Tracking Trump tariffs

Updated Friday, May 16, 2:00 pm ET

DLA Piper’s National Security and Global Trade team is closely monitoring the tariff landscape, in coordination with the Government Affairs and Public Policy team, and advising clients daily on how to strategize around the economic uncertainties that new and anticipated tariffs create. For example:

• Supply chain risk assessments, country of origin analyses, and tariff engineering and mitigation strategies
• Outreach to policymakers in Congress and the Executive branch related to industry and/or company-specific concerns
• Proactive monitoring and analysis of developments and trends, and strategic advice on how to plan accordingly
• Petitioning for exclusions when available
• Submission of public comments and participation in public hearings when available
• Review and modification of contractual language to shift the burden of payment
• Development of onshoring manufacturing strategy

On April 5, 2025, imports to the US from all countries became subject to an additional 10 percent reciprocal tariff on top of any existing duties or tariffs. On April 9, President Trump announced a 90-day pause on the increased reciprocal tariff rates, which took effect that morning, for all countries other than China - though China's additional reciprocal tariffs have since been paused as well. The pause maintains the 10 percent universal tariff, but delays the country-specific increases outlined in the chart below. These reciprocal tariffs apply to all goods from the listed countries with the exception of: (1) goods subject to Section 232 steel/aluminum tariffs, Section 232 automobiles and automobile parts tariffs, and any future Section 232 tariffs; (2) certain goods including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products; and (3) any goods from countries that do not have Normal Trade Relations (“NTR”) with the United States.

The following clarifications/actions have been taken with respect to these exceptions:

On April 11, the Trump Administration issued a Presidential Memorandum entitled “Clarification of Exceptions Under Executive Order 14257 of April 2, 2025, as amended” which clarified the “semiconductors” exception to include additional electronics imports in the list of excepted articles for the April 2 “Reciprocal Tariffs.” The Memo clarifies that the “semiconductors” exception listed in the April 2 Executive Order includes a variety of consumer electronics products such as smartphones, laptops, hard drives, flat-panel monitors, and certain chips. It also includes machines used to make semiconductors.

On April 14, the Department of Commerce announced that it had launched Section 232 National Security Investigations, which could lead to tariffs, into pharmaceutical and semiconductor products. The semiconductor investigation includes “semiconductors and semiconductor manufacturing equipment, and their derivative products” which “include downstream products that contain semiconductors, such as those that make up the electronics supply chain.” The pharmaceutical investigation includes pharmaceuticals, pharmaceutical ingredients, and their derivative products; this includes “both finished generic and non-generic drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients, and key starting materials, and derivative products of those items.” Section 232 investigations allow the president to restrict imports – such as through tariffs – deemed a threat to national security. While typical Section 232 investigations may take more than six months, the deadline for public comments on both investigations are just 21 days after their April 16 publication date, suggesting these investigations may be expedited. For inquiries regarding these investigations, or assistance filing comments, please contact the DLA Piper team.

On April 15, the Trump Administration issued an Executive Order directing the Secretary of Commerce to initiate another Section 232 Investigation into processed critical minerals. The Executive Order states that the investigation will include critical minerals and rare earth elements, and that “processed critical minerals” refers to critical minerals that have “undergone the activities that occur after critical mineral ore is extracted from a mine up through its conversion into a metal, metal powder, or master alloy,” suggesting raw critical minerals may not be in the scope of the investigation. However, the scope of the investigation appears to be quite broad, as “derivative products” include all goods that incorporate processed critical minerals as inputs, including smartphones and other electronics, and their components. While it is unclear what the intended scope of remedies is intended to be, it is not necessarily the case that remedies would apply as broadly.

On April 22, the Trump Administration initiated a Section 232 investigation to determine the effects on national security of imports of medium and heavy-duty trucks and their parts and derivative products. The investigation defines "medium-duty trucks" as those with a gross vehicle weight of between 10,000 and 26,000 pounds, and "heavy-duty trucks" as those with a gross vehicle weight rating of 26,001 pounds or more.

Additionally, on April 17, the United States Trade Representative ("USTR") announced a set of measures directed at the Chinese shipbuilding sector, following an investigation into China’s efforts to gain dominance in the maritime, logistics, and shipbuilding industries. The USTR’s response will unfold in two distinct phases. In the first phase, which will begin after an initial 180-day period during which no fees are charged, fees will be imposed as follows: (1) on vessel owners and operators based in China, calculated according to the net tonnage of cargo transported per voyage to the United States; (2) on operators of ships constructed in China, based on either net tonnage or the number of containers carried; and (3) on foreign-built car carrier vessels. These fees are set to rise gradually throughout the three-year duration of the first phase, and could total more than $3 million per voyage, depending on the vessel size. The second phase will introduce limited restrictions on the transportation of liquified natural gas using foreign vessels, with these restrictions becoming progressively stricter over a 22-year period. Additionally, the USTR is currently inviting public input on proposed tariffs for ship-to-shore cranes and other cargo handling equipment, as part of its ongoing review of Chinese activities in the maritime sector.

On April 29, President Trump signed an Executive Order revising the Administration’s tariff policy to prevent most tariffs from being applied cumulatively, or “stacked,” on the same goods. The Order specifically provides that the 25 percent tariffs imposed under Section 232 on automobiles, the IEEPA tariffs related to fentanyl and immigration for Canada and Mexico, and the 25 percent Section 232 tariffs on steel and aluminum will not be combined with one another. However, the Order does not apply to other tariffs not explicitly listed.

The Trump Administration has begun to announce the results of its ongoing trade negotiations. On May 8 the Trump Administration announced that it had reached a trade deal with the United Kingdom. The agreement in principle will maintain the 10 percent baseline tariff on imports from the UK, and will work to relax the Section 232 tariffs on automobiles, steel, and aluminum from the UK. The UK committed to increase its imports of U.S. agricultural and other products.

On May 12 the U.S. and China announced they reached a deal to temporarily cut tariffs for 90-days. The U.S. reduced its reciprocal tariffs from 125 percent to 10 percent, but left in place the fentanyl related IEEPA tariffs, bringing the total baseline tariff for Chinese goods to 30 percent . The U.S. also reduced its tariffs on de minimis imports from 120 percent  to 54 percent . Other U.S. tariff and trade measures against Chinese products will remain in place. China reduced its retaliatory tariffs on the U.S. to 10%, and has committed to rolling back its other retaliatory trade measures. The two countries committed to continue negotiations over the 90-day de-escalation period.

Goods with at least 20 percent US content are tariffed only on the value of the non-US content. In other words, the value of the US content is exempted from the new tariffs (again, provided that at least 20 percent of the value is US content).

Goods from Canada and Mexico are not subject to new tariffs, but the regime in place will continue. Specifically, goods that qualify for preferential treatment under USMCA are duty-free. Potash and energy goods from Canada that don’t qualify under USMCA are subject to a 10 percent tariff, and all other non-USMCA goods from Canada and Mexico are subject to a 25 percent tariff.

Please find below a table tracking additional US tariff updates, and firm insights into these and related developments.