Trump Administration Trade Actions Timeline
China tariffs go into effect, with an additional 10% ad valorem on all imports.
A section 232 investigation is initiated on imported copper and derivative products.
A section 232 investigation is initiated on imported timber, lumber, and derivative products.
Additional China tariffs go into effect, now with 20% ad valorem on all imports.
USTR releases the Trade Policy Agenda.
Canada & Mexico tariffs are amended and special exemptions are added.
Canada and Mexico tariffs of 25%, and 10% for Canadian energy, enter into effect.
USTR public comment input period on Unfair Foreign Trade Practices closes, ahead of its review.
Section 232 tariffs of 25% on Steel and Aluminum take effect, all partner country exclusions are rescinded.
USTR public comment on proposed actions impacting the Chinese maritime, logistics, and shipbuilding sectors closes.
Section 232 investigation on timber and lumber as well as copper products public comment period closes. Comment period is active for 21 days beginning from March 10.
America First Trade Policy Agency reviews on trade deficits, unfair practices, and reciprocal tariff recommendations due.
President Trump announces new tariffs: a 10% baseline starting April 5 and individualized reciprocal rates on noncompliant trade partners from April 9. China faces stacked duties over 50% and it de minimis exemption ends May 2.
Tariffs on Chinese imports increase to 104% across the board in response to China’s retaliation to the Liberation Day reciprocal tariffs.
Liberation Day reciprocal tariffs are paused for 90 days, while China tariffs are further increased to 145% across the board.
Product exceptions and tariff adjustments are announced for a wide range of electronic devices, though they are to later be included as part of other sectoral section 232 investigations.
A section 232 investigation is initiated on pharmaceutical products and semiconductors.
Section 301 trade action on Chinese shipbuilding is reduced in scope.
A section 232 investigation is initiated on critical minerals, rare earth products, and their derivatives, as well as truck imports.
President Trump announces amendments to the tariffs set on imports of automobiles and auto parts, laying down “offsets” to a portion of the duties.
A section 232 investigation is initiated on imports of commercial aircraft and jet engines and parts for commercial aircraft and jet engines. The investigation is announced on May 13.
Section 232 investigations on semiconductors and pharmaceuticals public comments close. Comment period is active for 21 days beginning from April 16.
A trade agreement is announced between the US and the UK.
The Commerce Department will let US steel and aluminum producers request added duties on derivative products.
An amendment is announced to the duties in place on China, reducing the overall tariff rate to 30%.
Section 232 investigation on critical minerals and trucks public comment period closes. Comment period is active for 21 days beginning from April 25.
301 product exclusion expiration: the remaining 164 product duty exclusions listed under the China Section 301 will expire.
Section 232 investigation on commercial aircraft and jet engines public comment period closes. Comment period is active for 21 days beginning from May 13.
The Commerce Department will allow US auto producers to request new duties on additional auto parts not covered in the March 26 announcement.
Trade Tracker
Date | Action Date | Trade Action | Impacted Country/Industry | Description | Primary Links | McLarty Analysis |
---|---|---|---|---|---|---|
20-Jan-25 | 1-Apr-25 | Announcement | World | America First Trade Policy Memorandum: The White House releases a memorandum outlining trade priorities for the administration, directing departments and agencies to complete studies by April 1, 2025. | America First Trade Policy | America First Trade Policy |
26-Jan-25 | 26-Jan-25 | Action Rescinded | Colombia | US tariffs on Colombia on hold: A Colombian order to not accept deportations from the US leads Trump to threaten to impose a 25% tariff on all Colombian goods. Shortly thereafter, the WH announces that the Colombian government agreed to Trump's terms. The emergency tariff on Colombia is held "in reserve" in case the country fails to honor its agreement with the United States. | Trump threatens action on Colombia | Trump reverses course on Colombia tariffs |
26-Jan-25 | 26-Jan-25 | Action Rescinded Retaliation | United States | Colombian tariffs on the US on hold: Following Colombian President Petro's order to retaliate with a 25% tariff on US goods, a Colombian government statement announces that Colombia and the United States had overcome this "impasse" and agreed to continue accepting deportations from the US. | Colombia announces resolution of tariff dispute | Trump reverses course on Colombia tariffs |
1-Feb-25 | 4-Feb-25 | Announcement | Canada | Tariffs on Canada, Mexico, and China: Trump issues executive orders and a fact sheet announcing tariffs on Canada, Mexico, and China from February 4. The orders would also end duty-free de minimis treatment of low-value packages from these countries. Canada's Trudeau announces that retaliation towards the US will go into effect if US tariffs go forward. | Imposing Duties to Address the Situation at Our Nothern Border | IEEPA Tariff Announcement Memo |
1-Feb-25 | 4-Feb-25 | Announcement | China | Tariffs on Canada, Mexico, and China: Trump issues executive orders and a fact sheet announcing tariffs on Canada, Mexico, and China coming February 4. The orders would also end duty-free de minimis treatment of low-value packages from these countries. Canada's Trudeau announces that retaliation on the US will go into effect if US tariffs go forward. | Imposing Duties to Address Synethic Opiod Supply Chain of PRC | IEEPA Tariff Announcement Memo |
1-Feb-25 | 4-Feb-25 | Announcement | Mexico | Tariffs on Canada, Mexico, and China: Trump issues executive orders and a fact sheet announcing tariffs on Canada, Mexico, and China coming February 4. The orders would also end duty-free de minimis treatment of low-value packages from these countries. Canada's Trudeau announces that retaliation on the US will go into effect if US tariffs go forward. | Imposing Duties to Address the Situation at Our Southern Border List of US products to Canada subject to tariffs (PAUSED) | IEEPA Tariff Announcement Memo |
3-Feb-25 | 4-Mar-25 | Paused Action | Mexico | Tariffs on Mexico on hold: Mexico’s Sheinbaum posts on X that US tariffs are on hold for one month after Mexico agrees to send more National Guard members to the southwest border and the US agrees to work on reducing weapons shipments to Mexico. The White House confirms in an executive order. | Progress on the Situation At Our Southern Border | IEEPA Tariff Update Memo |
3-Feb-25 | 4-Mar-25 | Paused Action | Canada | Tariffs on Canada on hold: Canada’s Trudeau posts on X that the tariffs are on hold for 30 days, as Canada implements its plan to secure the northern border to address fentanyl trafficking. The White House confirms in an executive order. | Progress on the Situation at Our Northern Border | IEEPA Tariff Update Memo |
4-Feb-25 | 4-Feb-25 | Duties in Effect | China | Tariffs on China go into effect, attempted end of duty-free de minimis packages from China: The US imposes 10% tariffs on imports from China announced February 1. The US also ends de minimis treatment of low-value packages from China receiving zero tariffs. | Implementation of Duties FRN | IEEPA Tariff Update Memo |
4-Feb-25 | 10-Feb-25 | Retaliation | US | China retaliates: China announces retaliatory 15% tariffs on coal and liquefied natural gas (LNG) and 10% tariffs on crude oil, agricultural machinery and large-engine vehicles, set to go in effect on February 10. China also expands its export restrictions on critical minerals, notably for items and technologies related to tungsten, tellurium, bismuth, molybdenum and indium, places two US companies on its sanctions list, and targets one with an antitrust probe. Chinese tariffs take effect on February 10. | 国务院关税税则委员会关于对原产于美国的部分进口商品加征关税的公告 | China Responds to IEEPA Tariffs Memo China’s Unreliable Entity List – Implications for PVH |
5-Feb-25 | 5-Feb-25 | Action Rescinded | China | Duty-free de minimis packages from China restored: The US amends the February 1 executive order to temporarily restore duty-free treatment of low-value shipments from China due to administrability concerns. The US vows to create a system to eventually administer this action. | AMENDMENT TO DUTIES ADDRESSING THE SYNTHETIC OPIOID SUPPLY CHAIN IN THE PEOPLE’S REPUBLIC OF CHINA | De Minimis Action Memo |
10-Feb-25 | 12-Mar-25 | Announcement | World | Tariffs on steel and aluminum: Trump issues one proclamation imposing 25% import tariffs on steel and a separate proclamation imposing 25% tariffs on aluminum as of March 12, 2025, adjusting the Section 232 tariffs on those metals first imposed in March 2018. All partner country steel and aluminum tariff exclusions are rescinded, this includes Australia, South Korea, Canada, Mexico, Brazil, Japan, Ukraine, the United Kingdom, and the European Union. No new company exclusions are accepted, but a new process is to be established by May 11, 2025 to petition for expanded tariff protections on derivative products. Existing derivative exclusions will remain valid until their expiration date or quota limit is reached. Modified product exclusions go into effect for derivative steel products processed in another country if originated from steel articles that were melted and poured in the US, and aluminum articles originally smelted and cast in the US. | Adjusting Imports of Steel into The United States Adjusting Imports of Aluminum into The United States | McLarty Update on Section 232 Steel and Aluminum 3.11.2025 McLarty Steel and Aluminum Section 232 Memo |
13-Feb-25 | 1-Apr-25 | Announcement | World | Reciprocal Trade and Tariffs Memorandum: The White House releases a memorandum, fact sheet, and statement defining the problem and outlining the Trump administration’s plan to counter nonreciprocal trading arrangements. | Reciprocal Trade and Tariffs | Fair and Reciprocal Trade Memo |
13-Feb-25 | Backdated: 1-Feb-25 | Tariff Adjustments | India | US and India announce "trade package": Among a number of announcements, Trump and Modi agree to negotiate a first tranche of a multi-sector market access "Bilateral Trade Agreement" by Fall 2025. As part of India's budget procedure, India lowers tariffs on US bourbon, motorcycles, ICT products and metals, and enhances market access for alfalfa, hay, duck meat, LNG, and medical devices. | Trump-Modi Joint Announcement India 2025-2026 Budget | Modi-Trump Summit Memo |
20-Feb-25 | DUE 11-Mar-2025 | Public Comment | World | Public Comment period on Unfair and Non-Reciprocal Foreign Trade Practices: USTR invites comments from the public as part of its work pursuant to the America First Trade Policy Presidential Memorandum and the Reciprocal Trade and Tariffs Presidential Memorandum. These comments assist the US Trade Representative in reviewing and identifying any unfair trade or non-reciprocal foreign trade practices. Deadline for submission: March 11, 2025. | Federal Register Notice | |
21-Feb-25 | None Listed | Announcement | World | America First Investment Policy Memorandum: The White House releases a memorandum and fact sheet on the administration’s policy toward inbound foreign direct investment, especially from adversaries such as China, that includes a “fast track” policy for investment from specified partners and allies. | America First Investment Policy | Digital Trade and America First Investment Policy Memo |
21-Feb-25 | None Listed | Announcement | China | America First Investment Policy Memorandum: The White House releases a memorandum and fact sheet on the administration’s policy toward inbound foreign direct investment, especially from adversaries such as China, that includes a “fast track” policy for investment from specified partners and allies. | America First Investment Policy | US-China Investment Memo |
21-Feb-25 | 1-Apr-25 | Announcement | Austria, Canada, European Union, France, Italy, Spain, Turkey, UK | Defending American Companies and Innovators From Overseas Extortion and Unfair Fines and Penalties Memorandum: The White House releases a memorandum and fact sheet articulating concerns with foreign treatment of US digital companies, especially by the European Union, requesting the US Trade Representative to re-examine any digital services taxes (DSTs) of Austria, France, Italy, Spain, Turkey, and the United Kingdom under Section 301 of the Trade Act of 1974, and considering a formal USMCA dispute against Canada. | Defending American Companies and Innovators From Overseas Extortion and Unfair Fines and Penalties | Digital Trade and America First Investment Policy Memo |
21-Feb-25 | Due 24-Mar-25 | Public Comment; Public Hearing | Shipbuilding | Public Hearing on Section 301 Shipbuilding Investigation: USTR invites members of the public to request to appear at the 301 proposal ITC hearing on March 24, 2025. Deadline to apply: March 10, 2025. USTR also invites public comment on proposed actions impacting the Chinese maritime, logistics, and shipbuilding sectors. | USTR 301 Shipbuilding Public Comment Federal Register Notice | USTR PRC Shipbuilding Memo USTR PRC Shipbuilding Memo |
25-Feb-25 | 25-Feb-25 | Investigation | Copper | Copper Section 232 Investigation: President Trump directs the Secretary of Commerce to initiate a Section 232 investigation on imported copper and its derivative products. | Addressing the Threat to National Security From Imports of Copper | |
1-Mar-25 | 1-Mar-25 | Investigation | Timber and Lumber | Timber and Lumber Section 232 Investigation: President Trump directs Secretary of Commerce to initiate a Section 232 investigation on imported timber, lumber, and their derivative products. | Addressing the Threat to National Security from Imports of Timber, Lumber | |
2-Mar-25 | 4-Mar-25 | Action Rescinded | Mexico | Amendment to de minimis exemption action: Ahead of the March 4 Mexico and Canada tariff implementation date, the US amends the February 4 executive order to continue duty-free treatment of low-value shipments from Mexico and Canada due to administrability concerns, regardless of tariff implementation outcome. The US vows to create a system to eventually administer this action. | Amendment to Duties on Southern Border | |
2-Mar-25 | 4-Mar-25 | Action Rescinded | Canada | Amendment to de minimis exemption action: Ahead of the March 4 Mexico and Canada tariff implementation date, the US amends the February 4 executive order to continue duty-free treatment of low-value shipments from Mexico and Canada due to administrability concerns, regardless of tariff implementation outcome. The US vows to create a system to eventually administer this action. | Amendment to Duties on Northern Border | |
3-Mar-25 | 3-Mar-25 | Announcement | World | 2025 Trade Policy Agenda: USTR releases Congressionally-mandated report on the 2025 Trade Policy Agenda and the 2024 Annual Report. | 2025 Trade Policy Agenda and 2024 Annual Report | |
3-Mar-25 | 3-Mar-25 | Duties in Effect | China | Additional Tariffs on China go into effect: The US imposes an additional 10% tariff on imports from China announced March 3, effective immediately. At this date, the US has raised ad valorem tariffs under IEEPA on China by 20% since February 4, 2025. | Further Amendment to Duties Addressing the Synethic Opioid Supply Chain in the PRC | March 4 Trade Action Memo |
4-Mar-25 | 4-Mar-25 | Duties in Effect | China | US tariff rate change for China: Effective on or after 12:01AM March 4, goods entering the US for consumption or leaving warehouses for the US border are hit with a 20% tariff. | Federal Register Notice | |
4-Mar-25 | 10-Mar-25 | Retaliation | US | China retaliates: In response to the US' March 3 action, China announces a slew of tariff and non-tariff retaliatory measures. In total, the tariffs impact $22 Billion USD in value of US agricultural exports to China. China raises tariffs by 15% or 10% depending on the US product. Products that leave US ports BEFORE March 10 12:01AM and arrive in China by April 12, 2025 are not impacted. This duty applies to all products departing the US dated on or after March 10, 2025. Non-tariff barriers include adding US companies to the Unreliable Entities List, prohibiting imports from certain US companies, adding 15 US-based companies to dual-use export control lists, an AD/CVD case against US optical fiber products, and license / import suspensions on several US soybean companies and US log products. | PRC Retaliatory Duties Announcement Chinese List of US Imports Receiving 15% Tariff Chinese List of US Imports Receiving 10% Tariff | |
4-Mar-25 | 4-Mar-25 | Duties in Effect | Mexico | Tariffs on Canada and Mexico: Effective as of 12:01AM on March 4, President Trump implements 25% tariffs on ALL goods from Mexico and 25% tariffs on ALL goods from Canada, with the exception of energy products from Canada that are hereby tariffed at a 10% ad valorem rate. Two FRN notices by CBP are online with formal publishing completed by March 6. These tariffs are issued under USMCA Chapter 99 authority for temporary increases in tariffs. The Trump Administration states that tariffs will remain in effect until "drugs, in particular fentanyl, and all illegal aliens stop the invasion of our country." | Fact Sheet on US Tariffs on Canada and Mexico CBP Public Notice on Mexico Tariffs | March 4 Trade Action Memo |
4-Mar-25 | 4-Mar-25 | Duties in Effect | Canada | Tariffs on Canada and Mexico: Effective as of 12:01AM on March 4, President Trump implements 25% tariffs on ALL goods from Mexico and 25% tariffs on ALL goods from Canada, with the exception of energy products from Canada that are hereby tariffed at a 10% ad valorem rate. Two FRN notices by CBP are online with formal publishing completed by March 6. These tariffs are issued under USMCA Chapter 99 authority for temporary increases in tariffs. The Trump Administration states that tariffs will remain in effect until "drugs, in particular fentanyl, and all illegal aliens stop the invasion of our country." | CBP Public Notice on Canada Tariffs | |
4-Mar-25 | 4-Mar-25 | Retaliation | US | Canada retaliates: Effective as of 12:02AM on March 4, Prime Minister Trudeau implements 25% tariffs on $20.8 Billion USD in value on select imported US goods. The list of tariffed goods are available in primary links. Trudeau states that an additional $86.4 billion USD in value of imported US goods are to be subject to retaliation after 21 days if a detente is not reached. | Canadian List of US Imports Receiving 25% Tariff | |
6-Mar-25 | 7-Mar-25 | Tariff Adjustments | Mexico, Canada | IEEPA Tariff Amendment: Goods from Canada or Mexico that qualify for US-Mexico-Canada Origin Certification, also known as General Note 11 of the Harmonized Tariff Schedule of the United States (HTSUS), and goods that receive “special classification status” are tariff exempt. This accounts for roughly 50% of imports from Mexico and 38% from Canada, according to White House officials. Mexico announces that it no longer plans to retaliate. | Fact Sheet and Exclusion Mexico Tariff Amendment | March 6 Policy Pivot Memo |
6-Mar-25 | 7-Mar-25 | Tariff Adjustments | Canada | Special Exclusions: Duty exclusion for the automotive sector and a reduced tariff rate to 10% for non-eligible origin certification potash is included. | Canada Tariff Amendment Mexican President Response | March 6 Policy Pivot Memo |
12-Mar-25 | 12-Mar-25 | Duties in Effect | World | Section 232 Steel and Aluminum Tariffs: All partner special exclusions are revoked. World-wide 25% tariffs on steel and aluminum go into effect, including derivative products. | CBP Bulletin on Steel CBP Bulletin on Aluminum | McLarty Steel and Aluminum Section 232 Memo |
12-Mar-25 | 13-Mar-25 | Retaliation | US | Canada retaliates again: Effective as of 12:01AM on March 13, Canada implements 25% tariffs on $21 Billion USD in value on select US steel, aluminum, computers, sports equipment, and cast iron goods. The full list of tariffed goods are available in primary links. Canada lists that these specific retaliatory duties are to remain in effect until the US drops the 25% steel and aluminum tariffs. | List of additional Canadian retaliatory tariffs | |
12-Mar-25 | 13-Apr-25 | Retaliation (MERGED) | US | The European Union retaliates: The European Union will lapse the suspension of 2018 and 2020 announced retaliatory tariffs on the US. Worth approximately $4.9 billion USD, the tariff lines on these products range in value between 10-50% on notable US products like motorcycles, bourbon, peanut butter and jeans. As of 3/21, the EU pushed this retaliation back from April 1 to on or around April 13. | List of April EU Retaliatory Duties | |
12-Mar-25 | Mid-Apr-25 | Retaliation (MERGED) | US | The European Union further retaliates: Open for comment period through March 26, the European Union provides a provisional list of goods worth approximately $23 billion USD ($28 billion total retaliation). The EU signals it is likely to announce finalized tariff rates on specific goods that should take effect in mid-April. | EU List of Provision Goods Set for Retaliation | |
24-Mar-25 | 2-Apr-25 | Announcement | World | Venezuela "Secondary Tariffs": Countries that directly or indirectly import oil (crude or petroleum products) from Venezuela on or after April 2, 2025 12:01AM may be subject to 25% tariffs imposed on all of their goods exported to the United States, at the specific discretion of the Secretary of State. Once a target country is determined, the tariffs can last up to one year before expiration. | White House Proclamation on Venezuelan Oil | |
26-Mar-25 | 3-Apr-25 | Duties in Effect | Autos | Section 232 Autos Tariffs: Effective 12:01AM on April 3, a 25% tariff is applied to all imported passenger vehicles and light trucks that are non-USMCA compliant. USMCA compliant vehicles and auto parts are to be tariffed once the Secretary of Commerce can establish a process to apply the tariff only to the non-US part of the North American content. | White House Proclamation on Auto and Auto Parts | |
26-Mar-25 | 3-May-25 | Duties in Effect | Auto Parts | (Amended) Section 232 Auto Parts Tariffs: Effective 12:01AM on May 3, a 25% tariff is slated to be applied to all "key auto parts" listed in the Federal Register Notice HTS code listing. Within 90 days of March 26, a process is to be established to include additional articles of the "key parts" mentioned in the FRN, as well as a new process to submit additional automobile parts to be tariffed per the request of domestic producers based on national security concerns. | Federal Register Notice on Autos and Auto Parts | |
31-Mar-25 | 31-Mar-25 | Announcement | World | NTE Report Released: USTR releases annual NTE report that tracks tariff and non-tariff barriers with almost all of the countries in the world. | 2025 NTE Report | |
2-Apr-25 | 2-Apr-25 | "Liberation Day" Announcement Duties in Effect | World | Liberation Day Announcement: President Trump announces that after a review of US free trade arrangements and tariff barriers, foreign trade and economic practices have created a “national emergency.” In reaction to these challenges, President Trump announces a series of tariff adjustments to rebuild the economy and restore economic security. President Trump may decrease or eliminate individualized tariffs on countries who change trading practices that “remedy non-reciprocal arrangements” or “align with US national security.” He also may increase duties against noncompliant partners. | Liberation Day Executive Order | McLarty Liberation Day Fact Sheet |
2-Apr-25 | 5-Apr-25 | "Liberation Day" Announcement Duties in Effect | World | New Baseline Tariffs: Citing IEEPA authority, President Trump will impose a 10% tariff on all countries (in addition to each country's MFN rate) that goes into effect April 5, 2025, at 12:01AM. | Liberation Day Fact Sheet CBP Bulletin on April 5 Administrability | McLarty Liberation Day Analytical Memo |
2-Apr-25 | 9-Apr-25 | "Liberation Day" Announcement Duties in Effect | World | (PAUSED) Individualized Reciprocal Rates: Also using IEEPA authority, President Trump will impose individualized reciprocal higher tariff rates on countries with higher tariff bound rates, non-tariff barriers, and perceived currency manipulation that will go into effect April 9, 2025, at 12:01AM. | Tariff Breakdown by Country Reciprocal Rate Methodology | McLarty Country Reactions and Retaliation Memo |
2-Apr-25 | 9-Apr-25 | "Liberation Day" Announcement Duties in Effect | China | Stacking IEEPA Rates for China: Unlike Canada and Mexico, the new 34% individualized reciprocal rate is to stack on top of 20% IEEPA tariffs on China levied by President Trump, and specific product-level 301 duties set by Presidents Trump and Biden over the last several years. | Further Amendment to Addressing Synthetic Opioid Emergency in China | |
2-Apr-25 | 9-Apr-25 | "Liberation Day" Announcement Duties in Effect | Canada, Mexico | Original IEEPA Actions Kept in Place: Unlike for China, President Trump opts not to stack new IEEPA tariffs for Canada and Mexico. USMCA compliant goods are also subject to reciprocal tariff exclusions. Meanwhile, non-USMCA compliant goods will continue to see a 25% tariff and non-USMCA compliant energy and potash will see a 10% tariff. If current fentanyl and migration IEEPA tariffs are terminated, non-USMCA compliant goods will be subject to a 12% tariff. | Liberation Day Executive Order | |
2-Apr-25 | 2-May-25 | "Liberation Day" Announcement Duties in Effect | China, Hong Kong | Revoking De Minimis for China: The de minimis exemption for goods valued under $800 USD per person, per day, ends for China and Hong Kong-originated goods on May 2, 2025. Additional rates are applied for packages through the postal service on June 1, 2025. | De Minimis Factsheet | |
2-Apr-25 | 4-Apr-25 | "Liberation Day" Announcement Duties in Effect | Steel and Aluminum | Amendment to Steel and Aluminum Duties: A 25% tariff is added on beer and empty aluminum cans, effective 12:01AM ET on April 4. | Amendment to Steel and Aluminum Duties | |
2-Apr-25 | 5-Apr-25 | "Liberation Day" Announcement Duties in Effect | Emergency Relief Products; Steel/Aluminum; Autos/Auto Parts; Copper; Pharmacueticals; Semiconductors; Lumber; Bullion; Energy; Critical Minerals not available in U.S. | Product and Sector Exclusions: Exclusions for these new duties are made available for select products, including those already subject to ongoing Section 232 investigations, energy and critical minerals not found in the US, bullion, products compliant with USMCA rules, and humanitarian articles, among others. See primary link for all products. | Executive Order Product Exclusions ANNEX II Executive Order Product Exclusions ANNEX III | |
3-Apr-25 | May 2025 | Announcement | United States | United Kingdom prepares retaliation list: Despite taking an approach prioritizing negotiation, the UK government asks businesses and stakeholders to provide input for potential retaliatory actions, and provides a list of US products that could be in scope for retaliatory tariffs. Deadline for responding to the consultation: May 1. | List of Potential UK Retaliation | |
3-Apr-25 | 3-Apr-25 | Announcement | World | America First Trade Policy Report: The Trump Administration releases the executive summary of the America First Trade Policy report, which details progress-to-date and what lies ahead. | America First Trade Policy Executive Summary | Analysis on AFTP Report |
4-Apr-25 | 10-Apr-25 | Retaliation (MERGED) | United States | China retaliates to Liberation Day reciprocal tariffs: Mirroring the US amount, China announces a 34% ad valorem tariff on all US goods. Before 12:01 on April 10, 2025, if the goods are shipped from the place of departure and imported from 12:01 on April 10, 2025 to 24:00 on May 13, 2025, the additional tariffs stipulated in this announcement are not levied. Additional export controls and investigations into US companies operating in China are also initiated. For more information see McLarty analysis. | Reciprocal Tariff Announcement from Chinese Customs Tariff Commission | China Retaliation Memo |
8-Apr-25 | 9-Apr-25 | Retaliation | Auto Parts | Canada retaliates on Autos: Effective 12:01AM ET on April 9, Canada imposes 25% tariffs on non-USMCA compliant US-made vehicles, and mirroring the US, also tariffs non-Canadian and non-Mexican content of USMCA-compliant US made vehicles. The retaliation is telegraphed by the Canadian government on April 3rd. | Canadian List of Vehicle Products Subject to Tariffs | |
8-Apr-25 | 9-Apr-25 | Duties in Effect | China | Additional increase on IEEPA China tariffs: Responding to China's retaliation, President Trump increases the "Liberation Day" tariff amount from 34% to 84%, making the total IEEPA rate imposed on China at this date equal to 104%. | Further Amendment to IEEPA China Tariffs | |
9-Apr-25 | 10-Apr-25 | Retaliation | United States | Additional retaliatory tariffs on US: China mirrors President Trump's April 8 action by raising the US tariff rate from 34% to 84%. For products listed in retaliatory categories linked to the fentanyl IEEPA tariffs, specific energy and agricultural products from the United States are subject to tariffs upwards of 84%. | Additional Announcement from Chinese Customs Tariff Commission | China Trade War Escalation Memo |
9-Apr-25 | 15-Apr-25; 15-May-25; 1-Dec-25 | Retaliation (PAUSED) | United States | (Action paused for 90 days) EU Retaliates on Steel and Aluminum: The European Union approves an amended retaliatory package in response to US tariffs on steel and aluminum. This amended package excludes politically sensitive products, like bourbon, but is to come in three tranches. The first tranche, comparatively small, is to be put into effect on April 15. The second tranche, which will be the majority of the retaliatory package, is to go into effect May 15, with the third package going into effect December 1, which is to only be comprised of seasonal agricultural products. As of 4/9, the final HTS code breakdown of each tranche is not finalized, but is likely to mirror the package proposed as part of the suspended 2018 steel and aluminum tariff response (noted above). At this date, Europe is expected to put another batch of retaliatory tariffs up to a vote, responding to autos and "liberation day," sometime in mid-May. | Statement from EU Commission President | |
9-Apr-25 | 9-Apr-25 | Paused Action | World | Reciprocal tariffs paused for 90-days: Rescinding what had gone into effect the same morning, all countries (except for one) receive a 90-day reprieve from reciprocal tariffs pending the negotiation of bilateral agreements. Secretary of Treasury Bessent states that Vietnam, India, South Korea and Japan are the first countries to begin formal negotiations. | Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment | 90-Day Reciprocal Tariff Pause Analysis |
9-Apr-25 | 10-Apr-25 | Duties in Effect | China | Another Additional increase on IEEPA China tariffs: As part of the pause announcement for other countries, China is subjected to an immediate additional tariff increase of 21%, up to 125% for the Liberation Day tariffs, bringing the total across-the-board tariff rate on Chinese goods to 145%. | CBP Updated Guidance for China April 10 | |
11-Apr-25 | 12-Apr-25 | Retaliation | United States | Further retaliatory tariffs on US: China mirrors President Trump's April 9 action by raising the US tariff rate from 84% to 125%. For products listed in retaliatory categories linked to the fentanyl IEEPA tariffs, specific energy and agricultural products from the United States are subject to tariffs upwards of 125%. | Further Amendment from China Customs Tariff Commission | |
11-Apr-25 | (Backdated) 5-Apr-25 | Tariff Adjustments | Electronics, Semiconductors | Product Exceptions and Tariff Adjustments: CBP issues an updated guidance on product exclusions from President Trump's reciprocal tariffs, imposed under Executive Order 14257 and its amendments (EO 14259). The exclusions cover a wide range of electronic devices, including computers, computer components, semiconductor manufacturing equipment, telecommunication devices, and solid-state memory products. These products are exempted because the White House intends to investigate them as part of a later 232 investigation on semiconductors and IT-related products. Products that fall into these categories that incurred duties at the border between April 5 - April 11 may be reimbursed. See CBP for more details. | Clarification of Exceptions for Liberation Day CBP Bulletin on Adjustments | |
14-Apr-25 | 16-Apr-25 | Investigation | Semiconductors | Section 232 Semiconductor investigation: Secretary of Commerce Howard Lutnick announces a Section 232 national security investigation concerning semiconductor products through a notice in the federal register set for formal release on April 16. Public comment on these investigations is made available for 21 days following the scheduled publication, to inform Commerce’s reports that will determine whether the import of both products, and their key inputs and respective derivatives, threatens or impairs US national security. Products listed in the April 11 electronics and semiconductor exceptions are likely to be in the scope of this investigation. | Semiconductor 232 Investigation FRN | Pharma and Semiconductor 232 Investigation Announcement Memo |
14-Apr-25 | 16-Apr-25 | Investigation | Pharmaceuticals | Section 232 Pharmaceutical investigation: Secretary of Commerce Howard Lutnick announces a Section 232 national security investigation concerning pharmaceutical products through a notice in the federal register set for formal release on April 16. Public comment on these investigations is made available for 21 days following the scheduled publication, to inform Commerce’s reports that will determine whether the import of these products, and their key inputs and respective derivatives, threatens or impairs US national security. | Pharmacuetical 232 Investigation FRN | Pharma and Semiconductor 232 Investigation Announcement Memo |
15-Apr-25 | 22-Apr-25 | Investigation | Critical Minerals | Section 232 Critical Minerals investigation: President Trump announces a Section 232 national security investigation concerning critical minerals, rare earth elements, processed critical minerals and their derivative products through an Executive Order. The Secretary of Commerce initiates the investigation through a formal release on the Federal Register Notice on April 22. Public comment on these investigations is made available for 21 days following the scheduled publication, to inform Commerce’s reports that will determine whether the import of these products, and their key inputs and respective derivatives, threatens or impairs US national security. | Critical Minerals 232 Investigation EO Critical Minerals 232 Investigation FRN | Pharma and Semiconductor 232 Investigation Announcement Memo |
16-Apr-25 | 7-May-25 | Public Comment | Semiconductors | Public Comment period on semiconductor investigation: DOC invites comments from the public as part of its work pursuant to the Section 232 semiconductor investigation. These comments assist the DOC in reviewing and identifying any harm or threats to US national security. Deadline for submission: May 7, 2025. | Link to submit comment | Pharma and Semiconductor 232 Investigation Announcement Memo |
16-Apr-25 | 7-May-25 | Public Comment | Pharmaceuticals | Public Comment period on pharmaceutical investigation: DOC invites comments from the public as part of its work pursuant to the Section 232 pharmaceutical investigation. These comments assist the DOC in reviewing and identifying any harm or threats to US national security. Deadline for submission: May 7, 2025. | Link to submit comment | Pharma and Semiconductor 232 Investigation Announcement Memo |
17-Apr-25 | 19-May-25 | Public Comment | Shipbuilding | Public Comment period on ship-to-shore cranes and other cargo handling equipment: USTR invites comments from the public on the proposed tariffs on ship-to-shore cranes and other cargo handling equipment, in line with the President’s Maritime Executive Order. Deadline for submission: May 19, 2025. | Link to submit comment | |
17-Apr-25 | 14-Oct-25 | Duties in Effect | Shipbuilding | Targeted action on Chinese vessels: Fees will increase from $0 on vessel owners and operators from China based on net tonnage per US voyage, on operators of Chinese-built ships based on net tonnage or containers, and on foreign-built car carrier vessels based on their capacity. It increases incrementally over the next three years. Details on fee increases can be found in the Federal Register Notice. | Federal Register Notice of Action | |
17-Apr-25 | 17-Apr-28 | Duties in Effect | Shipbuilding | Targeted action on transporting LNG via foreign vessels: After three years, the USTR will impose a restriction to require the use of US vessels for the maritime transport of certain percentages of LNG exports. Details can be found in the Federal Register Notice. | Federal Register Notice of Action | |
22-Apr-25 | 22-Apr-25 | Investigation | Autos (trucks) | Section 232 truck imports investigation: Secretary of Commerce Howard Lutnick announces a Section 232 national security investigation concerning the import of trucks through a notice in the federal register. The investigation serves to determine the effects on national security of the import of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts, and their derivative products. | Trucks 232 Investigation FRN | |
25-Apr-25 | 16-May-25 | Public Comment | Critical Minerals | Public Comment period on critical minerals investigation: DOC invites comments from the public as part of its work pursuant to the Section 232 critical minerals investigation. These comments assist the DOC in reviewing and identifying any harm or threats to US national security. Deadline for submission: May 16, 2025. | Link to Submit Comment | |
25-Apr-25 | 16-May-25 | Public Comment | Autos (trucks) | Public Comment period on truck imports investigation: DOC invites comments from the public as part of its work pursuant to the Section 232 truck imports investigation. These comments will assist the DOC in reviewing and identifying any harm or threats to US national security. Deadline for submission: May 16, 2025. | Link to Submit Comment | |
29-Apr-25 | (Backdated) 3-Apr-25 | Announcement | Auto parts | Amendment to Auto and Auto Parts Tariffs: President Trump announces an amendment to adjusting imports of automobiles and their parts into the US. The order "offers an offset" to a portion of tariffs for automobile parts used in US-assembled vehicles equal to 3.75% of the Manufacturer’s Suggested Retail Price (MSRP) of a manufacturer’s US production for the next year (April 3, 2025 to April 30, 2026), and 2.5% of US production the year after (May 1, 2026 to April 30, 2027). The offset is variable on US-assembled content, using 15% of the value of a US-assembled automobile for a 25% tariff on autos. | Amendments to Adjusting Imports of Automobiles and Automobile Parts Into the United States | |
8-May-25 | 8-May-25 | Trade Agreement | UK | Trade Agreement announced with the UK:: President Trump and Prime Minister Starmer announce a trade agreement has been reached between the US and the UK, the first to be struck after the April 2nd Liberation Day announcements and subsequent 90-day tariffs pause. The 10% baseline reciprocal tariffs stay in effect, but the US ends the Section 232 steel and aluminum tariffs on British exports to the US and reduces automobile duties. The UK will also buy $10 billion worth of Boeing airplanes, while Rolls-Royce engines are to receive tariff free entry into the US. The UK is set to receive "preferential treatment" in any further tariffs imposed. In return, the UK opens its market to American beef, poultry, ethanol, soft drinks and other products. | Fact Sheet: US-UK Reach Historic Trade Deal | McLarty US-UK Trade Deal Memo |
11-May-25 | 11-May-25 | Product Process | Steel and Aluminum | Product process for Steel and Aluminum: DOC establishes a process allowing US steel and aluminum producers, as well as industry associations representing them, to request the inclusion of additional duties on steel and aluminum derivative products. | Federal Register Notice | |
12-May-25 | 12-May-25 | Announcement | China | Amendment to US-China Tariffs: The US and China made a joint announcement on May 12 after senior economic and trade leaders met in Geneva for trade talks over the weekend. In a 90-day détente, the two sides agreed to reduce US “reciprocal” tariffs and Chinese retaliatory duties both to 10% from previous 125%. China also agreed to “adopt all necessary administrative measures to suspend or remove the non-tariff countermeasures” against the US since April 2, without elaborating. The 20% US fentanyl-related tariffs remain unchanged. China’s retaliatory tariffs imposed on US crude oil, coal, LNG and other products in response to this step are also expected to stay. The US and China will establish a mechanism to conduct discussions about economic and trade relations alternately in China and the US, or a third country. | White House Statement | McLarty US-China Trade Deal Memo |
13-May-25 | (Backdated) 1-May-25 | Investigation | Commercial Aircraft and Jet Engines | Section 232 Commercial Aircraft and Jet Engines investigation: Secretary of Commerce Howard Lutnick announces a Section 232 national security investigation concerning imports of commercial aircraft and jet engines and parts for commercial aircraft and jet engines through a notice in the federal register. The notice announces the 232 investigation began on May 1. | Commercial Aircraft and Jet Engines Section 232 FRN | |
13-May-25 | 3-Jun-25 | Public Comment | Commercial Aircraft and Jet Engines | Public Comment period on Commercial Aircraft and Jet Engines investigation: DOC invites comments from the public as part of its work pursuant to the Section 232 national security investigation concerning imports of commercial aircraft and jet engines and parts for commercial aircraft and jet engines. These comments assist the DOC in reviewing and identifying any harm or threats to US national security. Deadline for submission: June 3, 2025. | Link to submit comment | |
31-May-25 | 31-May-25 | Program Expiration | China | 301 product exclusion expiration: The remaining 164 product duty exclusions listed under the China Section 301 expire. | Section 301 Product Exclusion Expiration | |
24-Jun-25 | 24-Jun-25 | Product Process | Auto Parts | Product process for Auto Parts: DOC establishes a process allowing US auto producers, as well as industry associations representing them, to request the inclusion of new duties on additional auto parts or their derivative products not already included in the March 26 Section 232 announcement. | White House Proclamation | |
12-Aug-25 | 12-Aug-25 | Announcement | World | OMB report: The Office of Management and Budget issues a public report on the fiscal impacts of unfair or non-reciprocal trade, including non-tariff barriers. | EO on Fair and Reciprocal Trade | |
30-Sep-25 | 30-Sep-25 | Program Expiration | Haiti | Haiti HOPE-HELP expires: If Congress does not renew or revise the program through legislation, Haiti loses duty-free access for certain apparel and textile products. | Haiti HOPE/HELP Program | |
30-Sep-25 | 30-Sep-25 | Program Expiration | Sub-Saharan Africa | Africa Growth and Opportunity Act (AGOA) expires: If Congress does not renew or revise the program through legislation, the duty-free Sub-Saharan African trade preference program is terminated, impacting US market access for 32 African countries. | AGOA Program Information |