Tariffs

For the latest Trump trade executive actions, please view the below Torres Trade Trump Table for important information. This table will be monitored and updated regularly. The last update occurred September 11, 2025.

On June 16, 2025, President Trump issued an Executive Order titled “Implementing the General Terms of the United States of America-United Kingdom Economic Prosperity Deal” (“the E.O.”). The E.O. implements several changes to tariffs on UK imports based on “General Terms” agreed to by the U.S. and UK that were previously announced on May 8, 2025.[1]

This article provides an overview of the most recent tariff updates affecting businesses operating within the semiconductor, pharmaceutical, and critical mineral industries. Below we outline recent tariff exclusions for semiconductor products and new investigations into certain semiconductors, pharmaceuticals, and critical minerals which can lead to higher tariffs for these product groups. Industries affected by the newly launched investigations should consider filing a public comment.

On April 9, 2025, President Trump issued an Executive Order “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment” (“the E.O.”) amending prior executive orders imposing “reciprocal tariffs” on all imports of foreign-origin goods pursuant to the President’s authority under the International Emergency Economic Powers Act (“IEEPA”). The E.O. announced partial relief from the new reciprocal tariffs for all U.S. trading partners, except for China, which will now be subject to a total tariff rate of up to 170%.

90-Day Pause on Country-Specific Tariff Rates

On April 2, 2025, President Trump announced long-awaited reciprocal tariffs on imports of foreign goods into the United States. This action follows the President’s recent announcement on March 26, 2025, of a 25% tariff on imports of automobiles and automobile parts.

On March 26, 2025, President Trump issued a Proclamation announcing the imposition of a 25% tariff on imported automobiles set to become effective on April 3, 2025, and certain automotive parts, set to become effective no later than May 3, 2025. These automotive tariffs will follow what the President has dubbed “Liberation Day” (i.e., April 2, 2025), the day new reciprocal and sectoral tariffs are planned to go into effect on a wide range of imports from various countries.[1] 

Just two days after the tariffs on all Mexican and Canadian products became effective, on March 6, President Trump announced amendments to the tariffs against Mexico and Canada “to minimize disruption to the United States automotive industry and automotive workers.” Specifically, the amendments provide that the tariffs would not apply to goods that qualify for preferential treatment under the United States-Mexico-Canada Agreement (USMCA). The amendments also lowered the duty rate for non-qualifying imports of potash from Canada and Mexico. (For background on the tariffs and retaliation, see our earlier article, U.S. Implements New Tariffs on Canada, Mexico, and China.)

Beginning just after midnight on March 4, 2025, the United States implemented a 25% tariff on imports from Canada and Mexico (except Canadian “energy resources,” which are subject to a 10% tariff), and increased tariffs on China from 10% to 20%. These tariffs are implemented under the International Emergency Economic Powers Act (IEEPA) pursuant to national emergencies declared by President Trump related to the influx of illegal immigrants and drugs, particularly fentanyl, into the United States. For additional background on the initial actions, please see our previous trade alert, Tariffs on Mexico and Canada Delayed; China Retaliates Against 10% Tariff.

Pursuant to a Federal Register notice (“Notice”) released on February 20, 2025, the Office of the United States Trade Representative (USTR) seeks public comments to identify unfair trade practices by other countries and to investigate harm to the United States from non-reciprocal trade arrangements. The USTR’s request for comments is pursuant to the America First Trade Policy Presidential Memorandum and the Presidential Memorandum on Reciprocal Trade and Tariffs. For background on the “reciprocal tariffs,” see our earlier trade alert, President Trump Announces Plan to Establish “Reciprocal Tariffs” on All Countries. The USTR will use the information to recommend appropriate actions to remedy such practices in a report to the President.

On February 13, 2025, President Trump issued a Presidential Memorandum on “Reciprocal Trade and Tariffs” (the “Reciprocal Tariffs Memorandum”), introducing the “Fair and Reciprocal Plan” to determine “the equivalent of a reciprocal tariff with respect to each foreign trading partner.” The reciprocal tariffs may be implemented as soon as April 2025.[1]

On February 10, 2025, the Trump administration published a proclamation announcing reinstatement of the 25% tariff on all steel imports (“Steel Proclamation”). That same day, President Trump also issued a proclamation announcing the reinstatement and increase of tariffs on aluminum imports to 25% (“Aluminum Proclamation”). The tariffs will be imposed on steel and aluminum articles imported from all countries, and the Proclamations announced tariffs on certain steel and aluminum product derivatives. The reinstated tariffs become effective on March 12, 2025.

President Donald Trump has agreed to delay the implementation of tariffs on imports from Mexico and Canada for 30 days, following negotiations with the leaders of both countries. For more information about the threatened tariffs, see yesterday’s trade alert, U.S. Imposes Tariffs on Imports from Canada and China Beginning February 4; Mexican President Announces One Month Implementation Delay (published before the announcement of the delay of tariffs on Canada). The decision to delay implementation comes after Mexico and Canada committed to enhance border security and combat the flow of fentanyl into the United States.

On February 1, 2025, President Trump announced significant new tariffs on imports from Mexico, Canada, and China, set to take effect on February 4, 2025. The tariffs were announced via three separate Executive Orders (EOs) and are imposed on Canada to “Address the Flow of Illicit Drugs Across [the] Norther Border,” on Mexico to “Address the Situation at [the] Southern Border,” and on China to “Address the Synthetic Opioid Supply Chain in . . . China.” Importantly, unlike tariffs on China implemented under Section 301 of the Trade Act of 1974 (Section 301) in the first Trump administration, the new tariffs are imposed under the International Emergency Economic Powers Act (IEEPA) and are pursuant to a national emergency declared by President Trump.

On December 23, 2024, the Office of the United States Trade Representative (USTR) launched an investigation of China’s acts, policies, and practices related to targeting of the semiconductor industry for dominance. The investigation was launched under Section 301 of the Trade Act of 1974.

On November 25, 2024, President-elect Donald Trump provided some additional clarity on his immediate tariff plans in a post on Truth Social. Specifically, Trump announced his intent to sign an Executive Order on his first day in office to impose a 25% tariff on all products from Mexico and Canada. According to the post, the tariff will remain in effect for an indefinite period tied to fentanyl smuggling and illegal immigration. In a separate post, President-elect Trump also announced his intention to add a 10% tariff “above any additional tariffs” on all Chinese-origin products. Factoring in current 25% Section 301 tariffs on Chinese goods, this means that some Chinese products will be subject to a 35% tariff in addition to their normal duty rate. Trump similarly tied this tariff hike to China’s role in the fentanyl crisis.

A second Donald Trump presidency ushers in a moment in international trade without precedent…other than the first Trump presidency. It is often difficult to predict how a new administration will act, but in this case, the “new” president has previously shown that he does not always conform to the typical expectations of the office, particularly with respect to international trade. Below we outline a few initial impressions on the potential impacts the Trump presidency will have on global relationships and discuss how you can prepare for the new administration.

On May 22, 2024, the United States Trade Representative (“USTR”) announced the publication of a Federal Register Notice (“the FRN”) setting forth additional and increased Section 301 tariffs for specific Harmonized Tariff Schedule of the U.S. (“HTSUS”) subheadings. In addition, the FRN provides details on products subject to potential exclusions from the tariffs and establishes a period for interested parties to provide comments on the tariff modifications and potential exclusions.

On May 14, 2024, the United States Trade Representative (“USTR”) announced the publication of its long-awaited report on the Four-Year Review of Actions Taken in the Section 301 Investigation: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation (“the Report”). Considering the reported efficacy of the tariffs as strategic measures to counteract adverse Chinese policies and practices, and findings that unfair practices persist, President Biden and the USTR are now set to take further action related to Section 301 tariffs on Chinese-origin goods.

On April 17, 2024, the United States Trade Representative (“USTR”) initiated an investigation pursuant to Section 301 of the Trade Act of 1974 (“Section 301”) regarding China’s acts, policies, and practices to dominate the maritime, logistics, and shipbuilding sector. The investigation was initiated following the filing of a petition (“Petition”) by several domestic labor unions (“Petitioners”) representing these industries. The USTR encourages interested parties to submit comments on any issue covered by the investigation. Comments are due by May 22, 2024.

On December 26, 2023, the Office of the United States Trade Representative (“USTR”) announced the extension to May 31, 2024, of all current exclusions from Section 301 tariffs on Chinese-origin goods. The extended exclusions include 77 COVID-related exclusions and 352 previously reinstated exclusions. 

The Office of the United States Trade Representative (“USTR”) is conducting a review of the China Section 301 tariffs that were put into place in 2018 under the Trump administration. 

If your company has been negatively impacted by the Section 232 and Section 301 duties, you may now have another opportunity to voice your concerns in Washington. On May 5, 2022, the U.S. International Trade Commission (ITC) published information regarding a fact-finding investigation into the economic impact of the Section 232 and 301 duties on U.S. industries.

On May 3, 2022, the U.S. Trade Representative (“USTR”) announced a statutory two-phase review of the Section 301 tariffs on Chinese-origin goods. USTR also published a Federal Register Notice draft describing the process for filing requests for extension of the tariffs.

On June 2, 2021, the U.S. Trade Representative (“USTR”) announced the imposition – and immediate 180-day suspension – of 25% tariffs on goods from six countries pursuant to findings in the Section 301 of the Trade Act of 1974 investigations (“Section 301 investigations”) into digital services tax (“DST”) regimes.

If you have not noticed, 2020 is a U.S. presidential election year. If you missed that fact, you may also not realize that the United States is in the midst of a years-long trade war with China. The convergence of these two circumstances has caught the attention of the business community, particularly as relates to trade policy.

On April 18, 2020, President Trump issued an Executive Order providing authority to the Secretary of the Treasury, under 19 U.S.C. § 1318, to extend the deadline for payments of certain estimated duties, taxes, and fees for importers suffering significant financial hardship during the national emergency created by the COVID-19 novel coronavirus pandemic.

On December 18, 2019, the United States Trade Representative (“USTR”) officially signaled the first real respite in the ongoing trade war with China by publishing a Notice of Modification of Action  to suspend a planned 15% duty on certain products from China that was originally scheduled to take effect on December 15, 2019. This early Christmas present came after nearly two years of the USTR extending and increasing tariffs on Chinese goods pursuant to Section 301 of the Trade Act of 1974 (“Section 301”).

Halloween parties are an annual tradition for many Americans. But this year Halloween may be a little spookier than usual as some popular party items could become more expensive.

The USTR is still accepting exclusion requests for products subject to the trade action on $200 Billion of Chinese goods, also known as “List 3” products

In spite of a short-term reprieve from additional tariffs on select products, trade uncertainty under the Trump administration continues for U.S. companies that do business with China.

On September 11, 2018, the Department of Commerce (“Commerce”) issued an interim final rule in the Federal Register updating the process by which companies may request exclusion from additional duties on steel and aluminum articles pursuant to Section 232.

On August 7, 2018, the United States Trade Representative (“USTR”) announced it had finalized a list of $16 billion worth of imports from China that will be subject to a 25% tariff rate. 

On August 1, 2018, the United States Trade Representative (“USTR”) announced it was considering raising the proposed tariffs on $200 billion worth of goods imported from China from 10% to 25%. This is the latest in a long string of developments aimed at urging China to stop its unfair practices, open its market, and engage in true market competition. 

On July 6, 2018, the United States Trade Representative ("USTR") announced the procedures for filing and obtaining product exclusions from the recently announced Section 301 tariffs on the imports of $34 billion worth of Chinese goods. Exclusion requests are due by October 9, 2018.

On June 15, 2018, the Trump Administration took the next step in escalating trade tensions with China by imposing additional 25% tariffs on imports of more than 800 products under Section 301 of the Trade Act of 1974.

On May 8, 2018, President Trump announced the United States will withdraw from the Joint Comprehensive Plan of Action (“JCPOA”), commonly referred to as the “Iran Nuclear Deal,” which was adopted on October 18, 2015 and implemented on January 16, 2016 (“Implementation Day”). 

This article discusses the latest on tariff exemptions by the Trump Administration. 

This article serves as an update on the most recent tariff related developments.

On March 19, 2018, the U.S. Department of Commcer ("DOC") published an interim final rule (“the Interim Final Rule”) listing the requirements for companies seeking product-based exclusions to the steel and aluminum tariffs previously announced by President Trump on March 8, 2018.

On March 8, 2018, President Trump announced his decision to implement tariffs on steel and aluminum imports. These tariffs go into effect on March 23, 2018,[1] 15 days after President Trump’s announcement.

With the signing of two new executive orders, President Trump is taking the first steps in fulfilling two of his favorite campaign promises, both relating to trade: (1) no longer tolerating trade abuse that damages the American economy and (2) decreasing the national trade deficit.