On April 2, 2025, as part of a "Liberation Day" ceremony in the White House Rose Garden, U.S. President Donald Trump signed an executive order imposing wide-ranging tariffs on imports from virtually every country in the world (the "Tariff Executive Order"). The Tariff Executive Order imposes a baseline 10 percent tariff for all countries and a so-called "discounted reciprocal tariff" for approximately 60 countries with which the United States has the largest trade deficits. Notably, certain goods that are subject to Section 232 tariffs, such as steel and aluminum products, are exempt from the tariffs, as well as imports from Canada and Mexico that are eligible for entry under the U.S.-Mexico-Canada Agreement ("USMCA"). The baseline tariffs are effective on April 5, 2025, while the reciprocal tariffs are effective on April 9, 2025.
President Trump also signed an executive order eliminating the duty-free de minimis exemption for imports from China valued at or under $800 (the "De Minimis Executive Order").
The move comes after President Trump's imposition of tariffs on imports from Canada, Mexico, and China and on certain economic sectors, such as automobiles and steel and aluminum products.
The key details of the tariffs are as follows:
Legal Authority:
International Emergency Economic Powers Act ("IEEPA"). In the Tariff Executive Order, President Trump declared a national emergency with respect to the foreign trade and economic practices of U.S. trading partners. President Trump relied on his authority under IEEPA to address this declared national emergency through the imposition of tariffs.
Tariff Rates:
Baseline Tariffs
A 10 percent ad valorem baseline tariff will be imposed on imports of all foreign-origin goods.
The baseline tariff will apply to all goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 5, 2025. However, goods that are loaded onto a vessel at the port of loading and in transit on the final mode of transit before this date are not subject to the tariffs.
Reciprocal Tariffs
For those approximately 60 countries that the Trump Administration has deemed to be bad actors on trade, a country-specific tariff rate will be applied for all imports from such countries. These rates are inclusive of the baseline tariff and may be reduced to the baseline rate if the countries remove tariff and non-tariff barriers to U.S. imports.
The reciprocal tariffs will apply to goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on April 9, 2025. However, goods that are loaded onto a vessel at the port of loading and in transit on the final mode of transit before this date are not subject to the reciprocal tariffs.
The table below shows the country-specific rates for certain trading partners of the United States. The entire list can be found in Annex I to the Tariff Executive Order.
| Country | Reciprocal Tariff Rate |
| Cambodia | 49% |
| China | 34% |
| European Union | 20% |
| India | 26% |
| Indonesia | 32% |
| Iraq | 39% |
| Israel | 17% |
| Japan | 24% |
| Malaysia | 24% |
| Nigeria | 14% |
| Norway | 15% |
| Pakistan | 29% |
| Philippines | 17% |
| Serbia | 37% |
| South Africa | 30% |
| South Korea | 25% |
| Switzerland | 31% |
| Syria | 41% |
| Taiwan | 32% |
| Thailand | 36% |
| Venezuela | 15% |
| Vietnam | 46% |
In general, the baseline and reciprocal tariffs will apply in addition to any other applicable tariffs (subject to certain exceptions discussed below). With respect to China, the reciprocal tariff will be added to the existing 20 percent tariff on imports from that country, leading to an aggregate tariff rate on Chinese imports of 54 percent after April 9, 2025.
In addition, the baseline and reciprocal tariff will only apply to the non-U.S. content of an imported good if at least 20 percent of the good's value is U.S. content. For these purposes, "U.S. content" means the value of the good attributable to the components produced entirely, or substantially transformed in, the United States. U.S. Customs and Border Protection will establish a process to collect and verify claims related to the value of an item's U.S. content.
Exceptions:
The baseline and reciprocal tariffs will not apply in certain instances, including the following:
- Imports from Canada and Mexico will continue to be subject to the existing tariff regime for these countries whereby all USMCA compliant goods are exempt from tariffs and all non-USMCA compliant goods are subject to a 25 percent tariff (with non-USMCA compliant energy resources and potash imported from Canada subject to a 10 percent tariff);
- Steel and aluminum products that are subject to Section 232 tariffs;
- Automobiles and automotive parts that are subject to Section 232 tariffs;
- Goods that become subject to Section 232 tariffs in the future;
- Goods identified in Annex II to the Tariff Executive Order, including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products; and
- Imports from Cuba, North Korea, Russia, and Belarus will continue to be subject to their separate tariff rates.
Notably, there is no process noted for requesting an exemption from the tariffs.
With respect to the exception for imports from Canada and Mexico, if the existing executive orders imposing tariffs on these countries are terminated or suspended, imports from both countries will be subject to a 12 percent ad valorem reciprocal tariff.
Duration of Tariff Rates:
The President must review and, if necessary, may extend national emergencies declared under IEEPA on an annual basis. The tariffs will remain effective until specifically revised or revoked by the President, or until the President terminates the declared national emergency that is the basis for these tariffs. Congress may also terminate national emergencies through a successful joint resolution.
Elimination ofDe MinimisExemption for Chinese Imports:
Concurrent with his signing of the Tariff Executive Order, President Trump also signed the De Minimis Executive Order, which eliminates the duty-free de minimis exemption for shipments from China valued at or under $800. Under the De Minimis Executive Order, the applicable tariff rate for such shipments will vary depending on the shipping method.
- For goods shipped through means other than the international postal network and that would otherwise qualify for the de minimis exemption, all applicable tariffs will be due upon importation.
- For goods that are shipped through the international postal network that would otherwise qualify for the de minimis exemption, the applicable tariff rate is either 30 percent of the value of the goods or $25 per item (increasing to $50 per item after June 1, 2025), at the carrier's discretion. This tariff would replace any other applicable tariffs on Chinese imports, such as the existing Section 232 tariffs.
The De Minimis Executive Order applies to all goods entered for consumption on or after 12:01 a.m. eastern daylight time on May 2, 2025.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
