Stay Ahead in Trade Compliance: Tariff Updates

Product

Status

Ad Valorem Tariff Rate

Scope

Automobiles

Implemented (effective Apr. 3, 2025; amended June 16, 2025)

25%

See HTSUS Chapter 99, notes 33(a)-(e)

Reciprocal tariff exception: automobiles subject
to Section 232 tariffs are not subject to the reciprocal tariffs

“Stacking” exception: automobiles subject to Section 232 tariffs are not subject to (a) the tariffs on Canadian- and Mexican-origin goods, (b) any applicable Section 232 tariffs on aluminum and derivative products, or (c) any applicable Section 232 tariffs on steel and derivative products

UK aerospace exception (starting June 23): UK-origin products that fall under the WTO Agreement on Trade in Civil Aircraft are except from these tariffs.

For automobiles that qualify for preferential treatment under the USMCA, the tariff will apply to the non-U.S. content.

Exec. Order 14309 (June 16, 2025)

Exec. Order 14289 (Apr. 29, 2025)

Proclamation
10908 (Mar. 26, 2025)

Automobile parts

Implemented (effective May 3, 2025; amended June 16, 2025)

10% (including any most-favored-nation duties) for UK-origin products for use in UK-origin automobiles

25% for all other covered products

See HTSUS Chapter 99, notes 33(g)-(h)

Reciprocal tariff exception: automobile
parts subject to Section 232 tariffs at the time of import are not subject to the reciprocal tariffs

“Stacking” exception: automobile parts subject to Section 232 tariffs are not subject to (a) the tariffs on Canadian- and Mexican-origin goods, (b) any applicable Section 232 tariffs on aluminum or derivative products, or (c) any applicable Section 232 tariffs on steel or derivative products

Parts that qualify for preferential treatment under the USMCA will initially be exempt. The Commerce Department will establish a process for applying the tariff exclusively to the value of the non-U.S. content in these parts and then publish notice of that process in the Federal Register.

Exec. Order 14309 (June 16, 2025)

Exec. Order 14289 (Apr. 29, 2025)

Proclamation 10908 (Mar. 26, 2025)

Integrated circuits

Threatened (Jan. 31, 2025)

TBD

TBD

See Updates below

See semiconductors, semiconductor equipment, and derivative products below

On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of legacy chips, leading-edge chips, & microelectronics.

iPhones

Threatened (May 23, 2025)

25%

TBD

Lumber, timber, and derivative products

Threatened (Mar. 3, 2025)

25%

TBD

Commerce initiated a Section 232 investigation. A report is due to the President by November 26, 2025.

Exec. Order 14223 (Mar. 1, 2025)

Maritime cargo handling equipment

Threatened (Apr. 9, 2025)

20–100%

100%

Containers, chassis, and chassis parts (HTSUS 8609.00.00, 8716.390090, 8716.90.30, 8716.90.50)

Ship-to-shore gantry cranes (HTSUS 8426.19.00)

As part of the USTR’s Section 301 investigation into China’s targeting of the maritime, logistics, and shipbuilding sectors, President Trump directed the USTR to consider tariffs on (a) ship-to-shore cranes manufactured, assembled, or made using Chinese-origin components, or manufactured anywhere in the world by a company owned, controlled, or substantially influenced by a Chinese national; and (b) other cargo handling equipment.

The proposed tariffs cover both products of China, as well as STS cranes manufactured anywhere in the world using Chinese-origin components or by a company owned, controlled, or substantially influenced by a Chinese national.

Exec. Order 14269 (Apr. 9, 2025)

Pharmaceuticals, pharmaceutical ingredients, and derivative products

Threatened (Feb. 18, 2025; new threatened rate announced July 8, 2025)

200%

TBD

See Updates below

On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of pharmaceuticals, pharmaceutical ingredients, and derivative products.

Processed critical minerals and derivative products

Threatened (Apr. 15, 2025)

TBD

TBD

See Updates below

On April 22, Commerce initiated a Section 232 investigation to determine the effects on the national security of imports of processed critical minerals, as well as their derivative products.

“Processed critical minerals” are critical minerals that have undergone activities that occur after critical mineral ore is extracted from a mine up through its conversion into a metal, metal powder, or a master alloy.  “Derivative products” include all goods that incorporate processed critical minerals as inputs, including semi-finished goods (e.g., semiconductor wafers, anodes, cathodes) and final products (e.g., permanent magnets, motors, electric vehicles, batteries, smartphones, microprocessors, radar systems, wind turbines and their components, advanced optical devices).

Exec. Order 14272 (Apr. 16, 2025)

Semiconductors, semiconductor manufacturing equipment, and derivative products

Threatened (Feb. 18, 2025)

25% or higher

TBD

See Updates below

On April 1, Commerce initiated a Section 232 investigation to determine the effects on national security of imports of semiconductors; semiconductor manufacturing equipment; and derivative products, including downstream products that contain semiconductors.

Unmanned aircraft systems and their parts and components

Threatened (July 14, 2025)

TBD

TBD

See Updates below
 
On July 14, Commerce initiated a Section 232 investigation to determine the effects on the national security of imports of unmanned aircraft systems (UAS) and their parts and components.