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Chronology of Tariffs in the Second Trump Administration - August 2025

This chronology compiles the official tariff actions and announcements (U.S. presidential proclamations, executive orders, Federal Register notices, and foreign government releases) from January 20, 2025 through August 18, 2025. All measures are reported in the order issued.

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January 2025 - Issuance of the America First Trade Policy Presidential Memorandum

On January 20, 2025 (the first day of President Trump’s second term), U.S. President Donald Trump issued an America First Trade Policy Presidential Memorandum directing the Administration to investigate large U.S. trade deficits and unfair trade practices​. In the following days, the Administration issued executive orders and proclamations to begin addressing these issues.

February 2025Border Tariffs and Section 232 Metal (and Beer) Tariffs

On February 1, 2025, President Trump signed emergency trade orders (under IEEPA and Section 301) imposing across-the-board tariffs of 25% on Canadian and Mexican goods, alongside 10% tariffs on Chinese imports (later raised to 20%). These duties targeted illegal immigration as well as the flow of contraband drugs like fentanyl to the United States.

On February 4, 2025, President Trump temporarily paused the implementation of tariffs on Canada and Mexico for 30 days following diplomatic interventions from Prime Minister Trudeau and President Sheinbaum, while proceeding with the China tariffs.

On February 10, 2025, the President issued Proclamation 10895 and Proclamation 10896 adjusting aluminum and steel imports under Section 232.

  • Section 232 Aluminum (Proclamation 10895): This proclamation increased the additional U.S. tariff on most aluminum imports from 10% to 25%, effective March 12, 2025​, and terminated U.S. exemption agreements with Argentina, Australia, Canada, Mexico, the EU, and the UK. A Federal Register notice implementing these changes (modifying the Harmonized Tariff Schedule) was published on March 5, 2025. On April 4, 2025, a notice adding two additional aluminum derivative products (i.e. beer, classified under subheading 2203.00.00 of the HTSUS, and empty aluminum cans, classified under the subheading 7612.90.10) was published in the Federal Register.

  • Section 232 Steel (Proclamation 10896): This proclamation imposed specified rates of additional duty on steel articles (25% on steel from most countries)​, and directed Commerce to update the tariff schedule accordingly. On March 5, 2025, a Federal Register notice was published implementing these tariff adjustments.

  • Proclamations 10895 and 10896 significantly expanded previous steel and aluminum tariffs by: (1) ending all country exemptions, (2) phasing out specific product exclusion processes, (3) terminating existing General Approved Exclusions, (4) raising aluminum tariffs from 10% during the first term to 25%, and (5) adding more downstream steel and aluminum products.

On February 13, 2025, President Trump signed a Presidential Memorandum entitled “Reciprocal Trade and Tariffs”, directing the Secretary of Commerce and the U.S. Trade Representative to work with Treasury and Homeland Security to provide assessments of each trading partner's non-reciprocal trading practices, including: (1) non-reciprocal tariffs on U.S. exports, (2) unfair taxes imposed on U.S. companies, (3) policies imposing costs on U.S. businesses, (4) exchange rate policies, and (5) other unfair practices. On April 1, 2025, President Trump received the final results of those investigations. The directive established the foundation for what would later be termed "Liberation Day" tariffs, which as decribed below, were issued on April 2, 2025.

March 2025 - Automobile Tariffs, Amendments to Northern-Border and Southern-Border Tariffs, and Amendments to China Fentanyl Tariffs

  • Synthetic Opioids (March 3, 2025): Executive Order 14228 further amended the February 1 tariff order on Chinese imports related to synthetic opioids. It raised the additional tariff on those goods from 10% to 20%​, reflecting the China's alleged ongoing failure to curb illicit fentanyl flows.
  • Border Tariff Amendments (March 6, 2025): Executive Order 14231 (March 6, 2025) amended the earlier northern-border tariff order. It exempted automotive parts and other goods of Canada that qualify as Canadian goods under USMCA, removing their additional 25% duty. The order also reduced the 25% tariff on imported potash from 25% to 10%. Likewise, Executive Order 14227 (March 6, 2025) amended the southern-border tariffs to exempt U.S.-Mexico-Canada-Agreement (USMCA) qualifying Mexican goods and to reduce the duty on non-exempt potash to 10%. These changes were effective March 7, 2025, and were intended to minimize disruptions to North American auto supply chains. These adjustments have provided temporary relief for certain goods that complied with USMCA rules of origin. Approximately 38% of Canadian goods and 50% of Mexican goods were USMCA-compliant in 2024, with Mexico reportedly planning to increase compliance to 85-90%.

  • On March 12, 2025, the global steel and aluminum tariffs previously announced on February 10 entered into force. The implementation of these tariffs triggered additional retaliatory measures. Canada imposed 25% tariffs on approximately $20.6 billion of US goods, including steel products, aluminum products, and other goods. The European Union announced plans for tariffs on €4.5 billion of US consumer goods and €18 billion of US steel and agricultural products.

  • Automobile Imports (Presidential Proclamation 10908, March 26, 2025): On March 26, 2025, the President issued Proclamation 10908 under Section 232 (based on a 2019 Commerce report) to impose a 25% ad valorem duty on imported passenger vehicles, light trucks, and certain auto parts (engines, transmissions, etc.), effective April 3, 2025​. The tariff would apply only to the non‑U.S. content of qualifying vehicles (i.e. exclude U.S. parts) under USMCA preferential rules. These tariffs are currently in effect as of 12:01 am ET on Thursday, April 3, 2025. The Trump administration has announced that similar tariffs will be implemented for auto parts by May 2025.

March 2025 - Retaliation by Canada and China

  • Canada: Canadian Prime Minister, Mark Carney, announced countermeasures against the United States in early March. On March 4, 2025 (effective 12:01 a.m.), Canada imposed 25% tariffs on C$30 billion of U.S. goods, mirroring the U.S. tariffs on Canada​. These tariffs targeted a wide range of U.S. exports (from agricultural products to industrial goods). On March 13, 2025, Canada further imposed 25% tariffs on selected U.S. imports: $12.6 billion worth of steel products and $3.0 billion of aluminum products, plus additional products totaling $14.2 billion, for a total of ~$29.8 billion​. These counter-tariffs matched the U.S. steel and aluminum tariffs dollar-for-dollar.
  • Mexico: Mexico had announced plans to retaliate similarly, but no countermeasures have been imposed to date.
  • China: On March 4, 2025, the State Council Tariff Commission of the People’s Republic of China announced that in response to the additional 10% imposed on February 1, 2025 on products imported from China, an additional 15-percent tariff will be imposed on imported chicken, wheat, corn and cotton originating from the United States, effective from March 10, 2025. Furthermore, sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables and dairy products will be subject to an additional 10-percent tariff, effective from March 4, 2025.

April 2025Reciprocal Tariffs and Chinese Retaliation

In April 2025 the U.S. imposed broad reciprocal tariffs and adjusted duties in response to trade deficits. It also :

  • Synthetic Opioid Low-Value Tariffs (April 2, 2025): Executive Order 14256 (April 2, 2025) revoked duty-free de minimis treatment for low-value shipments (valued ≤ $800) from China (including Hong Kong). Effective May 2, 2025, all such previously exempt shipments became subject to the applicable additional duties (e.g. 20% set by the previous EO)​.

  • "Liberation Day" Reciprocal Tariffs (April 2, 2025): On April 2, 2025, President Trump signed Executive Order 14257 titled "Regulating Imports With a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits", declaring a national emergency on account of persistent U.S. goods trade deficits. The order stablished a two-tiered tariff framework: (1) a universal 10% ad valorem tariff on virtually all imports (effective April 5, 2025); and, (2) country-specific "reciprocal" tariffs targeting approximately 60 nations (effective April 9, 2025). Canada and Mexico remained largely exempt from this new round of tariffs, though they continued to face the earlier 25% tariffs imposed in February and March. As of April 10, 2025, the United States has temporarily suspended the reciprocal tariffs for 90 days for all trading partners except China, with which tensions have escalated dramatically during the past weeks. Our team has written a detailed article on these reciprocal tariffs, which can be accessed here.

  • Chinese Tariffs (April 4–9, 2025): In early April, China responded to the U.S. measures. On April 4, 2025, China’s State Council Tariff Commission announced it would impose a 34% tariff on all U.S. imports (effective 12:01 a.m. Apr 10, 2025). In reaction, on April 8, 2025 the U.S. issued an Executive Order raising the U.S. tariff on the affected Chinese goods from 34% to 84%, effective April 9, 2025​. The U.S. order also increased the additional de minimis duty rate (which had been 30%) up to 90%​.

  • Further Escalation (April 9, 2025): On April 9, 2025, President Trump issued a further Executive Order 14266 adjusting U.S. tariffs in light of China’s new retaliation. The order increased the U.S. tariff on remaining Chinese imports from 84% to 125%, effective April 10, 2025​. It also raised the additional de minimis duty rate from 90% to 120% for one-dollar low-value shipments​.
  • Global Trade Retaliation: By mid-April 2025, the United States faced retaliatory tariffs from multiple trading partners. Notably, on April 9, 2025, the European Union voted in favor of introducing a retaliatory 25% tariff on a wide range of US products, including almonds, orange juice, poultry, soyabeans, steel and aluminium, tobacco and yachts, in response to the March decision by the US to impose tariffs on imports of steel and aluminium from the EU. These first wave of EU countermeasures were expected to enter into force on April 15, 2025. However, on April 14, 2025, the EU decided to pause its countermeasures to allow time for US-EU negotiations. The EU reportedly suspended EU countermeasures worth €21 billion of US exports. 

April 2025 – Trump Administration Softens Tariffs on Auto Parts and Initiates Section 232 Investigations on Pharmaceuticals, Semiconductors, and Critical Minerals

  • Automobile Parts Tariff Relief (April 29, 2025): On April 29, 2025, President Trump issued an executive order amending Proclamation 10908 (by which the Trump administration imposed a 25% tariffs on imported automobiles and automobile parts under Section 232). This modification, effective retroactively from April 3, 2025, establishes an "import adjustment offset" mechanism for automobile manufacturers that assemble vehicles in the United States. Under this program:
    • For vehicles assembled between April 3, 2025, and April 30, 2026, manufacturers can apply for an offset equal to 3.75% of the aggregate Manufacturer's Suggested Retail Price (MSRP) value of all U.S.-assembled vehicles.

    • For vehicles assembled between May 1, 2026, and April 30, 2027, the offset will be reduced to 2.5% of total MSRP.

    • According to the White House, these percentages reflect the duty that would be owed when a 25% duty is applied to parts accounting for 15% of an automobile's MSRP value in the first year, and 10% in the second year. Effectively, this structure allows automakers with 85% U.S. content levels to avoid paying tariffs on the remaining imported parts. The Commerce Department was given 30 days to establish a documentation process for manufacturers to receive these offsets. For more information about this tariff adjustment, and its impact on the automotive sector, please refer to this article, in which our team provides an in-depth analysis.

  • Section 232 Semiconductor Investigation (April 14, 2025): On April 14, 2025, the Department of Commerce's Bureau of Industry and Security (BIS) officially published its notice requesting public comments on the Section 232 investigation of semiconductors and semiconductor manufacturing equipment on April 16, 2025. This investigation, initiated on April 1, 2025, covers a broad range of products including "semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics, and SME components", as well as "downstream products that contain semiconductors". The comment period concluded on May 7, 2025, with industry groups like the Semiconductor Industry Association (SIA) submitting detailed responses addressing potential impacts of tariffs on the domestic semiconductor ecosystem. The SIA recommended that the administration pursue a multi-country sectoral agreement focused on semiconductors rather than broad-based tariffs.

  • Section 232 Pharmaceuticals Investigation (April 14, 2025): Also on April 14, 2025, the Secretary of Commerce initiated an investigation to determine the effects on the national security of imports of pharmaceuticals and pharmaceutical ingredients, including finished drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients, and key starting materials, and derivative products of those items. The investigation aims to assess U.S. dependency on foreign suppliers, particularly China and India, which collectively account for 80% of global API production.

  • Section 232 Investigation on Critical Minerals and Derivatives (April 15, 2025): On April 15 U.S. President Trump signed Executive Order 14272 directing the Department of Commerce to initiate a Section 232 investigation into processed critical minerals and derivative products, to encompass rare earth elements, uranium, and downstream goods such as batteries, wind turbines, and advanced optical devices. This investigation targets China’s dominance in critical mineral processing, where it controls 70% of rare earth element refining capacity. For critical minerals, the Commerce Department faces a compressed 180-day timeline (instead of the standard 270-day period) to deliver recommendations, signaling potential tariffs by October 2025.

May 2025 – US-China Tariff De-Escalation

  • US-China 90-Day Tariff Suspension (May 12, 2025): On May 12, 2025 the United States and China agreed—as a result of bilateral negotiations held in Geneva—to a 90-day suspension of escalating tariffs, significantly reducing duties imposed on each other's goods. Under this agreement, U.S. tariffs on Chinese imports were reduced from 145% to 30%, while China lowered its tariffs on U.S. goods from 125% to 10%. This de-escalation, effective May 14, 2025, marks the first major thaw in trade relations since 2024, albeit Treasury Secretary Scott Bessent emphasized continued "strategic decoupling" in sectors like semiconductors and pharmaceuticals.

  • U.S. Threatens Maximum Tariffs (May 18, 2025): On May 18, 2025, Treasury Secretary Scott Bessent reportedly reiterated that the U.S. would revert to April 2, 2025, reciprocal tariff rates -ranging from 20% to 145%-for countries failing to negotiate trade deals in "good faith" during the 90-day pause. These tariffs include broad levies such as a 10% duty on nearly all imports and harsher "reciprocal" tariffs targeting nations with existing levies on U.S. goods. Southeast Asian nations were notably impacted, with tariffs reaching up to 49%. Canada and Mexico remained exempt from these new measures due to compliance with the 2020 USMCA deal.

May 2025 – European Union Gets Ready to Retaliate Against U.S. Unilateral Tariffs

  • On 8 May 2025, the E.U. Commission published a preliminary list identifying U.S.-origin products that may become subject to EU retaliatory tariffs. The Commission has also launched a public consultation, inviting comments from stakeholders. The deadline for submissions is 10 June 2025 at noon CET. For additional details about this consultation process, please refer to this article, where our team provides an in-depth analysis.

June 2025 – Tariff Hikes and Status on Trade Deals

Section 232 Steel and Aluminum Tariffs Increased to 50% (3-4 June 2025)

On 3 June 2025, President Trump issued a proclamation doubling the Section 232 tariffs on most steel and aluminum imports, including derivative products, from 25% to 50%. The increase took effect at 12:01 a.m. EDT on 4 June 2025. The proclamation also narrowed the exception from reciprocal tariffs imposed under the International Emergency Economic Powers Act (IEEPA), modifying the tariff stacking order so that imports from Canada and Mexico now face the full 50% Section 232 tariffs on these goods. Imports from the United Kingdom were temporarily exempted from the increase, remaining at 25% pending further negotiations, with a potential modification on or after 9 July 2025. The move is projected to add $50 billion in new tariff costs annually.

US-China Trade Framework Agreement (9–11 June 2025)

Following meetings in London, U.S. and Chinese officials announced a framework agreement to uphold the terms of the Geneva trade deal reached in May. While full details remain private, President Trump stated that the U.S. is getting "a total of 55% tariffs, China is getting 10%," suggesting the current tariff structure will remain in place post-truce. Commerce Secretary Howard Lutnick confirmed the 55% rate will be maintained on most Chinese goods. This effective tariff rate is a composite of three separate, stacking duties:

  • The 25% Section 301 tariffs from the first Trump term.

  • The 20% "fentanyl" tariffs imposed in March 2025.

  • The 10% "reciprocal" baseline tariff from April 2, 2025

Expansion of Steel Tariffs to Household Appliances (16 June 2025)

On 16 June 2025, the U.S. Bureau of Industry and Security (BIS) of the Department of Commerce revised the list of products subject to Section 232 duties on steel to include the following additional steel derivative products:

  1. Combined refrigerator-freezers (HTSUS 8418.10.00)
  2. Small and large dryers (HTSUS 8451.21.00 and 8451.29.00)
  3. Washing machines (HTSUS 8450.11.00 and 8450.20.00)
  4. Dishwashers (HTSUS 8422.11.00)
  5. Chest and upright freezers (HTSUS 8418.30.00 and 8418.40.00)
  6. Cooking stoves, ranges, and ovens (HTSUS 8516.60.40)
  7. Food waste disposals (HTSUS 8509.80.20)
  8. Welded wire racks (statistical reporting number 9403.99.9020)

Section 232 duties will apply to imports of these products entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on 23 June 2025. As a result, these products will face an additional 50% tariff levied on the value of the steel content within the item.

Implementation of US-UK Economic Prosperity Deal (16 June 2025)

During the G7 summit in Canada, President Trump and UK Prime Minister Keir Starmer signed an agreement to implement the "US-UK Economic Prosperity Deal", the general terms of which were announced on the 8th of May. The deal reduces U.S. tariffs on UK-origin automobiles and aerospace goods in exchange for UK commitments to lower tariffs on American meat and ethanol. However, key issues remain under negotiation, including the treatment of UK steel, aluminum, and pharmaceutical imports.

EU Trade Negotiations Status (Mid-July 2025): European officials are reportedly growing resigned to the likelihood that the 10% baseline "reciprocal" tariff will be a permanent feature of any future U.S.-EU trade agreement. U.S. negotiators have signaled that a rate below 10% is not on the table. The EU is seeking to finalize a deal before the 90-day tariff truce expires in August, which could see tariffs on a wide array of EU goods escalate significantly.

July 2025 – Trump's Ultimatum Letters and August 1 Deadline

Extension of Reciprocal Tariff Deadline (7th July 2025): On 7th July 2025, President Trump signed Executive Order 14316 on Extending the Modification of the Reciprocal Tariff Rates, extending the reciprocal tariff deadline from 9th July to 1st August 2025. This marked the second extension of Trump's "Liberation Day" tariffs, which had been temporarily suspended for 90 days to allow for trade negotiations. The executive order stated that the President had "determined, based on additional information and recommendations from various senior officials, including information on the status of discussions with trading partners, that it is necessary and appropriate to extend the suspension effectuated by Executive Order 14266 until 12:01 a.m. eastern daylight time on August 1, 2025."

Tariff Ultimatum Letters Campaign (7th-15th July 2025): Following the extension order, the Trump administration launched an unprecedented campaign of bilateral tariff ultimatums through formal letters to trading partners. These letters outlined specific tariff rates that would take effect on 1st August 2025, unless new trade agreements were reached. The administration's approach represented a significant departure from traditional trade negotiations, effectively treating unilateral tariff announcements as concluded trade agreements.

Major Trading Partners Targeted: The European Union received notification on 12th July 2025 of a 30% tariff rate, affecting €553 billion in annual trade. European officials expressed surprise at the development, with Finland's trade minister Ville Tavio noting that "during the week we had quite a positive mood about getting the framework agreement done". The EU had been optimistic about finalising a comprehensive trade deal with the United States and was reportedly "fully locked and loaded to conclude" an agreement as late as 11th July 2025.

Mexico also received notice of a 30% tariff rate on 12th July 2025, separate from existing USMCA exemptions. Canada was notified of a 35% tariff rate on 10th July 2025, escalating from the existing 25% rate. Japan and South Korea each received letters on 7th July 2025, announcing 25% tariff rates, affecting $148 billion in annual trade with Japan alone.

Brazil's 50% Tariff – Political and Economic Justifications: Brazil received notification of a 50% tariff rate on 9th July 2025, with Trump explicitly linking this to what he characterised as the "witch hunt" trial of former President Jair Bolsonaro. Trump's letter to Brazilian President Luiz Inácio Lula da Silva stated: "The way that Brazil has treated former President Bolsonaro, a highly respected leader throughout the world during his term, including by the United States, is an international disgrace." The letter further accused Brazil of "insidious attacks on Free Speech" and claimed that Brazil's Supreme Court had unlawfully censored U.S. social media platforms.

Limited Trade Agreement Success: Despite the administration's negotiations, only three countries reached formal agreements with the United States by 15th July 2025. Vietnam secured a reduced tariff rate through direct negotiations, while Indonesia concluded similar arrangements. The United Kingdom had previously secured a framework agreement through Executive Order 14309 on Implementing the General Terms of The United States of America-United Kingdom Economic Prosperity Deal (16th June 2025), which provided preferential treatment for certain sectors.

Section 232 Investigation Completions and New Sectoral Tariffs: On 9th July 2025, President Trump announced a 50% tariff on all copper imports, effective 1st August 2025, citing national security concerns.

Pharmaceutical Tariff Threat (8th July 2025): During a Cabinet meeting on 8th July 2025, Trump announced plans to impose tariffs "at a very, very high rate, like 200%" on pharmaceutical imports, with a 12-18 month grace period for companies to relocate production to the United States. Commerce Secretary Howard Lutnick indicated that the Section 232 investigation into pharmaceutical imports would be completed by the end of July 2025.

This announcement built upon the Section 232 investigation into pharmaceuticals initiated in April 2025, which aimed to assess U.S. dependency on foreign suppliers, particularly China and India, which collectively account for 80% of global active pharmaceutical ingredient production. Ireland, Switzerland, Germany, Singapore, and India are the top exporters of pharmaceuticals to the United States, with Ireland alone accounting for approximately $50 billion in annual pharmaceutical exports to the U.S.

BRICS Additional Tariff (6th July 2025): On 6th July 2025, coinciding with the BRICS summit in Rio de Janeiro, Trump announced an additional 10% tariff on countries aligning themselves with the so-called anti-American policies of BRICS, stating that "Any country aligning themselves with the Anti-American policies of BRICS, will be charged an additional 10% Tariff. There will be no exceptions to this policy".

The BRICS threat was explicitly tied to concerns about dollar dominance. The U.S. President has characterised the potential loss of the dollar's reserve currency status as equivalent to "losing a war, a major world war". The threat affects BRICS members including Brazil, Russia, India, China, South Africa, Egypt, Ethiopia, Indonesia, Iran, and the United Arab Emirates, as well as nine partner countries.

Limited Trade Agreement Success: Despite the administration's initial promise of "90 deals in 90 days", only three countries have reached formal agreements with the United States by 15th July 2025. Vietnam secured a reduced tariff rate of 20% (down from 46%) on 2nd July 2025, with the agreement including a 40% tariff on goods deemed to be "transshipped" through Vietnam from other countries. The deal includes Vietnamese commitments to zero tariffs on U.S. imports and pledges to purchase billions of dollars in U.S. agricultural products, energy, and Boeing aircraft.

Indonesia concluded negotiations on 15th July 2025, reducing its tariff rate from 32% to 19%. The agreement includes Indonesian commitments to purchase $15 billion in U.S. energy, $4.5 billion in U.S. agricultural products, and 50 Boeing aircraft. The United Kingdom had previously secured a framework agreement through Executive Order 14309, maintaining a 10% baseline rate with preferential treatment for certain sectors.

International Responses and Retaliation Preparations: The European Union responded by preparing a comprehensive list of potential retaliatory tariffs affecting €72 billion ($84 billion) worth of U.S. goods. EU Commission President Ursula von der Leyen stated that the EU would "safeguard its interests, including the adoption of proportionate countermeasures" if necessary. Despite the tariff threat, EU Trade Commissioner Maros Sefcovic maintained that the bloc would "continue to engage with the United States administration and prioritise negotiated solutions by the new deadline of August 1".

Brazilian President Luiz Inácio Lula da Silva rejected Trump's ultimatum, stating: "Brazil is a sovereign nation with an independent judiciary and will not accept any form of tutelage". Brazil threatened retaliatory tariffs under its "Law of Economic Reciprocity". Russian officials were similarly dismissive, with former President Dmitry Medvedev calling Trump's threats "a theatrical ultimatum" and stating that "Russia didn't care".

August 2025 – “Liberation Day” Tariffs Take Effect and Renewed Escalation

At 12:01 a.m. EDT on 1 August 2025, the Trump administration allowed the suspension of reciprocal tariff measures (initially announced under Executive Order 14257) to expire. As a result, a universal 10% ad valorem duty on virtually all imports entered into effect, alongside country-specific reciprocal rates ranging from 20% to 145%. Key changes include:

Trading partner

New tariff since 1 April

Switzerland

39%

European Union

15%

United Kingdom

10%

India

25% (increasing to 50% on 27 Aug.)

Japan

15%

Viet Nam

20%

Indonesia

19%

Turkey

15%

Iceland

15%

Norway

15%

Liechtenstein

15%

Israel

15%

Chinese Taipei (Taiwan)

20%

Korea

15%

New Zealand

15%

Brazil

10% + 40% penalty = 50%

Some additional details are worth highlighting:

  • Brazil: Following a July 30 Executive Order, Brazil is subject to a combined 50% tariff—10% reciprocal plus a 40% penalty—citing national security and political reasons tied to the prosecution of Jair Bolsonaro. Exemptions exist for certain aircraft, orange juice, and some metals. Brazil has threatened to retaliate after receiving a 50% tariff, but is still formulating an official response. President Lula condemned the U.S. move as political interference.

  • India: The U.S. announced an additional 25% tariff on Indian goods, bringing the total to 50%, as a penalty for continued import of Russian oil and military equipment. The 50% tariff will enter into force, absent any agreement between the U.S. and India, on 27 August 2025.

  • De Minimis exception: The de miinimis exception has been repealead for almost all countries, except China. As of August 29, all shipments under $800 must enter customs and pay applicable duties. For six months, postal items may use flat rates ($80–$200/item depending on country/tariff level); full ad valorem duties apply from March 2026. U.S. travelers still enjoy limited duty-free allowances.

  • Copper tariff: Trump imposed a new Section 232 tariff of 50% on the copper content of semi-finished and copper-intensive derivative products, including tubes, wires, rods, sheets, and electrical components. The order cited supply chainProducts containing copper must declare copper and non-copper values separately for tariff calculation. and national security risks identified in a June Commerce Department report.

  • Partial U.S. - China truce: With hours to spare before the planned expiry, President Trump signed an Executive Order extending the 90-day US-China tariff truce until 10 November 2025.

Legal Implications

The escalation and global expansion of U.S. tariffs—coupled with the end of de minimis and aggressive transshipment enforcement—has radically changed the trade environment for 2025. The "Liberation Day" tariff architecture now governs more than 90 trade partners with few exemptions. Major partners face rates up to 50%, and critical e-commerce exemptions have ended, affecting millions of small businesses and consumers.

From a legal standpoint, these developments continue to stretch the boundaries of U.S. international obligations under the WTO and USMCA, though national security justifications remain the principal government defense. Legal, economic, and compliance risks are at historic highs.

The expansion of tariff justifications to include various economic and political considerations represents a substantial broadening of the administration's interpretation of national security exceptions under both domestic law and WTO frameworks. From a legal perspective, many of these measures appear to conflict with US commitments under the WTO and USMCA frameworks, albeit the U.S. administration has consistently invoked national security exemptions. Under WTO jurisprudence, however, particularly following the December 2022 ruling against US steel and aluminum tariffs, these security justifications face increasing scrutiny from the international legal community.

The USMCA implications remain complex, with Canada and Mexico receiving higher tariff rates while maintaining exemptions for USMCA-compliant goods. This dual-track approach may create precedential issues for future trade agreement interpretation and could potentially trigger dispute settlement procedures under the USMCA framework.

At the time of writing, there have been no invocations of the USMCA security exception. The text of the USMCA security exception is somewhat similar to that under WTO law, albeit with two notable differences. First, the USMCA version does not require that the party invoking the exception demonstrates the existence of an emergency in international relations. Second, the language of the USMCA exception seems to provide virtually unlimited discretion to the party invoking it as to what it regards as a "security" issue. As a result, the United States has significantly higher probability of successfully invoking the security exception before a potential USMCA panel, compared to if it were to do so before the WTO tribunals.

The same rationale may apply to the countermeasures that some of the United States' trading partners have adopted (or are considering to adopt) in response to the Trump administration tariffs.

De Minimis Law ccontinues to monitor developments closely and stands ready to advise on compliance, risk mitigation, and trade dispute resolution in this volatile environment. For further updates or assistance in navigating these complex trade issues, please contact our office.

Disclaimer:

This article is for informational purposes only and does not constitute legal advice.

Dr. Manuel Sanchez Miranda
Partner, International Trade
smiranda@deminimislaw.com
+41 (0)78 694 1217

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