News & Press

May
12
2025

Trade Alert: Trump Tariffs

June 2nd, 2025

Trade Alert: Trump Increases Aluminum and Steel Tariffs to 50%

President Donald Trump announced on his Truth Social account that, effective June 4th, tariffs on steel and aluminum will increase from 25% to 50%. This change applies to the existing Section 232 tariffs on applicable steel/iron and aluminum products. No additional information has been provided beyond the announcement, and we are therefore awaiting further guidance from U.S. Customs and Border Protection (CBP).

The European Union has expressed concerns about the announcement, warning that it could disrupt ongoing negotiations between the United States and the European Union. In a statement, the European Commission said: “If no mutually acceptable solution is reached, both existing and additional EU measures will automatically take effect on July 14th— or earlier, if circumstances require.”

 

May 29th, 2025

Trade Alert: Court of International Trade Ruled Against IEEPA-Based Tariffs

On Wednesday, May 28, the U.S. Court of International Trade (CIT) ruled that President Trump’s Reciprocal and Fentanyl-Related Tariffs were not authorized under the International Emergency Economic Powers Act (IEEPA).  The CIT has ordered the Trump administration to implement new orders within 10 days to comply with the ruling. The Trump Administration has announced that it will be appealing this ruling.

As of now, no changes have been made to the tariffs or their rates, and we are awaiting further guidance.

Please see below for the full order from the CIT:

CIT Order

 

May 15th, 2025

Trade Alert Update: Guidance on Chinese Reciprocal Tariffs

On May 14th, the United States reduced the China-specific reciprocal tariff rate from 125% to 34% as previously issued in Annex I to Executive Order, Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits, dated April 2, 2025.  Additionally, the reciprocal rate of 34% has been paused for 90 days to allow time for further negotiations.  In the meantime, a 10% reciprocal tariff will remain in effect on all products originating in China (HK and Macau).

This reciprocal tariff will be applicable to all products entered or withdrawn from warehouse for consumption on or after 12:01 AM EDT on May 14th.

U.S. Customs and Border Patrol released a CSMS message with further guidance.

CSMS: Guidance – Modifying Reciprocal Tariff Rate for China

We have updated our “Tariff Cheat Sheet” to include guidance on the updated Reciprocal Tariffs on China.

Tariff Cheat Sheet

 

May 12th, 2025

Trade Alert Update: U.S. Lowers Chinese Reciprocal Tariffs

Beginning on May 14th, the United States and China will reduce their reciprocal tariffs by 115% while maintaining a 10% baseline tariff. This agreement was reached after representatives of the two countries met in Geneva, Switzerland, over the weekend. Both nations dropped tariffs from 125% to 10%. For the United States, this marks a reversion to the initially proposed rate of 34% on Chinese imports, which was announced on April 2. The 34% rate will be paused for 90 days to allow time for further negotiations. In the meantime, a reciprocal tariff of 10% will remain in effect.

All U.S. duties imposed prior to April 2, 2025, including those under Section 301, Section 232, and the IEEPA-Fentanyl-related tariffs, will remain in effect.

This trade alert is based on limited information. We are awaiting further guidance from U.S. Customs regarding the particulars of the new agreement and will provide an update as soon as additional information becomes available.

For more guidance:

 

April 10th, 2025

Trade Alert: 125% Tariff on China and a 90-Pause on Country-Specific Rates

Beginning at 12:01 A.M. on April 10, reciprocal tariffs on China (including Hong Kong and Macau) have increased to 125%. This increase is in response to the 84% reciprocal tariffs imposed by China on U.S. goods.

On a more positive note, President Trump has also announced a 90-day pause on country-specific tariff rates (excluding China, Canada, and Mexico). During this period, the ad valorem duty rate will be reduced to 10%.

For more guidance:

CSMS: Reciprocal Tariffs – Increase in Rate for China and Reversion of Other Country-Specific Rates

 

April 8th, 2025

Trade Alert: April 9th Reciprocal Tariffs Begin & 50% Additional on China

 

Reciprocal Tariffs

Beginning April 9th at 12:01 A.M., the remainder of the tariff amounts on all imported goods outlined in Annex I will take effect. Goods loaded onto a vessel at the port of lading and in the final mode of transit before this time will not be subject to the additional duty upon entering the U.S. However, the original 10% tariff will still apply to these imports.

Additional guidance can be found in the CSMS below:

CSMS # 64649265 – GUIDANCE – Reciprocal Tariffs

Executive Order:

Regulating Imports with a Reciprocal Tariff

Annex I

Annex II

An Additional 50% Tariff Placed on Chinese Imports

Beginning April 9th at 12:01 A.M., an additional 50% tariff will be placed on Chinese imports, bringing the total duty amount to 104%. This tariff is in response to China’s reciprocal tariff of 35%. We are awaiting clarification and official orders regarding this tariff.

Executive Order

CSMS Message

 

April 3rd, 2025

Trade Alert Update: Important Updates Regarding Reciprocal Tariffs

 

Reciprocal Tariffs

Beginning April 5th, at 12:01 A.M., all imported goods will be subject to a 10% ad valorem IEEPA duty. However, goods loaded onto a vessel at the port of lading and in the final mode of transit before this time will not be subject to the 10% duty upon entering the U.S.

Specific countries in Annex I will face higher tariff rates.

The tariff rates outlined in Annex I will be effective for the countries with high tariff amounts, beginning April 9th at 12:01 A.M. Goods loaded onto a vessel at the port of lading and in final transit before that time will also be exempt from the additional duty specified below upon entry into the U.S.

Executive Order:

Regulating Imports with a Reciprocal Tariff

Annex I

Annex II

Exceptions: Products Excluded from Additional IEEPA Reciprocal Tariffs

The additional duty will not apply to products already covered under Section 232 tariffs, which include steel, aluminum, and automobiles/parts.

Products listed in Annex II are also exempt from these reciprocal tariffs.

Goods from Canada and Mexico are exempt from the Reciprocal Tariffs until the termination or suspension of the IEEPA Border. Once this happens, only goods qualifying under the USMCA will remain exempt, while non-USMCA goods will be subject to a 12% Reciprocal Tariff.

Furthermore, goods containing at least 20% U.S. content will be exempt. “U.S. content” refers to the value of the article attributed to components that are entirely produced or substantially transformed in the U.S.

Tariff Adjustments

If a country retaliates against U.S. goods in response to these tariffs, the President may increase or expand the scope of the tariffs.

If a country resolves the non-reciprocal trade issues, the President may reduce or narrow the scope of these tariffs.

232 Autos and Auto Part Annex Released

Effective at 12:01 A.M. on April 3rd, 25% tariffs shall apply to specific autos and light trucks.

Below is the list of exemptions from this tariff:

EXCLUSIONS FROM FEDERAL LABOR-MANAGEMENT RELATIONS PROGRAMS

   

Additions to the Aluminum Derivatives List

The Bureau of Industry and Security (BIS) has added two items to the aluminum derivatives list. The two new derivative products are beer and empty aluminum cans. These additions will be subject to the new tariff beginning April 4th at 12:01 A.M.

Executive Notice:

Implementation of Duties on Aluminum Derivatives Beer and Empty Aluminum Cans 

 

April 2nd, 2025

Trade Alert Update: 25% Tariff Placed on Automobiles and Auto Parts

 

At 12:01 A.M. April 3rd, a 25% tariff on automobile imports will take effect. This tariff will be applied in addition to any other applicable duties. It will cover passenger vehicles, including sedans, sport utility vehicles (SUVs), crossover utility vehicles (CUVs), minivans, and cargo vans. Light trucks will also be subject to the tariff.

Automobiles Under the USMCA:

If an automobile contains parts from the U.S., the importer must submit the necessary documentation to the Secretary of Commerce to verify the amount of U.S.-originating content. The 25% tariff will be assessed on the import’s value, excluding the value of U.S.-originating content. The full 25% tariff will apply to the entire automobile’s value if the U.S. content cannot be determined.

Below is a link to the Federal Register outlining the specifics and a fact sheet from the Trump administration.

Federal Register

Fact Sheet

A 25% tariff on automobile parts is still expected to begin May 3rd at 12:01 A.M. This tariff will cover engines, engine parts, transmissions, powertrain components, and electrical components.

 

April 2nd, 2025

Trade Alert: Reciprocal Tariffs Announced

President Donald Trump has announced a reciprocal tariff of at least 10% on nearly all goods imported into the U.S. Beginning April 5th, a 10% tariff will be placed on imports from all nations not listed in Annex I (waiting for list to be released). The countries listed in Annex I will begin on April 9th, at 12:01 A.M. Some of the affected countries include China (34%), India (26%), and Vietnam (46%), among others. Generally, these calculated tariff amounts are determined by the respective countries’ existing tariffs on U.S. goods and other non-tariff barriers, the total of which was reduced by 50%.

These tariffs will apply to imports entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 A.M. on April 5th, except “goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 a.m. eastern daylight time on April 5th, 2025, and entered for consumption or withdrawn from warehouse for consumption after 12:01 a.m. eastern daylight time on April 5th, 2025, shall not be subject to such additional duty.”

Executive Order

 

March 27th, 2025

Trade Alert: 25% Tariff Placed on Automobiles and Automobile Parts

The Trump Administration has announced a 25% tariff on imports of automobiles and specific auto parts under Section 232 authority. This tariff will be applied in addition to any other applicable duties. Tariffs on automobiles will take effect on April 3rd at 12:01 A.M., while tariffs on auto parts will begin no later than May 3rd.

Clarification:

Tariffs will be applied to passenger vehicles, including sedans, sport utility vehicles (SUVs), crossover utility vehicles (CUVs), minivans, and cargo vans. Light trucks will also be included. The tariff on automobile parts will cover engines, engine parts, transmissions, powertrain components, and electrical components.

Automobiles Under the USMCA:

If an automobile contains parts from the U.S., the importer must submit the appropriate documentation to the Secretary of Commerce to verify the amount of U.S.-originating content. The 25% tariff will be placed on the value of the import minus the value of the U.S.-originating content. If the amount of U.S. content cannot be determined, the full 25% tariff will be applied to the entire automobile value.

Trump Administration Announcement:

Executive Order

 

March 25th, 2025

Trade Alert: 25% Tariff Imposed on Countries Importing Venezuelan Oil

 

The Trump Administration has announced that, starting April 2nd, a 25% tariff will be imposed on all imports from countries that purchase Venezuelan oil. This includes oil purchased directly from Venezuela and indirectly through third-party suppliers. The tariff is expected to have a greater impact on several Asian countries. The tariff will expire one year after the last oil purchase from Venezuela. We are pending further guidance on how this determination will be made. Additionally, this tariff will be stacked on any existing tariffs.

Trump Administration Announcement:

Executive Order

 

March 12th, 2025

Trade Alert Update: Section 232 Tariff – 25% On All Derivative Products Begins

 

The Customs and Border Protection (CBP) agency released a Cargo Systems Messaging Service (CSMS) notification at 9:24 PM last night, providing guidance on the new tariffs for steel and aluminum. According to this message, tariffs on ALL derivative products (including those not categorized within HTS Chapters 73 and 76) will take effect starting at 12:01 AM this morning. It is important to note that iron products are also included in these tariffs.

CSMS Notifications:

The Department of Commerce also published a notice stating, “This notice certifies that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles related to both steel and aluminum” (Federal Register).

For reference, the below excerpt includes the reporting instructions for tariffs on aluminum derivative products (reporting requirements for steel derivative products are similar):

Rogers & Brown is currently working to determine the most complete guidance to our importers affected by these tariffs. This will include documentation requirements and addressing current shipments for which these tariffs are applicable. We will be reaching out to importers accordingly to discuss and address entry handling. 

 

 

 

March 11th, 2025

Section 232 Tariffs

On March 12th, at 12:01 A.M., all steel and aluminum imports entering the U.S. will be subject to a 25% tariff (these are steel and aluminum articles and their derivatives listed in HTS Chapters 73 and 76). To avoid these tariffs, all products must be entered for consumption or withdrawn from a warehouse for consumption before 12:01 A.M. All previous amendments to the Section 232 tariffs will be suspended.

The effective date for duties placed on derivative products outside Chapters 73 and 76 of the USHTS has not yet been determined. These duties will be based on the products’ steel and aluminum make-up. If the amount of steel or aluminum in a product is unknown, then the 25% duty will be placed on the product’s entire value.

Guidance:

Import Duties on Aluminum and Derivative Products

Import Duties on Steel and Derivative Products

Section 232 Chart

 

 

 

March 6th, 2025

Trade Alert: 25% Tariffs Paused for Mexican and Canadian Imports

On March 6th, President Donald Trump announced that the U.S. would pause the 25% tariff on Mexican and Canadian imports that qualify under the U.S.-Mexico-Canada Agreement (USMCA) until April 2nd. This is also the date set for all reciprocal tariffs to be implemented on nations with existing tariffs against U.S. exports.

These changes do not affect the recently enacted additional tariffs on Chinese goods, which were also implemented under IEEPA (the International Emergency Economic Powers Act).

 

 

 

March 4th, 2025

Trade Alert Update: IEEPA and Section 232 Tariff Updates 

Customs and Border Protection (CBP) has issued a message clarifying that the 10% Chinese tariff increase, scheduled to begin on March 4th, will NOT be retroactive to February 1st.

Tariff on Chinese Goods Increased to 20%

On March 3rd, the Trump Administration announced that the Tariff on Chinese imports will increase from 10% to 20%. The same rules as previously noted apply: If you provide evidence that your goods were on a vessel or in transit by 12:01 a.m. ET on February 1st, your goods will not be subject to these tariffs as long as they are entered for consumption before March 7th.

Fact Sheet: Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China

Mexican and Canadian Tariffs Begin Today

Beginning today, March 4th, a 25% tariff is applicable on imports coming into the U.S. from Mexico and Canada (10% tariff for Canadian energy resources). Section 321 de minimis goods will not be subject to these tariffs at this time.

No drawback will be available for these duties. Duty drawback will be available for other applicable duties.

Fact Sheet: President Donald J. Trump Proceeds with Tariffs on Imports from Canada and Mexico

Steel & Aluminum Tariff Clarifications

These tariffs will begin on March 12th, and all previous amendments to the Section 232 tariffs will be dissolved. Effective dates have yet to be announced for derivative products outside of Chapters 73 and 76 of the Harmonized Tariff Schedule of the U.S. (HTSUS). The tariffs on those products will be based on their steel and aluminum weight make-up (in Kilograms).

Aluminum Federal Register

Steel Federal Register

 

 

 

February 27th, 2025

Trade Alert: Upcoming Tariff Dates

As tariff enactment dates quickly approach, it is important to know how each tariff will affect you. Below, you will find relevant dates for upcoming tariffs and other important details.

Mexican and Canadian Tariffs

On February 4th, President Trump announced a 25% tariff on imports from Mexico and Canada (10% tariff on Canadian energy resources). After negotiations, these tariffs were delayed by one month once Canada and Mexico agreed to increase border security. Despite border security efforts, Trump has announced that these tariffs will proceed on March 4th (there are some reports that negotiations are taking place between Mexico and the U.S.).

IEEPA Tariffs

On February 4th, President Trump imposed a 10% tariff on all Chinese imports entering the U.S. under the International Emergency Economic Powers Act (IEEPA). This additional 10% tariff will be applied to imports from China on March 7th at 12:01 A.M. Goods in transit as of February 1st and arriving prior to March 7th at 12:01 A.M. will not be subject to the additional tariff.

Steel & Aluminum Tariffs

On February 10th, President Trump announced a 25% tariff on all steel and aluminum imports entering the U.S., an update to the current Section 232 tariffs. These tariffs will begin on March 12th, and all previous amendments to the Section 232 tariffs will be dissolved. Effective dates have yet to be announced for derivative products outside of Chapters 73 and 76 of the Harmonized Tariff Schedule of the U.S. (HTSUS). The tariffs placed on those products will be based on their steel and aluminum make-up.

 

 

 

February 17th, 2025

Trade Alert Update: Lists of Derivative Products for Section 232 Tariffs Released 

The Trump Administration has released the list of derivative products subject to 25% tariffs under Section 232. Below are the two notices scheduled to be released in the Federal Register tomorrow, February 18th. Tariffs on these derivative products will not begin until the Secretary of Commerce confirms that a system is in place to collect tariff revenues.

Steel Derivative Products

Aluminum Derivative Products

The products are categorized by their Harmonized Tariff Schedule of the United States (HTSUS) codes.

Steel Derivative Products:

HTSUS Chapter 73 will have their entire value subject to tariffs.

HTSUS Chapters 84, 85, and 94 will only have a tariff on the steel content.

Aluminum Derivative Products:

HTSUS Chapter 76 products will have their entire value subject to tariffs.

HTSUS Chapters 66, 83, 84, 85, 87, 88, 90, 94, 95, and 96 will only have a tariff on the aluminum content.

Many customers have asked if these tariffs will replace the current ones. The answer is no; the 25% steel and aluminum tariffs will be applied on top of any other applicable duty rates (stacked).

 

 

 

February 14th, 2025

Trade Alert: Trump Launches Investigation for Reciprocal Tariffs on Foreign Nations

On February 13th, President Trump released a memorandum announcing that the White House will launch an official investigation into nations that have imposed tariffs on U.S. goods. This new policy is called the “Fair and Reciprocal Plan.” Once existing tariffs are identified, he has ordered reciprocal tariffs be placed on those nations. It can be inferred that April 1st is the soonest any of these tariffs would be made effective.

These tariffs will not be implemented immediately. After the warning, President Trump expects these nations to lower or eliminate their tariffs.

The investigation will examine factors that President Trump believes are affecting the U.S. economy. As stated in his memorandum, these factors include:

(a) Tariffs imposed on United States products.

(b) Unfair, discriminatory, or extraterritorial taxes imposed by our trading partners on the United States’ businesses, workers, and consumers, including a value-added tax.

(c) Costs to United States businesses, workers, and consumers arising from nontariff barriers or measures and unfair or harmful acts, policies, or practices, including subsidies and burdensome regulatory requirements on United States businesses operating in other countries.

(d) Policies and practices that cause exchange rates to deviate from their market value to the detriment of Americans; wage suppression; and other mercantilist policies that make United States businesses and workers less competitive.

(e) Any other practice that, in the judgment of the United States Trade Representative, in consultation with the Secretary of the Treasury, the Secretary of Commerce, and the Senior Counselor to the President for Trade and Manufacturing, imposes any unfair limitation on market access or any structural impediment to fair competition with the market economy of the United States.

 

 

 

February 12th, 2025

Trade Alert: 25% Tariff on Steel and Aluminum Imports into U.S.

President Donald Trump has announced the expansion of Section 232 Tariffs. Starting March 12th, a 25% tariff will be imposed on all steel and aluminum imports into the United States unless the products qualify for “domestic status.” All previous agreements and exemptions related to steel and aluminum with trading partners will be canceled. A 50% tariff will be applied to steel products and derivatives from Turkey. Additionally, if the primary aluminum used in a derivative product originates from Russia, the duty rate will be 200%.

Duty Drawback will not be allowed for these tariffs.

Notice from the Trump Administration 

A complete list of derivative products has not been released yet, but they will also be subject to tariffs. The date that these will be implicated is based on when the Secretary of Commerce declares that it has a system to collect tariffs quickly and efficiently.

To be admitted under “domestic status,” a derivative steel product made in another country has to be made from melted steel poured in the U.S., and a certification must be provided to the CBP. If these requirements are met, the product will not be subject to the additional duty, regardless of origin. Similarly, importers must provide CBP with information to identify the aluminum content of aluminum products. CBP will issue guidance or regulations on the required documentation as soon as possible.

 

 

 

February 4th, 2025

Trade Alert: Tariffs on Chinese Imports

Beginning this morning, February 4th, at 12:01 a.m., a 10% tariff will be applied to imports from China and Hong Kong. The tariff will be in addition to the standard tariff rate, the Section 301 additional duty, and any applicable antidumping/countervailing duties.

If you provide evidence that your goods were on a vessel or in transit by 12:01 a.m. ET on February 1st, your goods will not be subject to these tariffs as long as they are entered for consumption before March 7th.

Items with Section 301 exclusions or Miscellaneous Trade Bill duty suspensions/reductions are still subject to 10% tariffs.

No drawback will be allowed for these tariffs. However, duty drawbacks are still permitted for other eligible duties.

Below is a U.S Customs CSMS message and an unpublished Federal Register Notice that provides guidance on the implementation of the tariffs:

CSMS (Customs Messenging Service)

Federal Register Notice

In response to the U.S. tariffs, China’s Finance Ministry announced it will impose its own tariffs starting February 10th. These will include a 15% tariff on U.S. liquified natural gas and coal imports and a 10% tariff on crude oil, farm equipment, and some autos. Further, they filed a formal complaint with the World Trade Organization (WTO).

 

 

 

February 3rd, 2025

Trade Alert: Tariffs on Canadian Imports Postponed for 30 Days

At 3 p.m. today, United States President Donald Trump and Canadian Prime Minister Justin Trudeau met to negotiate. They have just announced that they have postponed tariffs on Canadian imports for 30 days. The Canadian government has agreed to move 10,000 frontline personnel to the Canadian-U.S. border.

As for China, there has been no news of negotiations between the two governments. Below, you can find an unpublished version of the Federal Register Notice.

Implementation of Additional Duties on Products of the People’s Republic of China

 

 

 

February 3rd, 2025

Trade Alert: Trump Imposes Tariffs on Mexico, Canada, and China

Due to the fluidity of information availability and ongoing negotiations, our team has been closely monitoring the situation to ensure we provide our customers with accurate and up-to-date information. Here’s what we know now:

On Saturday, February 1st, President Donald Trump announced that he would impose a 25% tariff on Canadian (10% tariff on Canadian energy resources) and Mexican imports and a 10% tariff on imports from China.

It was recently announced that tariffs on Mexican imports will be postponed for 30 days. Mexican President Claudia Sheinbaum and President Trump have agreed to take joint measures to fight fentanyl trafficking across the U.S. border. Mexico has agreed to send 10,000 soldiers to the U.S-Mexico border to help prevent drug trafficking.

We also understand that President Trump and Canadian Prime Minister Trudeau will be meeting today at 3 p.m. ET.

If no further action is taken, tariffs on Canadian and Chinese imports will take effect at 12:01 AM Eastern Standard Time on February 4th, 2025. If you provide evidence that your goods were on a vessel or in transit by 12:01 AM ET on February 1st, then your goods will not be subject to these tariffs.

Fact Sheet: President Donald J. Trump Imposes Tariffs on Imports from Canada, Mexico and China

President Trump claims by imposing tariffs on these countries; he is holding them accountable for their promises to stop illegal immigration and prevent the flow of dangerous fentanyl and other drugs into the U.S.

Canada has announced 25% retaliatory tariffs on $155 billion worth of goods in response to the U.S.’s new tariffs. China has yet to respond, but we anticipate that they will announce retaliatory tariffs if no settlement is reached in the interim.

 

As always, do not hesitate to contact your Rogers & Brown representative or email us at [email protected] with any questions or concerns. We will keep you updated as we receive new information.

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