A Look Back and a Look Forward at Trump Tariff Policy

With the August 1 deadline looming for the imposition of sweeping tariffs on all countries, many global traders are preparing for “what comes next.” A major part of this planning includes a look back at all of the various duties paid under various statutes since the Trump administration took office in January 2025. Because any potential refund of duties always tracks the “entry date” of record with U.S. Customs & Border Protection (CBP), many importers are gearing up to file protests on entries which paid the reciprocal and fentanyl tariffs collected under the authority of the International Emergency Powers Act (IEEPA). Those actions have been ruled illegal by two federal courts and, although the cases are on appeal, importers still need to protect their rights to claim a refund through CBP’s administrative procedures, which precisely follow the date of entry, the date of liquidation (closing out of an entry and final assessment of duties), and the 180-day post-liquidation date which bars any protests after that deadline. 

The sheer number and unpredictability of the tariff announcements and adjustments—sometimes in the form of executive orders (EOs) and sometimes simply a post on President Trump’s media platform, Truth Social—accompanied by various Commerce Department investigations, judicial challenges, and now the impending August 1 deadline for new tariffs, have produced an uncertain environment for the business community. This alert provides an overview of the chronology of events since the Trump administration took office. 


Tariff and Action Timeline

When President Trump released his “America First Trade Policy” hours after being sworn in on January 20, 2025, he announced that tariffs of 25% would be levied on imports from Canada and Mexico beginning February 1. Six days later, after Columbia turned back U.S. planes carrying deported migrants, President Trump announced that a tariff of 25% would be levied on all U.S. imports of Columbian-originating goods, with a hike to 50% proposed for the following week. Columbia and the U.S. immediately reach a deal to rescind these proposed tariffs.

The promise to impose tariffs on Canadian and Mexico goods materialized on February 1, 2025, when President Trump issued three EOs declaring that the increased flow of illegal migrants and illicit fentanyl and precursor drugs from Canada, China, and Mexico constitute a national emergency under the IEEPA. He imposed new 25% ad valorem tariffs on imports of all goods imported from Canada and Mexico starting on February 4, with no exemption for goods qualifying as USMCA-originating. (USMCA is the free trade agreement between the U.S., Canada, and Mexico, which was negotiated during President Trump’s first term). These tariffs would apply in addition to any Normal Trade Relations or other trade remedy tariffs. The president also slapped a new 10% ad valorem tariff on China to be imposed from the same dates—these tariffs apply in addition to any other applicable tariffs, including the Section 301 “China tariffs” already in place at 100%, 50%, 25%, or 7.5%. (Section 301 tariffs are additional import taxes imposed on goods from countries the U.S. Trade Representative (USTR) deems to be unfairly restricting trade or engaging in unfair trade practices.) The EOs also stated that the tariffs will remain in effect until President Trump determines that the Canadian, Mexican, and Chinese governments have taken “sufficient action to alleviate the crisis.”

However, before the tariffs even went into effect, President Trump pulled back on the tariffs on Canada and Mexico for 30 days following promises of retaliatory actions in the form of tariff and non-tariff measures, mainly by Canada. The tariffs were reinstated on March 4, but on March 6 a new EO was issued exempting USMCA-originating goods and lowering the duty rate from 25% to 10% for non-originating imports of potash. The measures were not made retroactive, so many importers wound up paying the 25% duties on USMCA-originating goods that were imported into the U.S. between March 4-5. CBP later issued a notice instructing that it had no legal authority to refund those duties paid during the “gap” period. The exemption for USMCA- originating goods was extended indefinitely on April 2.

The tariffs on China went into effect on February 4 as planned, but China countered with a 15% tariff on coal and liquefied natural gas products and a 10% tariff on crude oil, agricultural machinery, and large-engine cars imported from the U.S., which took effect on February 10. China also announced export controls on several elements critical to the production of certain high-tech products. 

The next tranche of tariffs were announced on February 10 in two Presidential Proclamations imposing tariffs of 25% ad valorem that apply to all imports of steel and aluminum products from all countries starting March 12. The president used Section 232 of the Trade Expansion Act of 1962, as amended, as the legal basis for these tariffs. These tariffs applied not only to imports of raw materials (as the original Section 232 tariffs did in 2018 when President Trump imposed them during his first term in office) but also to derivative and downstream products, as determined by each item’s tariff code under the Harmonized Tariff Schedule of the United States (HTSUS). Section 232 allows the president to impose restrictions on certain imports if the Commerce Department determines that the restrictions are needed on national security grounds. The department has 270 days from the date an investigation is launched to finalize its report.)

Then on February 13, the White House issued a memorandum announcing a plan to levy “reciprocal” tariffs to address the large and persistent trade deficits the U.S. has with its major trading partners due to other countries’ tariffs and policies. The reciprocal tariffs will apply to imports from most U.S. trading partners, except for goods already subject to specific tariffs, e.g., steel, aluminum, autos/auto parts, etc. (also known as “sector-specific” tariffs). This was followed by another memorandum on February 21 directing the Departments of Commerce and Treasury and the Office of the U.S. Trade Representative (USTR) to propose retaliatory measures in the form of U.S. tariffs against merchandise imported from countries that discriminate against U.S. technology companies. The latter tariffs would also aim to remedy trade deficits (especially with the EU) and help dissuade foreign countries from collecting corporate income taxes from U.S. tech companies operating abroad. Targeted taxes include digital services taxes (DSTs) and VAT.

On February 14, President Trump announced plans to proceed with imposing tariffs of unspecified amounts on imports of foreign-made passenger vehicles starting April 2.

On February 25, the Commerce Department launched an investigation of copper to ascertain if imports of that material posed a threat to U.S. national security such that tariffs under Section 232 would be warranted. (The investigation was announced via an EO.)

On February 27, the president increased the tariffs on China by another 10% starting March 4, bringing the tariff rate to 20%.

On March 4, in response to the re-imposition of U.S. tariffs on goods of Canadian origin, Canada announced tariffs of 25% on C$155 billion worth of U.S.-originating goods (as determined by Canada’s harmonized tariff code for those products).

On March 5, President Trump exempted auto imports from the 25% tariffs on non-USMCA-originating goods from Canada and Mexico for one month until April 2. 

On March 6, President Trump released two EOs announcing that he was suspending many of the 25% tariffs on Canadian and Mexican imports, a mere two days after the tariffs went into effect. However, the suspension applied only to merchandise that qualified as “North American-originating” under USMCA. 

On March 10, China began imposing retaliatory tariffs on many goods from U.S. “farm states,” including imports of chicken and corn (subject to a tariff of 15% in addition to the normal duties applicable to the tariff codes of those products when imported into China) and soybeans and various fruits (subject to an additional 10% tariff). The Canadian province of Ontario also announced a 25% surcharge on electricity routed to Michigan, New York, and Minnesota, as well as imposing its own provincial tariffs on U.S. imports.

On March 11, the president threatened to double the 25% tariff rate on steel and aluminum to 50% because of Canada’s retaliation but he retracted the increase the same day. The Premier of Ontario also suspended the electricity surcharge.

On March 12, the EU and Canada announced billions more in U.S. goods that would be hit with new retaliatory tariffs. Canada proceeded with implementation of these tariffs, but the EU suspended any further action until April 1. Because the EU list of retaliatory tariffs included American bourbon, on March 13 President Trump threated counter retaliation with new tariffs of 200% to be applied to imports of champagne and all wines and liquors from the EU.

On March 26, in another EO, President Trump directed the Secretary of State to compile a list of countries that consume oil from Venezuela on which duties of 25% would be imposed on imports from those countries beginning “on or after” April 2. No list of countries has yet to be published. 

In a bigger announcement that same day, President Trump followed through on his threat to impose tariffs on imports of motor vehicles and light trucks, as well as parts for those vehicles, with a new 25% tariff under Section 232, the “national security” tariff. The tariff for vehicles was effective April 3 while the tariff for parts was delayed until May 3 to give the government time to create an orderly process for the thousands of parts and tariff codes to be covered by the new tariff.

On April 1, the Commerce Department launched investigations of imports of semiconductors, semiconductor manufacturing equipment and pharmaceuticals and pharmaceutical ingredients for potential assessment of national security tariffs under Section 232. The scope of the semiconductor investigation encompasses various elements critical to the industry, such as semiconductor substrates, bare wafers, legacy chips, leading-edge chips, microelectronics, etc.

On April 2 (coined “Liberation Day”) President Trump announced a 10% “baseline” reciprocal tariff on all imports and another set of reciprocal tariffs of up to 49% on 57 U.S. trading partners, which were to go into effect on April 5. Citing trade deficits and trade barriers with other countries that put the U.S. at a disadvantage as a “national emergency,” the new tariffs were issued under the authority of IEEPA. (The accompanying Fact Sheet released by the White House lists specific countries and industries that the Trump administration considered to be failing to provide the U.S. with reciprocal treatment.) A second EO issued on April 2 ended the duty-free de minimis exemption for imports of Chinese or Hong Kong-originating goods valued under US$ 800; as from May 2, all relevant postal items containing goods that are sent through the international postal network that would otherwise be eligible for the de minimis exemption will be subject to a U.S. Customs duty rate of 30% of their value or $25 per item (increased to $50 per item after June 1).

On April 4, China countered the combined 34% IEEPA tariffs imposed on its goods entering the U.S. with the same tariff rate on U.S.-origin goods entering China. A separate countermeasure was applied barring 11 U.S. companies from doing business in China. President Trump then threatened to add an additional 50% tariff, ramping up the total U.S. tariffs on Chinese-origin goods to 104%.

The country-specific IEEPA reciprocal tariffs took effect on April 9, including 20% on goods of EU origin, 24% on goods from Japan, 46% on Vietnamese goods, and 104% on goods of Chinese origin. China retaliated by raising its tariff rate on U.S.-originating goods from 34% to 84% and the EU finalized a list of U.S.-made goods to be hit with retaliatory tariffs the following week. The same day, President Trump announced a pause of 90 days on the country-specific IEEPA tariffs until July 9 so that affected countries could conclude trade deals with the U.S. to address the trade deficits and other barriers cited in the Presidential Proclamation imposing the IEEPA tariffs. The baseline reciprocal tariff of 10% was to remain in place. The EU then paused its plan to implement retaliatory tariffs on U.S. goods until July 14. 

China was excluded from the pause and the lower tariff rate; indeed, the same day President Trump announced a new rate of 125% in addition to the 20% IEEPA tariffs already imposed on goods from China in response to the fentanyl and migrant inflow national emergencies, bringing the total tariff rate to 145% on U.S. imports of Chinese-originating goods. Canada also retaliated on April 9 with a new tariff of 25% on U.S.-made non-USMCA-qualifying motor vehicles.

On April 11, President Trump issued a Presidential Memorandum exempting certain semiconductor components, smartphones, laptops, and other electronics (based on their tariff classification code under the HTSUS) from the 10% universal baseline reciprocal tariff retroactive to April 5. Specific instructions were issued to CBP to refund any IEEPA tariffs collected during the gap period. On the same day, CBP released a message via the Cargo Systems Messaging Service confirming the exemptions and providing guidance to importers about declaring the exemptions, as well as actions to take to correct filing entries and when requesting refunds. On April 13, the reprieve on these electronics products was clarified to be temporary given the ongoing Section 232 investigation of semiconductor chips, including merchandise incorporating chips.

On April 22, the Commerce Department announced two new investigations of merchandise deemed to threaten U.S. national security: trucks and processed critical minerals/derivative products. As with the other investigations, Commerce has 270 days from the date of the initiation of the investigation to deliver a final report to the president with tariff or non-tariff recommendations if a threat to national security is found. The department initiated another investigation on May 1, this one focusing on the potential impact of commercial aircraft, jet engines, and related parts imports on U.S. national security. Most expect these investigations to be completed well before the statutory deadline.

An EO issued on April 29 clarified the issue of “stacking,” i.e., which tariffs were cumulative with other tariffs and which were not, with respect to imports of motor vehicles and parts. For importers paying the 25% tariffs on these items, the EO clarified that the 25% tariff on imports of non-USMCA-qualifying goods from Canada and Mexico would not apply, nor would the 25% steel and aluminum IEEPA tariffs.

On May 8, the U.S. and the U.K. announced that the first “trade deal” during the IEEPA reciprocal tariff pause had been agreed to although final details had yet to be finalized, such as the all-important issue of steel imports into the U.K. While the U.S. agreed to roll back tariffs on imports of cars and steel, the 10% IEEPA reciprocal tariff for U.K. imports would remain in place. (such details were claimed to have been concluded on June 16.) The president issued another EO and a Fact Sheet shortly after the signing the agreement and the general terms of the pact were released

Further progress with respect to Chinese-originating goods was announced on May 12. The U.S. agreed to cut tariffs from 145% to 30% (consisting of the 20% IEEPA “fentanyl” tariffs and the 10% universal IEEPA reciprocal tariff). In turn, China lowered its tariffs on U.S. goods from 125% to 10%. The two trading partners set August 12 as the target date for final conclusion of any trade deal (although this deadline may be extended).

On May 23, President Trump expressed his frustration with the lack of progress on the EU trade negotiations by threatening to hit the EU with tariffs of 50%, which he tabled two days later after calls with EU leaders. He indicated no further action would be forthcoming until July 9 when the 90-day pause on the 57 country-specific IEEPA reciprocal tariffs was to end.

On May 28, a three-judge panel of the U.S. Court of International Trade (CIT) invalidated all of the IEEPA tariffs (including the “fentanyl” and “trade deficit” reciprocal tariffs). In V.O.S. Selections, Inc. v. United States, the CIT held that President Trump’s use of IEEPA to impose the fentanyl and reciprocal tariffs via EOs exceeded the authority granted to the president by Congress pursuant to the statute. The CIT issued a permanent injunction to block the administration from enforcing the IEEPA tariffs and gave the administration 10 days to issue the necessary orders to end the collection of the offending tariffs. This injunction was stayed by the U.S. Court of Appeals for the Federal Circuit, which is now considering the appeal on the merits (with oral arguments scheduled for July 31). On May 29, 2025, a federal judge for the District of Columbia also found in Learning Resources, Inc. v. Donald J. Trump, et al. that the IEEPA tariffs were illegally imposed; an appeal is proceeding to the U.S. Court of Appeals for the District of Columbia. Both cases are expected to wind up at the U.S. Supreme Court and are being closely followed by affected and interested parties since a Supreme Court decision could potentially reconfigure the scope of the president’s authority on trade issues.

On June 3, President Trump doubled tariffs on imports of steel and aluminum products from 25% to 50%, citing ongoing unfair trade practices that undermined U.S. national security. Copper was added to the 50% list on July 10 following the conclusion of the Section 232 Commerce Department investigation; the new tariff is effective on August 1.

China confirmed on June 27 that a trade framework had been reached with the U.S., pursuant to which China would loosen exports of critical rare earth minerals to the U.S. and lift other restrictions on imports of U.S. merchandise imported into China.

On June 29, in a concession to the U.S. during ongoing trade negotiations, Canada agreed to end its DST which, like other DSTs in place around the world, is believed to target the largest U.S. companies dominating global internet commerce and transactions.

Another trade deal was announced on July 2, when Vietnam and the U.S. agreed to a 20% tariff on all imports into the U.S. (under all tariff codes). However, any imports from Vietnam found to have been transshipped there from China would be subject to a 40% duty. U.S. imports into Vietnam would be subject to a zero-duty rate.

Two days before the 90-day pause on the country-specific reciprocal tariffs expired on July 9 and taking into account that fact that the administration did not secure “90 deals in 90 days” as promised in April, President Trump released another EO with a revised start date of 1 August for new (high) tariff rates.

On July 8, President Trump threatened to impose tariffs on pharmaceutical products and semiconductors imported into the U.S. as soon as 1 August, once the April investigations conclude. The president indicated that such tariffs could be imposed “at a very, very high rate, like 200%” but he would delay imposition for a year to give affected companies time to onshore manufacturing to the U.S.

Shortly before the expiration of the IEEPA country-specific reciprocal tariff pause on July 9, President Trump began sending letters to over 20 countries informing them of the final tariff rate that would apply to imports from those countries in place of the rates first proposed on April 2. Some of the revised tariffs are the same as those announced in April, others are lower and still others are higher (see chart below). Japan and South Korea, two major U.S. trading partners, were both assessed with final duty rates of 25%; interestingly, the president sent a letter to Vietnam announcing a 40% tariff despite the framework for a trade deal reached a week earlier with a 20% rate.


JurisdictionNew Tariff Ratei (July letters)Original Reciprocal Tariff Rate (April announcement)
Algeria30%30%
Bangladesh35%37%
Bosnia and Herzegovina30%36%
Brazilii50%-
Brunei25%24%
Cambodia36%49%
Canada35%25%iii
European Union30%-
Indonesia32%32%
Iraq30%39%
Japan25%24%
Kazakhstan25%27%
Laos40%48%
Libya30%31%
Malaysia25%24%
Mexico30%25%iv
Moldova25%31%
Myanmar40%44%
Philippines20%17%
Serbia35%37%
South Africa30%30%
South Korea25%25%
Sri Lanka30%44%
Thailand36%36%
Tunisia25%28%
Vietnam40%46%

i All the letters provide that the tariffs will apply on top of any sectoral tariffs. They contain a threat of additional tariffs if a country attempts to retaliate in any way and indicate that a higher rate will apply if goods pass through a country as part of a “transshipping” process.

ii Trump cited Brazil’s treatment of former president Bolsonaro (who is currently on trial), rather than a trade imbalance, as one reason for the high tariff. Brazil was not one of the countries targeted for reciprocal tariffs in April.

iii A 25% rate has applied to most Canadian-produced based on goods this year. 

iv A 25% rate has applied to most Mexican-produced based on goods this year.

On July 9, President Trump also aimed his tariff threats at the “BRICS” nations of emerging economies: Brazil, Russia, India, China, South Africa, Egypt, Ethiopia, Iran, and the United Arab Emirates. A 10% duty was proposed unless these BRICS nations ceased their “anti-American rhetoric."

Two days later, on July 11, new tariffs of 30% on goods imported from the EU and Mexico were announced in place of the 20% proposed for the EU on April 2 and the 25% already in place for Mexico. Absent any trade deal, those new tariffs will apply effective August 1. Canada’s rate was later hiked to 35% from its current 25%, also effective August 1.

That same day, President Trump threatened new tariffs of 50% on all goods imported from Brazil unless that country agreed to drop its prosecution of the former president on charges that he illegally tried to overturn the results of an election that he lost. No statutory authority was cited as the basis for this proposal and the 50% tariff is considerably higher than the baseline 10% rate set in April. Nonetheless, four days later, the Office of the U.S. Trade Representative (USTR) launched an investigation of Brazil under Section 301 “to determine whether acts, policies, and practices of the Government of Brazil related to digital trade and electronic payment services; unfair, preferential tariffs; anti-corruption interference; intellectual property protection; ethanol market access; and illegal deforestation are unreasonable or discriminatory and burden or restrict U.S. commerce.” The statute permits USTR to conclude its investigation within 12-18 months after the initiation date of the investigation.

On July 14, President Trump expressed his unhappiness over the state of negotiations with Russia to end the war in Ukraine. In announcing plans to deliver “top of the line” weapons to Ukraine (perhaps via a purchase from NATO), he also expressed plans to impose a new tariff of 100% on imports from any country that “trades” with Russia. Similar to the Venezuelan oil tariffs, the Secretary of State would presumably be tasked with drafting the list of nations subject to these new tariffs.

On July 15, the U.S. and Indonesia reached a trade deal to reduce Indonesia’s original IEEPA reciprocal tariff rate of 32% to 19%, as well as a 40% rate on any “transshipped” goods. The primary goal of the trade deal was cited as “full market access” for U.S. companies to the Indonesian market, pursuant to which the duty rate on many U.S. goods imported into Indonesia was dropped to zero. Indonesia also agreed to purchase $15 billion of U.S. merchandise, including energy and agricultural products, and 55 Boeing jets.

Finally, on July 22, President Trump announced that the U.S. concluded trade deals with Japan and the Philippines. Based on the Truth Social post, the Japan pact sets the reciprocal tariff rate at 15% (down from the 25% rate outlined in the July letter and 24% under the Liberation Day announcement), as will the tariffs on autos, which are currently subject to a 25% sector-specific tariff (Normal Trade Relation duties of 2.5% will also apply to autos). Japan has agreed to invest $550 million in the U.S. Under the Philippines agreement, goods imported into the U.S. will face a 19% tariff (20% in the July letter and 17% under the Liberation Day announcement) and U.S. exports to the Philippines will not be subject to any import tax in the Philippines.


Going Forward

The August 1 deadline is less than two weeks away, and while a few countries have struck trade deals with the U.S., thus fending off the steep tariffs, agreements with some major U.S. trading partners (e.g., the EU) have not materialized. For countries that are unable to negotiate a trade deal with lower tariff rates, tariffs as high as 50% could commence on products exported to the U.S. and these may be accompanied by sector-specific tariffs on merchandise such as semiconductors, pharmaceuticals, aircraft, and critical minerals. Should the tariff hikes proceed, current global tensions and trade conflict are likely to be exacerbated. The potential for the escalation of countermeasures by trading partners remains high and market instability is likely to continue. Global traders are bracing for the next phase.


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