Trump Tariffs 2.0: The Tariff Tracker

UPDATES

2/4/25:

Escalated negotiations with Mexico and a Canada have led to a pause in the tariff implementation for 30 days. Reports indicate that talks between the United States and China are occurring within the next 24 hours.

2/3/25:

The Executive Orders for China and Mexico have been posted on the White House website and align with our 2/1 report. However, today Mexican President Claudia Sheinbaum and President Trump announced via social media that the two countries agreed to delay implementation of the tariff increases on Mexico products by one month - March 3, 2025. Mexico agreed to take steps to prevent the inflow of fentanyl and migrants into the United States, including sending soldiers to the border. We are closely watching developments on the China and Canada front for possible implementation delays. It has been reported that Trump is speaking with Canadian Prime Minister Justin Trudeau this afternoon.

2/1/25:

After fluctuating reports yesterday between a February 1 and March 1 date for initiation of the tariffs, President Trump signed three executive orders (EOs) today, said to implement 25% additional tariff on Mexico and Canada (except 10% for Canadian energy resources), and a 10% additional tariff on China, effective Tuesday, February 4 at 12:01am ET. Goods in final transit to the United States before 12:01 am ET on February 1 are exempt from these tariffs. While only the Canada EO and the White House Fact Sheet covering the tariffs have been officially released, various details on the China and Mexico EOs have been reported and unofficial copies have been circulated that have not been made publicly available at the time of this posting. This update is based on this latest intel, but as we have seen over the last few weeks, a lot can change in 24 hours, and more so in a little more than two days before the effective date.  

The President is invoking the International Emergency Economic Powers Act (IEEPA) to impose tariffs due to the national emergency posed by illegal drugs, including fentanyl, and illegal immigration. These tariffs, targeting all goods from Canada, Mexico, and China, would be in addition to existing duties, such as Section 301 tariffs, and would remain until the crisis is resolved. The orders include retaliation clauses to counter measures such as retaliatory tariffs from Canada, Mexico and China, as well as information on the applicability of de minimis, free trade zones (FTZ), drawback. We expect US Customs and Border Protection (CBP) or other US agencies to provide additional guidance to the trade community on the governance of these tariff implementations (e.g., clarity on HTSUS codes, Ch. 98 provisions, USMCA application, FTZ, bonds, goods on water, etc.).

Canada

The Canada EO defines the “Energy Resources” subject to the tariffs as including: crude oil, natural gas, lease condensates, natural gas liquids, refined petroleum products, uranium, coal, biofuels, geothermal heat, kinetic movement of flowing water, critical minerals.

In response to the tariff announcements, Canada has also announced retaliatory tariffs of 25% on a wide variety of American goods on this list including certain beverages, perfume, clothing, shoes, consumer products, limber and plastic products, etc., enacted in two stages:

• February 4: tariffs on $30 billion of US products
• February 21: tariffs on $125 million of US products

Canada and certain provinces are also considering other retaliatory measures.

We expect action from Mexico and China as well.

1/30/25:

From the Oval Office this evening, President Trump announced that 25% tariffs on Canada and Mexico are starting February 1, and deciding whether oil will be exempt from tariffs. These increases are pending issuance of an Executive Action or similar official documentation, which if issued, may not come until February 1.

1/26/25:

On January 26, President Trump announced plans to impose tariffs starting at 25% and potentially increasing to 50% in one week, alongside treasury, banking, and financial sanctions, as well as specific travel and immigration measures. These actions were a response to Colombia’s initial refusal to accept migrants deported from the United States. However, within hours of the announcement, the White House released a statement indicating that Colombia had agreed to accept the migrants, thereby averting the imposition of these measures, including the tariffs. The draft orders related to these tariffs issued under the authority of International Emergency Economic Powers Act (IEEPA),  and other measures will remain unsigned unless Colombia fails to uphold its agreement. This situation underscores President Trump’s readiness to swiftly implement tariffs as a tool in international relations to ensure compliance with US terms. It appears IEEPA may be the authority employed to implement immediate tariffs.

1/22/25:

The Trump Administration continues to announce possible additional tariffs that will be applied to specific country targets. For example, on January 22, Trump raised possible tariff increases on Russia in connection with the war in Ukraine. On January 21, he also announced possible increases of 10% on China and 25% on Mexico and Canada as early as February 1. To date, no official action to implement tariff increases has taken place.

1/20/25:  

Additional tariffs have yet to be imposed, but an America First Trade Policy executive order was issued on President Trump’s first day in office, outlining various administrative agency investigations and potential reorganizations as summarized further below. Many of the investigatory reports are due in April 2025, however, other sources indicate that additional tariffs may be announced as early as February 2025 in relation to these policy developments. 

1. Investigation of Trade Deficits: The Administration is investigating the causes of persistent trade deficits, with potential measures such as global tariffs being considered.
2. Establishment of an ERS: The feasibility of creating an External Revenue Service (ERS) to manage tariffs and trade-related revenues is being explored, potentially impacting how duties are collected.
3. Review of Unfair Trade Practices: The US Trade Representative (USTR) is tasked with identifying unfair trade practices and recommending actions, which may include tariffs.
4. USMCA Review and Public Consultation: A public consultation process will begin for the 2026 review of the United States–Mexico–Canada Agreement (USMCA), assessing its impact on American stakeholders and considering the United States’ continued participation.
5. Currency Manipulation: Measures against currency manipulation are under review, potentially impacting international trade dynamics.
6. Trade Agreements: USTR shall review existing trade agreements to recommend revisions to achieve or maintain appropriate level of reciprocal and mutually advantageous concessions, as well as identify countries for negotiation of new agreements.  
7. AD/CVD Review: Policies regarding Antidumping and Countervailing Duties (AD/CVD) laws are being reviewed to ensure compliance and address transnational subsidies.
8. De Minimis Exemption Review: The impact of the $800 duty-free de minimis exemption on tariff revenues and public health will be assessed, with potential modifications to protect US interests.
9. Section 301 Tariffs on China:  USTR shall assess the Section 301 Four-Year Review Report from May 14, 2024, and recommend actions necessary to remediate any issues.  
10. Additional China Focused Reviews:  The memorandum outlines other initiatives to review with respect to China, including the trade relations under the Economic and Trade Agreement between the United States and China (indicating a potential of tariffs or other measures as needed), legislative proposals regarding Permanent Normal Trade Relations with the People’s Republic of China (PRC), the status of US intellectual property rights conferred upon PRC persons is being assessed to ensure reciprocal and balanced treatment.
11. Section 232 Tariffs on Aluminum and Steel: Review of the effectiveness of the exclusions, exemptions, and other import adjustments on steel and aluminum as imposed under the Section 232 tariffs.
12. Unlawful Migration and Fentanyl Flows: Commerce and DHS to assess unlawful migration and fentanyl flows from Canada, Mexico, the PRC, and other relevant jurisdictions to recommend appropriate measures to resolve such emergency issues.
13. Additional Reviews: Examining extraterritorial taxes, World Trade Organization, and Federal Procurement agreements in connection to Buy America, export control authorities and national security,  and recent rule from BIS covering the Information and Communication Technology and Services on Connected Vehicles.