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.

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.