Overview
Provided below is a status update and summary of tariffs that have been implemented since February 1, 2025, and its impacts on imports from multiple countries.
IEEPA (Fentanyl) Tariffs
IEEPA tariffs were announced on February 1, 2025 and went into effect on February 4, 2025. The current tariff burden is as follows:
- Goods with Country of Origin China (including Hong Kong) 20%
Tariff rates were originally 10% and then were increased to 20% on March 4, 2025
All goods under all HTS numbers are subject to these tariffs
- Goods with Country of Origin Canada 25%
Tariffs were paused until March 4, 2025 and went into effect on March 4, 2025
Goods qualifying for USMCA treatment are excluded effective March 7, 2025
Goods subject to Section 232 steel and aluminum tariffs or Section 232 automobile and auto parts tariffs are not subject to Canada IEEPA tariffs.
- Goods with Country of Origin Mexico 25%
Tariffs were paused until March 4, 2025 and went into effect on March 4, 2025
Goods qualifying for USMCA treatment are excluded effective March 7, 2025
Goods subject to Section 232 steel and aluminum tariffs or Section 232 automobile and auto parts tariffs are not subject to Mexico IEEPA tariffs.
Section 232 Duties on Steel and Aluminum Products and Steel and Aluminum Derivative Products
Section 232 duties on all imports of steel and aluminum subject to the HTS numbers identified in the published Federal Register notices went into effect on March 12, 2025. There are no exceptions or exclusions and all steel and aluminum as well as derivative goods are subject to these duties.
- Steel Products 50%
- Aluminum Products 50%
- Steel Derivative Products 50%
- Aluminum Derivative Products (including aluminum cans) 50%
Steel and Aluminum duties from all countries were increased to 50% on June 4, 2025.
IEEPA Universal/Reciprocal Tariffs
IEEPA Universal tariffs of 10% on imports of all goods from all countries. The tariffs went into effect on April 5, 2025, however, the escalated tariffs on specific list of 83 countries have been paused for 90 days until July 9, 2025. The U.S. and China also agreed to pause the reciprocal tariffs of 125% for 90 days.
- Goods with Country of Origin China (including Hong Kong) 10%
(125% paused for 90 days until August 12, 2025)
- Goods with Country of Origin from All Other Countries 10%
The universal/reciprocal tariffs are not applicable on the following goods which are currently subject to Section 232 duties or will be subject to Section 232 duties as part of ongoing investigations. This exemption is explicitly articulated in Section 2(b) of the Executive Order and enumerated in Annex II announcing the universal/reciprocal tariffs.
- All articles of steel or aluminum subject to Section 232 duties
- All automobiles and autoparts subject to Section 232 duties
- Certain Copper
- Certain Pharmaceuticals
- Certain Semiconductors
- Certain Lumber articles
- Certain Critical minerals
- Certain Energy and energy products
The 10% reciprocal tariff rate is similarly not applicable to goods from Mexico or Canada as those are subject to the 25% rate except for those products qualify under the USMCA for duty free treatment.
If goods are subject to Section 232 Auto/Auto Parts, then the same good is not subject to Section 232 Steel/Aluminum duties, IEEPA Canada, or IEEPA Mexico tariffs.
Tariffs and Duties Are Cumulative (Stacked)
The tariffs and duties summarized above are cumulative (i.e. stacked) and are not mutually exclusive. These rates also apply on top of any Section 301, antidumping and countervailing duties, and any normal duty rate. As a result, the duties and tariffs must be calculated as follows:
| Tariff Type | Additional Duties | Total Duty Increase |
| China | ||
| IEEPA (Fentanyl) and Universal/Reciprocal Tariffs (China) | Normal Duty + 20% + 10% | Normal Duty + 30% |
| Section 301 and IEEPA (Fentanyl) and Universal/Reciprocal Tariffs (China) | Normal Duty + 25% (301 List 1, 2, & 3) + 20% + 10% | Normal Duty + 55% |
| Section 301 and IEEPA (Fentanyl) and Universal/Reciprocal Tariffs (China) | Normal Duty + 7.5% (301 List 4) + 20% + 10% | Normal Duty + 37.5% |
| Section 232 Steel and Aluminum Duties and IEEPA (Fentanyl) Tariffs (China) | Normal Duty + 50% + 20% | Normal Duty + 70% |
| Section 232 Steel and Aluminum Derivative Duties and IEEPA and Reciprocal Tariffs (China) | Normal Duty + 50% (on steel or aluminum content only) + 20% + 10% (on non-steel and non-aluminum content) | Normal Duty + 20% + proportional steel/aluminum and non-steel and non-aluminum content |
| Section 301 and Section 232 Duties and IEEPA (Fentanyl) Tariffs (China) | Normal Duty + 25% (301 List 1, 2, & 3) + 25% + 20% | Normal Duty + 70% |
| Section 301 and Section 232 Duties and IEEPA (Fentanyl) Tariffs (China) | Normal Duty + 7.5% (301 List 4) + 25% + 20% | Normal Duty + 52.5% |
| Canada and Mexico (Not USMCA Qualifying) | ||
| IEEPA (Fentanyl) and Universal/Reciprocal Tariffs (Canada & Mexico) | Normal Duty + 25% | Normal Duty + 25% |
| Section 232 Steel & Aluminum Duties and IEEPA Tariffs (Canada & Mexico) | Normal Duty + 0% + 50% | Normal Duty + 50% |
| Section 232 Steel and Aluminum Derivative Duties and IEEPA and Reciprocal Tariffs | Normal Duty + 50% (on steel or aluminum content only) + 0% | Normal Duty + 50% |
| Section 232 Auto & Auto Parts Duties and IEEPA Tariffs (Canada & Mexico) | Normal Duty + 25% (auto & auto parts only) | Normal Duty + 25% |
| All Countries | ||
| Universal/Reciprocal Tariffs Only (All Countries) | Normal Duty + 10% | Normal Duty + 10% |
| Section 232 Steel and Aluminum Duties and Universal/Reciprocal Tariffs (All Countries) | Normal Duty + 25% + 0% | Normal Duty + 25% |
| Section 232 Steel and Aluminum Derivative Duties and Reciprocal Tariffs | Normal Duty + 50% (on steel or aluminum content only) + 10% (on non-steel and non-aluminum content) | Normal Duty + % on proportional steel/aluminum + % non-steel and non-aluminum content |
| Section 232 Auto & Auto Parts Duties and Reciprocal Tariffs | Normal Duty + 25% (auto & auto parts only) | Normal Duty + 25% |
| United Kingdom | ||
| Universal/Reciprocal Tariffs Only (UK) | Normal Duty + 10% | Normal Duty + 10% |
| Section 232 Steel and Aluminum Duties and Universal/Reciprocal Tariffs (All Countries) | Normal Duty + 25% + 0% | Normal Duty + 25% |
| Section 232 Steel and Aluminum Derivative Duties and Reciprocal Tariffs | Normal Duty + 25% (on steel or aluminum content only) + 10% (on non-steel and non-aluminum content) | Normal Duty + % on proportional steel/aluminum + % on non-steel and non-aluminum content |
| Section 232 Auto & Auto Parts Duties and Reciprocal Tariffs | Normal Duty + 25% (auto & auto parts only) | Normal Duty + 25% |
The Husch Blackwell team is continuing to monitor developments and will provide additional updates as they arise.