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2 April 202533 minute read

Tracking Trump tariffs

Updated Friday, April 18, 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. The pause maintains the 10% universal tariff, but delays the country-specific increases outlined in the chart below. In the same announcement, President Trump increased the reciprocal tariffs on China to 125%, effective immediately. 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.


Imposed on Amount Imposed on Amount Imposed on Amount
China 125 percent North Macedonia
33 percent Vanuatu
22 percent
Lesotho 50 percent Angola
32 percent
Côte d`Ivoire
21 percent
Cambodia 49 percent Fiji
32 percent
Namibia
21 percent
Laos 48 percent Indonesia
32 percent
European Union
20 percent
Madagascar 47 percent Taiwan
32 percent
Jordan
20 percent
Vietnam 46 percent Switzerland
31 percent
Nicaragua
18 percent
Myanmar (Burma) 44 percent Libya
31 percent
Zimbabwe
18 percent
Sri Lanka 44 percent Moldova
31 percent
Philippines
17 percent
Falkland Islands 41 percent South Africa
30 percent
Malawi
17 percent
Syria 41 percent Algeria
30 percent
Israel
17 percent
Mauritius
40 percent
Nauru
30 percent
Zambia
17 percent
Iraq
39 percent
Pakistan
29 percent
Mozambique
16 percent
Guyana
38 percent
Tunisia
28 percent
Norway
15 percent
Botswana
37 percent
Kazakhstan
27 percent
Venezuela
15 percent
Serbia
37 percent
India
26 percent
Nigeria
14 percent
Bangladesh
37 percent
South Korea
25 percent
Chad
13 percent
Liechtenstein
37 percent
Brunei
24 percent
Equatorial Guinea
13 percent
Thailand
36 percent
Japan
24 percent
Cameroon
11 percent
Bosnia and Herzegovina
35 percent
Malaysia
24 percent
Democratic Republic of the Congo
11 percent

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.


Imposed by Imposed on Date Type of Tariff Amount Exemptions
US Canada, Mexico March 4, 2025 All goods, excluding energy and potash 25 percent USMCA-compliant imports
US Canada, Mexico March 4, 2025 Energy and potash 10 percent USMCA-compliant imports
US China Feb 4, 2025
10 percent

March 4, 2025 raised to 20 percent
All goods 20 percent
US All countries March 12, 2025 Steel/aluminum and certain derivative products 25 percent Derivative products processed outside the US from steel "melted and poured" or aluminum "smelted and cast" in the US
US All countries April 3, 2025 Passenger vehicles and light trucks 25 percent Only applicable to the value of non-US content of USMCA-compliant vehicles; not applicable to automobile knock-down kits or parts compilations
US All countries May 3, 2025 Key automobile parts (such as engines, transmissions, powertrain components, and electrical components) 25 percent Not applicable to USMCA-compliant automobile parts until a process to apply tariffs to their non-US content is established

Tariffs are “stackable” unless otherwise noted.

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