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Chronology of Tariffs in the Second Trump Administration
This article summarizes the key tariff measures implemented during President Trump’s second term, providing context for the anticipated "Liberation Day" tariffs. Recent tariffs have targeted key industries and trading partners, significantly escalating trade tensions and prompting retaliatory measures. The upcoming tariff announcement may redefine US trade policy, potentially challenging WTO rules and global economic stability.
Before assessing the expected "Liberation Day" tariff announcement scheduled for later today (April 2, 2025), this report examines the chronological evolution of trade measures implemented during President Trump's second term. This analysis provides crucial context for understanding the anticipated reciprocal tariff regime and its potential global implications.
Invoking the National Emergencies Act (50 U.S.C. § 1621) and International Emergency Economic Powers Act (IEEPA, 50 U.S.C. § 1701), President Trump imposed across-the-board tariffs of 25% on Canadian and Mexican goods, alongside 10% tariffs on Chinese imports (later raised to 20%). This initial announcement represented a significant departure from traditional trade policy implementation, bypassing usual procedural frameworks by invoking emergency powers. For US importers, the announcement created immediate uncertainty across supply chains heavily dependent on these neighboring countries and China. Exporters from these targeted countries faced the prospect of substantially reduced competitiveness in their largest market.
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.
Building on first-term Section 232 tariffs (19 U.S.C. § 1862), Proclamations 10425 and 10426 removed all country exemptions and expanded coverage to downstream products like automotive stamped metal components.
The Commerce Department's updated "melted and poured" requirements now mandate:
US content ≥ 85% for steel
US content ≥ 75% for aluminum
This exceeds USMCA's 75% regional value content (RVC) rules, creating compliance conflicts for integrated North American supply chains.
Proclamations 10425 and 10426 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.
This memorandum directed the Secretary of Commerce and the US Trade Representative to work with Treasury and Homeland Security to provide assessments of each trading partner's: (1) tariffs on US exports, (2) unfair taxes imposed on US companies, (3) policies imposing costs on US businesses, (4) exchange rate policies, and (5) other unfair practices5. The directive established the foundation for what would later be termed "Liberation Day" tariffs, creating significant market uncertainty given its potentially expansive scope.
Product coverage: Potentially all imports, subject to country-specific assessment
Upon activating Canada/Mexico tariffs, the administration faced immediate retaliation:
Canada: C$26.6 billion in countermeasures targeting U.S. steel, aluminum, and agricultural exports under Customs Tariff S.C. 1997, c. 364
Mexico: Secretaría de Economía's DOF 05-03-2025 imposed 20-30% tariffs on 54 U.S. agricultural products while strategically exempting corn and dairy to avoid inflation5
China: MOFCOM Announcement No. 2025/03 expanded its "Unreliable Entity List" to include U.S. semiconductor equipment manufacturers
These measures escalated the trade conflict, particularly with China, where tariffs doubled compared to the first administration's levels. U.S. importers with established supply chains in these countries faced immediate cost increases.
This adjustment 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.
On March 26, 2025, President Trump signed a proclamation invoking Section 232 of the Trade Expansion Act of 1962 to impose a 25% tariff on imports of automobiles and certain automobile parts, citing "a critical threat to U.S. national security". The proclamation established a complex compliance framework where importers of automobiles under USMCA would certify their US content, with the 25% tariff applying only to non-US content. A similar system would be implemented for auto parts by May.
Name of measure: "Liberation Day" Reciprocal Tariffs
Legal basis: Likely IEEPA or potentially Section 301 of the Trade Act of 1974
Date of issuance: April 2, 2025 (scheduled for announcement today)
Date of entry into force: According to White House statements, these tariffs will go into effect "immediately" upon announcement
Product coverage: Uncertain, but potentially comprehensive across trading partners
The specific details remain undefined pending today's announcement, but various sources suggest potential approaches. Administration officials have reportedly drafted a plan for 20% reciprocal tariffs on most imports. The tariffs could potentially affect $3.3 trillion in imports - nearly ten times the scale of those enacted during Trump's initial term.
From a legal perspective, these broad reciprocal tariffs may face challenges under the "major questions doctrine," which holds that administrative agencies cannot regulate matters of extraordinary economic significance without clear statutory authority from Congress. Additionally, they may be challenged under the nondelegation doctrine for potentially ceding Congress's tariff powers to the executive without sufficient constraints.
The second Trump administration has rapidly expanded the scope, scale, and legal justifications for tariffs beyond those established in the first term. While his initial administration imposed tariffs on approximately $380 billion in imports, the total under his second administration is projected to exceed $1.4 trillion by April 2025. The administration has invoked various legal authorities, including Section 232 of the Trade Expansion Act, the National Emergencies Act, and the IEEPA, pushing the boundaries of executive authority in trade policy.
For importers, exporters, and legal practitioners in international trade law, today's "Liberation Day" announcement represents a watershed moment with potentially far-reaching implications for global trade governance and the multilateral trading system established under the WTO.
From a WTO and USMCA legal perspective, many of these measures appear to conflict with US commitments, though the U.S. administration has consistently invoked national security exemptions. Under WTO jurisprudence, particularly following the December 2022 ruling against US steel and aluminum tariffs, these security justifications face increasing scrutiny from the international legal community. The reciprocal tariffs expected today may further test the boundaries of WTO-consistent trade policy and trigger additional challenges from affected trading partners.
[Note: This research report will be updated following the April 2 "Liberation Day" announcement.]
