a final decision in the litigation. Better to be safe than sorry.
If you have any questions, please contact our office.
Trade News Updates
Please see the following message from Ted Murphy of Sidley Austin LLP.
It has been a crazy couple of weeks on the trade front, right? Since the trade deal with the EU was announced a little over two weeks ago, the Trump administration has:
- imposed a 50% tariff on imports of certain copper products under Section 232;
- imposed an additional 40% tariff on goods of Brazil under the International Emergency Economic Powers Act (IEEPA) (the administration also initiated a Section 301 investigation targeting Brazil)
- suspended de minimis for all countries;
- increased the rate of additional tariffs applicable to goods of Canada that do
- not qualify under USMCA from 25% to 35%;
- extended a decision on additional tariffs applicable to goods of Mexico for 90 days; and
- imposed new country-specific reciprocal tariffs ranging from 10-40% depending on the country.
During this time, President Trump has also teased massive tariffs on imported pharmaceuticals and on imported semiconductors based on the respective Section 232 investigations. There have also been some clarifications around the trade deals (frameworks) agreed to with the EU and with Japan (but the specific terms of these deals have still not yet been made public).
While this is (more than) enough, I wanted to highlight two other important developments for you.
The first is the decision by the United States and by China to further extend the trade truce the two sides announced back in May. As you may recall, the United States and China had each imposed additional tariffs of 125% on products of the other, China had restricted the export of critical minerals, etc. After a series of meetings, the tariffs on both sides were reduced from 125% to 10% for 90 days. This 90-day period was set to expire today, August 12, 2025, and the higher tariffs snap back into place. The two sides announced yesterday, that a further 90-day extension had been agreed to while they continue talking. Based on this, the higher tariffs will now snap back on November 10, 2025, unless further action is taken. See here.
The second relates to the on-going litigation challenging the validity of the additional tariffs imposed under IEEPA (i.e., the fentanyl tariffs imposed on Canada, Mexico and China; and the reciprocal tariffs imposed on everyone). As you will recall, a number of companies and several states have sued the Trump administration over the IEEPA tariffs. Thus far, two different federal courts have struck down the tariffs, but each decision has been stayed pending appeal. One of those appeals (V.O.S. Selections, et al. v. Trump, et al.) was recently heard by the entire Court of Appeals for the Federal Circuit. Yesterday, the Solicitor General sent to the Court the attached letter with the heading “Pertinent and Significant Authority Arising Since Our Briefs Were Filed”. The letter is worth a read. While it does not cite any new legal authority for the IEEPA tariffs, it does make several noteworthy claims about the tariffs, the government’s ability to repay tariffs collected to date if ultimately determined to be illegal, and the country itself. The letter is quite remarkable. The Court is widely expected to issue its decision this fall.
If you have any questions, please contact our office.
Executive Order Signed Delaying Additional China Tariffs
President Trump has signed an executive order delaying additional tariffs on Chinese imports for another 90 days. The following are the official publications:
The new deadline for the U.S. to reach a deal with China is 12:01am EDT on November 10.
Current tariffs on China include:
- 10% across the board IEEPA tariff
- 20% IEEPA fentanyl tariffs
- All other tariffs assessed on Chinese imports, including Section 301 tariffs, Section 232 tariffs, and Most Favored Nation tariffs
If you have any questions, please contact our office.
Copper Tariff Instructions
Please see this guidance on copper tariffs in Spanish. The following is a message from CBP.
CSMS # 65794272 - GUIDANCE: Section 232 Import Duties on Copper and Copper Derivative Products
The purpose of this message is to provide guidance on applying the 50 percent Section 232 ad valorem duty on all imports of semi-finished copper products and intensive copper derivative products imposed by the Proclamation issued on July 30, 2025.
BACKGROUND
On July 30, 2025, the President issued a Proclamation on Adjusting Imports of Copper into the United States, under Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862), imposing an ad valorem tariff of 50 percent on all imports of semi-finished copper products and intensive copper derivative products, from all countries.
ENTRY FILING INSTRUCTIONS
This guidance provides instructions for importers, brokers, and filers on submitting entries to U.S. Customs and Border Protection (CBP) of semi-finished copper products and intensive copper derivative products, from all countries, as provided for in headings 9903.78.01 and 9903.78.02 of the Harmonized Tariff Schedule of the United States (HTSUS), entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 1, 2025.
Heading 9903.78.01:
50 percent additional ad valorem rate of duty on the copper content of semi-finished copper and intensive copper derivative products
Heading 9903.78.02:
0 percent additional ad valorem rate of duty on:
the non-copper content of semi-finished copper and intensive copper derivative products; and
imported goods under the subject HTSUS classifications which contain no copper.
Reporting Instructions for Applying Duties Based on Copper Content (HTSUS 9903.78.01)
The 50 percent duty is to be reported based upon the value of the copper content. The value of the copper content should be determined in accordance with the principles of the Customs Valuation Agreement, as implemented in 19 U.S.C. 1401a. The value of the copper content is the total price paid or payable for that content, which is:
- the total payment made/to be made for the copper content by the buyer to, or for the benefit of, the seller of the copper content.
- Normally, this would be based on the invoice paid by the buyer of the copper content to, or for the benefit of the seller of the copper content.
For imported articles composed only of copper, the dutiable value of the copper content is the total entered value, and the duty must be reported under the HTSUS 9903.78.01 classification based on the total entered value, on only one entry summary line.
If the value of the copper content cannot be determined, then report the duty based on the total entered value, on only one entry summary line.
For articles not composed only of copper, the value of the copper content and the value of the non-copper content should be reported on two entry summary lines. The first line should represent the non-copper content, and the second line should represent the copper content. Each line should be reported in accordance with the instructions below.
Non-copper content, first line:
- Ch. 1-97 HTSUS, this same HTSUS must be reported on both lines.
- The same country of origin must be reported on both lines.
- Total entered value of the article less the value of copper content.
- Report the total quantity of the imported goods.
- Report the 0 percent Section 232 duties based on the value of the non-copper content with HTSUS 9903.78.02.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
Copper content, second line:
- Same Ch. 1-97 HTSUS reported on the first line.
- Same country of origin reported on the first line
- Report 0 quantity for the Ch. 1-97 HTSUS.
- Report the value of the copper content.
- Report the Section 232 duties based on the value of copper content with HTSUS 9903.78.01.
- Report a second quantity (of the copper content) in kilograms with the HTSUS 9903.78.01.
- Report all other applicable duties, such as IEEPA tariffs and antidumping and countervailing duties.
For all Section 232 duties based on copper content which are based on a value other than the entire value of the good, importers must keep documentation to support the reported values and provide to CBP upon request. Examples of such documentation include, but are not limited to, the bill of materials for the production of the goods, invoices for the materials used in the production of the goods, and accounting documentation to substantiate the reported values.
When insufficient documentation is provided to substantiate the reported values, CBP will collect the duties on the copper content based on the entire value of the good.
Importers who submit underreported declarations may be subject to severe consequences, such as significant monetary penalties, loss of import privileges, and criminal liability, consistent with United States law.
Duties Applying to the Non-Copper Content
Per the July 30, 2025 Proclamation, the non-copper content of all subject copper articles shall be subject to any other import duties in effect, including import duties established by Presidential Proclamations, except as specified below.
Exemption for Goods Subject to Section 232 Duties on Auto Parts
If an imported good is subject to both the Section 232 duties on automobiles and automobile parts under Proclamation 10908, as amended, and the Section 232 duties on copper and copper derivative products, then the Section 232 duties on copper and copper derivative products are not applicable.
IEEPA Reciprocal Tariff Exception
International Emergency Economic Powers Act (IEEPA) Reciprocal tariff exception 9903.01.33 applies to goods subject to Section 232 tariffs including semi-finished copper and intensive copper derivative products provided for in 9903.78.01.
DRAWBACK
No drawback shall be available with respect to the duties imposed pursuant to the July 30, 2025 Proclamation.
FOREIGN TRADE ZONE
Any product, except those eligible for admission under "domestic status" as defined in 19 CFR 146.43, that is subject to the duty imposed by the July 30, 2025 Proclamation and that is admitted into a U.S. foreign trade zone on or after the effective date of August 1, 2025, must be admitted as "privileged foreign status" as defined in 19 CFR 146.41, and will be subject upon entry for consumption to any ad valorem rates of duty related to the classification under the applicable HTSUS subheading.
Questions from the importing community concerning ACE entry rejections involving copper goods and their derivative filings should be referred to their CBP Client Representative.
For reference, a summary of Copper Chapter 99 HTSUS classification list is attached.
For questions regarding our trade Remedy programs, please visit our cbp.gov webpage at https://www.cbp.gov/trade/programs-administration/trade-remedies or contact the Trade Remedy Branch at TradeRemedy@cbp.dhs.gov.
If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
If you have any questions, please contact our office.
New IEEPA Tariff Rates - Canada, Mexico and China
Please see the following message from Accelerate Strategies.
President Trump issued an Executive Order last night, July 31, announcing new IEEPA tariff rates that will go into effect on August 7. Goods that leave port within seven days of tomorrow and arrive in the U.S., clearing Customs and Border Protection (CBP) by October 5, 2025, will be exempt from the new tariff rates.
The tariffs announced tonight are in addition to existing (Column 1) tariffs, with the only exception being the EU – see below.
Additional Information
- For countries that have established framework trade agreements with the Administration (including the UK, Vietnam, Indonesia, Philippines, Japan, and South Korea), the applicable tariff rate will be the one announced by the President.
- Exports from the European Union will be subject to the higher of either 15% or the Column 1 rate. If the Column 1 rate is below 15%, an IEEPA tariff will be applied equal to the difference between 15% and the Column 1 rate. If the Column 1 rate exceeds 15%, only the Column 1 rate will apply, with no additional IEEPA tariff.
- The updated tariff rates for all countries are listed in the Executive Order. Any country not specifically listed will be subject to the 10% across the board IEEPA tariff.
The Executive Order is silent on Canada and Mexico and explicitly states that the latest executive order pertaining to China is still in effect.
- CANADA: The White House issued an Executive Order last night (July 31) and CBP issued a new CSMS message pertaining to Canada at 10:20pm EDT – text of the CSMS is below my signature.
- MEXICO: Yesterday, President Trump announced a 90-day extension of his tariff deadline for Mexico to allow more time for negotiations on a longer-term trade agreement, which we believe will be focused on IEEPA tariffs. Note that Commerce Secretary Howard Lutnick said earlier this month that the Trump administration does not view the current negotiations with Mexico as a substitute for the Year Six review of the USMCA scheduled to take place in 2026. Presumably, that means the Administration is trying to keep IEEPA separate from USMCA, but whether that is practical remains to be seen.
- CHINA: The White House press secretary hinted that President Trump may not extend the August 12 deadline for China. 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.
Transshipment: Here is what the Executive Order says about transshipment: “An article determined by CBP to have been transshipped to evade applicable duties under section 2 of this order shall be subject to (i) an additional ad valorem rate of duty of 40 percent, in lieu of the additional ad valorem rate of duty applicable under section 2 of this order to goods of the country of origin, (ii) any other applicable or appropriate fine or penalty, including those assessed under 19 U.S.C. 1592, and (iii) any other United States duties, fees, taxes, exactions, or charges applicable to goods of the country of origin. CBP shall not allow, consistent with applicable law, for mitigation or remission of the penalties assessed on imports found to be transshipped to evade applicable duties.”
Looking at the newly announced rates compared to what we were expecting based on April 2 list or rates put in letters in early July:
- 30 countries will pay a lower rate than anticipated
- 24 countries will pay the anticipated rate
- 18 countries will pay a higher rate than anticipated
Reference
CSMS # 65798609 - Update - Additional Duties on Imports from Canada
The purpose of this message is to update guidance on the additional duties due on imports that are the products of Canada, pursuant to Executive Order 14193, “Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border” issued on February 1, 2025, as amended by:
- Executive Order 14197, “Progress on the Situation at our Northern Border” issued on February 3, 2025,
- Executive Order 14226, “Amendment to Duties to Address the Flow of Illicit Drugs Across Our Northern Border” issued on March 2, 2025,
- Executive Order 14231, “Amendment to Duties to Address the Flow of Illicit Drugs Across Our Northern Border” issued on March 6, 2025, and
- Executive Order, “Amendment to Duties to Address the Flow of Illicit Drugs Across Our Northern Border” issued on July 31, 2025.
- This CSMS updates CSMS 64336037 with the following information only.
GUIDANCE
For goods that are products of Canada, that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on August 1, 2025, the following HTSUS classifications and additional duty rates apply:
- 9903.01.10: All imports of articles that are products of Canada, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13, 9903.01.14 or 9903.01.15 and other than products for personal use included in accompanied baggage of persons arriving in the United States, will be assessed an additional ad valorem rate of duty of 35%.
- All articles that were subject to the additional ad valorem rate of duty of 25 percent under Executive Order 14193, as amended, shall instead be subject to an additional ad valorem rate of duty of 35 percent, effective 12:01a.m. eastern daylight time on August 1, 2025.
For goods that are determined by U.S. Customs and Border Protection (CBP) to have been transshipped to evade the additional ad valorem for products of Canada, CBP will direct the importer that such goods are subject to the following HTSUS classification and additional duty rate:
- 9903.01.16: Except for products described in 9903.01.11, 9903.01.12, and 9903.01.14, articles the product of Canada that are determined by CBP to have been transshipped to evade applicable duties, will be assessed an additional ad valorem rate of duty of 40%, in lieu of the rates that would otherwise be applicable under 9903.01.10, 9903.01.13 and 9903.01.15.
CBP will provide additional guidance to the trade community through CSMS messages as appropriate.
If you encounter any errors in filing an entry summary, contact your CBP client representative or the ACE Help Desk.
Questions regarding this message should be directed to Trade Remedy at traderemedy@cbp.dhs.gov.