In a stunning turn of events for the Trump Administration's trade policy, today, May 28, the Court of International Trade vacated President Trump's reciprocal tariffs and trafficking-related tariffs on China, Canada and Mexico, all of which were issued under the International Emergency Economic Powers Act ("IEEPA"). The court held that the retaliatory tariffs "exceed any authority granted to the President by IEEPA to regulate importation by means of tariffs" and that the trafficking tariffs on China, Canada and Mexico "fail because they do not deal with the threats set forth in those orders." The CIT's three-judge panel was unanimous in its ruling, declaring that the tariffs imposed by the Trump Administration would be vacated. This decision vacates the tariffs entirely and permanently enjoins the government from enforcing them.
The Trump Administration has filed an appeal with the U.S. Court of Appeals for the Federal Circuit. While the government is seeking to overturn the CIT decision, the tariffs remain vacated unless the higher court issues a stay. Until the Court of Appeals issues a ruling, the CIT's decision not only impacts the current tariffs issued under IEEPA, but also undercuts the President's ability to impose new tariffs under the guise of IEEPA.
Note, the CIT's ruling does not impact the tariffs that have been imposed pursuant to Section 232 Investigations or which are still subject to ongoing Commerce Department investigations. For interested parties, the comment period for the Commerce Department's Section 232 Investigation on imports of commercial aircraft and jet engines, and parts for commercial aircraft and jet engines remains open until June 3, 2025.
Keeping track of all of the tariffs that have been promulgated or proposed during the Trump Administration continues to be a head-spinning task. To help follow the proliferation of tariffs in the Trump Administration, I have put together the following list of each of the tariff measures that have been implemented, pending, or proposed since January 20,2025.
Here is the developing landscape of U.S. tariffs as of May 28, 2025:
| Country | U.S. Tariff Measure | Status |
|---|---|---|
|
Global [Canada & Mexico Exempt] |
Reciprocal tariffs – 10% ad valorem duty China-specific 54% ad valorem duty on de minimis valued imports, other country-specific duties suspended Certain goods excluded |
VACATED 5/28/2025 Revised 5/12/2025 Implemented4/2/2025 Executive Order Establishing Tariffs Executive Order Revising Tariffs CBP Bulletin on Excluded Electronics |
| China | Chinese Vessels – Port Entry Fees on Chinese owned or built vessels, and foreign-built car carriers. |
Implemented: 4/17/2025 USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing |
| Global | Automobiles – 25% ad valorem duty on imports of automobiles (with certain allowances for USMCA-qualifying autos) and certain automobile parts (with limited tariff offsets) |
Implemented 4/3/2025 (effective 5/3/2025 for automobile parts) Proclamation on Sec. 232 Duties Proclamation with HTS Amendments |
| Global | All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed |
Implemented4/2/2025 |
| Global | Steel – 25% ad valorem duty on imports of steel articles and derivative products with no exemptions or exclusions |
Implemented: 3/12/2025 |
| Global | Aluminum – 25% ad valorem duty on imports of aluminum articles and derivative products with no exemptions or exclusions |
Implemented: 3/12/2025 |
| Canada |
10% ad valorem duty on non-USMCA-qualifying energy and potash 25% ad valorem duty on all other non-USMCA-qualifying products of Canada |
VACATED 5/28/2025 Implemented: 3/4/2025; 4/2/2025 (updated) |
| Mexico | 25% ad valorem duty on all non-USMCA-qualifying products of Mexico |
VACATED 5/28/2025 Implemented: 3/4/2025; 4/2/2025 (updated) |
| China | 20% ad valorem duty on all products of China |
VACATED 5/28/2025 Implemented: 3/4/2025 CBP Fed Reg Notice |
| Global | Aircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts |
Pending: Section 232 Investigation |
| Global | Critical Minerals – potential tariffs on imports of processed critical minerals and derivative products |
Pending: Section 232 Investigation |
| Global | Medium & Heavy Duty Trucks – potential tariffs on imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts. |
Pending: Section 232 Investigation |
| Global | Semiconductors – potential tariffs on imports of semiconductors, SME, and derivative products |
Pending: Section 232 Investigation |
| Global | Pharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products |
Pending: Section 232 Investigation |
| Global | Copper – potential tariffs on imports of copper and derivative products |
Pending: Section 232 Investigation |
| Global | Lumber – potential tariffs on imports of timber, lumber, and their derivative products |
Pending – Section 232 Investigation |
| Global | 100% tariff on movies produced outside of the United States | Proposed: 5/4/2025, announced by President Trump on Truth Social |
| E.U. | 25% ad valorem duty on all products of the E.U. | Proposed: 2/26/2025, superseded by Reciprocal Tariffs |
This list will be updated weekly as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.
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.
