The New Trade Landscape 2025

Section 301 Exclusions
On May 31, 2025, the United States Trade Representative (USTR) granted a three-month extension of certain exclusions from the China Section 301 tariffs. This extension expires on August 31, 2025. Read the official USTR Notice.

Tariff on Indian Imports
Effective on August 27, 2025, the United States will impose an additional 25% ad valorem tariff on imports of Indian products. This is in addition to the 25% reciprocal tariff, which took effect on August 7, 2025. View more details in our previous trade alert.

Section 321 Exemption Suspended
On July 30, 2025, President Trump signed an Executive Order suspending the de minimis exemption for commercial shipments globally, effective on August 29, 2025. As a result, imported goods sent through means other than the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties.

For more information on this Executive Order, listen to the recent episode of our podcast Time Out for Trade, where Amy Magnus, Director of Customs Affairs & Compliance, explains the implications of the de minimis suspension. Watch it here.

Canada to Remove Tariffs on US Goods Covered by CUSMA
On August 22, 2025, the Canadian Government announced plans to eliminate tariffs on US goods that are covered by the Canada-US-Mexico Agreement (CUSMA), effective September 1, 2025. Canada’s 25% counter-tariffs on US steel, aluminum, and automotives will remain in place for now. The full statement from the Office of the Prime Minister of Canada can be found here.

On August 15, 2025, the Trump Administration greatly expanded the list of goods subject to 50% tariff included within Section 232 Aluminum and Steel duties. This is a significant development that U.S. importers should take note of, since the new list of HTS codes now includes a large number of products previously not considered steel or aluminum derivatives. These duties are now required (August 18, 2025), and the provision does not include exceptions for goods in transit.

As noted by attorney Michael Roll: 

"Many of these new HTS provisions would not normally be considered aluminum or steel derivative products ... at least not by any reasonable understanding of those words. For example... the list of goods now subject to the aluminum and steel tariffs include items as diverse as dairy products (0402), food preparations (2106), petroleum oils (2710), and certain chemicals, etc. While the 50% tariff will only apply to the aluminum/steel aspects of these goods (which will presumably be just certain aluminum and steel packaging or container type materials), it shows just how broad this administration intends to throw its tariff net".

Roll also states:

"Importers will recall that earlier this year the Trump Administration significantly expanded the list of products considered to be "steel derivative" and "aluminum derivative" products. The historic expansion of the 232 tariffs on aluminum and steel derivative products was only the beginning of the tariff nightmare for importers and brokers. The White House also allowed private parties to petition the Department of Commerce to include more products as aluminum and steel derivative products.

Under the "inclusion" process, the Department of Commerce created a process where every May, September and January, it will open up a two (2) week submission window to allow companies to ask for additional products to be included as aluminum or steel derivative products subject to the 50% tariff. The public will then have 2 weeks to review and comment on such proposals and Commerce will act on the petitions and comments within 60 days. See here for the relevant Federal Register notice.

On May 1, 2025, Commerce opened the first submission window. Over 50 companies asked Commerce to include hundreds of additional HTSUS classifications as aluminum and steel derivative products. On May 20, 2025, Commerce posted the petitions to regulations.gov, thereby starting the 14 day window for importers and the public to comment. The deadline for submitting comments was June 4, 2025. Friday's announcement represents the culmination of this first inclusion process. Next month, another window will open for parties to request even further expansion of the aluminum and steel tariff coverage."

To further aid our customers and partners, Deringer has compiled the government's list of additional products into a user-friendly Excel file.  The Unofficial New Expanded Section 232 Derivative List of August 15, 2025 may be downloaded from our Forms page.

Source:  Michael Roll, Roll & Harris LLP

On August 6, 2025, President Trump issued an Executive Order imposing an additional 25% ad valorem tariff on Indian product imports into the United States, effective 12:01 a.m. ET on August 27, 2025. This action is in response to India’s continued importation of Russian oil amid ongoing conflict in Ukraine.

This tariff is in addition to the 25% reciprocal tariff scheduled to take effect on August 7, 2025. Exceptions apply to goods that:

• Were loaded and in transit prior to 12:01 a.m. ET on August 27, and

• Are entered for consumption or withdrawn from warehouse before 12:01 a.m. ET on September 17, 2025.

Per the EO, the additional duty will not apply to:

• Articles subject to Section 232 actions under the Trade Expansion Act of 1962

• Articles excepted by 50 U.S.C. 1702(b)

• Articles listed in Annex II of Executive Order 14257 (April 2, 2025), as amended

Goods admitted into a Foreign Trade Zone on or after August 27 must be entered under privileged foreign status, unless eligible for domestic status under 19 CFR 146.43.

A. N. Deringer, Inc. will continue to monitor developments and provide updates as additional guidance becomes available from U.S. Customs and Border Protection.

The U.S. Presidential Administration issued an Executive Order and Fact Sheet addressing new International Emergency Economic Powers Act (IEEPA) Reciprocal Tariff rates for multiple countries, effective on August 7, 2025.

Key provisions outlined in the Executive Order and Fact Sheet include:

• There are two groups addressed in this Order:

  • Effective August 7th, goods from countries listed in Annex 1 will be subject to tariff rates as shown in the list provided by the White House. (The current IEEPA 10% tariff rate will remain in effect until August 7th for these countries.)

  • Countries that are not listed in Annex 1, will continue to be subjected to a 10% tariff. (This is consistent with IEEPA Reciprocal tariffs published April 2nd.)

    • Brazil is a notable exception – and is currently levied a 10% Reciprocal tariff stacked on the recently announced 40% tariff, for a total of 50%.

• There is an in-transit provision importers should note:

  • “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 [August 7, 2025], and entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. eastern daylight time on October 5, 2025,” shall not be subject to the new rates, and remain subject to the 10% additional duty.

• The order also addresses transshipments, although a definition of ‘transshipment’ is not yet published:

  • If CBP determines there is a ‘transshipment’, it will be subject to a 40% tariff rate as well as any additional applicable duties, as well as possible fines or penalties.

  • The U.S. Government will also publish circumvention schemes and countries every six months to inform the public, national security reviews, and commercial due diligence.

Tariff Status for China, Canada, and Mexico:

• Recent negotiations between the U.S. and China has not yielded any formal changes, so current duty rates for the country include:

  • 10% IEEPA duties

  • 20% Fentanyl tariff

  • Section 301 tariffs

  • Section 232 duties

  • Most favored nations tariffs

• On July 31, 2025 Mexico received a 90-day extension for IEEPA negotiations.

• Effective today, August 1, Canadian goods imported to the U.S. that do not qualify for the U.S.-Mexico-Canada Agreement (USMCA) are now subject to a 35% tariff.

Annex 1

 USMCA Goods Remain Exempt 

President Trump issued an Executive Order raising the duties on Canadian goods bound for the U.S. from 25% to 35%, effective today, August 1, 2025. The order clearly states that “Goods qualifying for preferential tariff treatment under the United States-Mexico-Canada Agreement (USMCA) continue to remain not subject to the IEEPA Canada tariffs.”

Another important change noted in the Executive Order raises the tariff on transshipments from 35% to 40%. U.S. Customs and Border Protection (CBP) has issued official guidance through its Cargo Systems Messaging Service (CSMS, #65798609) overnight, with guidance on the additional duties on Canadian imports.

Recap of Executive Orders and Proclamations enacted by U.S. President Donald Trump on 7/30/2025

De Minimis Suspension
President Trump signed an Executive Order suspending the de minimis exemption for commercial shipments globally, effective on August 29. This means imported goods sent through means other than the international postal network that are valued at or under $800 and that would otherwise qualify for the de minimis exemption will be subject to all applicable duties.

U.S. Copper Imports Subject to 50% Tariffs
President Trump issued a Proclamation stating that all imports of semi-finished copper products and intensive copper derivative products will be subject to a 50% tariff, effective on August 1st. This measure applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on Aug. 1 and will remain in effect, unless such action is expressly reduced, modified, or terminated, according to the Proclamation. The Proclamation also states, “This tariff is in addition to any other duties, fees, exactions, and charges applicable to such imported semi-finished copper products and intensive copper derivative products.”

Tariffs on Brazilian Imports Increased to 50%
President Trump signed an Executive Order implementing an additional 40% tariff on Brazilian products under IEEPA, which brings the total tariff amount to 50%. The Trump Administration cites these tariffs are in response to “recent policies, practices, and actions by the Government of Brazil that constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States.”

Major Tariff Changes & Investment Commitments

On July 27, 2025, President Trump and European Commission President von der Leyen announced a new U.S.–E.U. trade agreement with major implications for transatlantic commerce.

The E.U. will eliminate tariffs on U.S. goods and commit to $750 billion in U.S. energy purchases and $600 billion in U.S. investments. In return, the U.S. will reduce tariffs on E.U. goods, including autos, from 30% to 15%. However, steel and aluminum from the E.U. will remain subject to a 50% tariff.

For more information, click here to read the NCBFAA briefing.

Tariff enforcement postponed as negotiations continue

President Trump signed an Executive Order delaying the start of country-specific reciprocal tariffs from July 9 to August 1, 2025, citing ongoing trade talks and updated guidance. He also confirmed that 14 countries received letters warning of tariff hikes above 10% if no deals are reached by August 1, with more countries possibly to follow. These 14 nations represent a significant share of affected U.S. imports, broken down as follows:

1. Japan: 25%
2. South Korea: 25%
3. Tunisia: 25%
4. Malaysia: 25%
5. Kazakhstan: 25%
6. South Africa: 30%
7. Bosnia & Herzegovina: 30%
8. Indonesia: 32%
9. Serbia: 35%
10. Bangladesh: 35%
11. Thailand: 36%
12. Cambodia: 36%
13. Laos: 40%
14. Myanmar: 40%

The President mentioned an agreement with Vietnam, though no details have been released, leaving the nature of the deal open to speculation. He also announced via Truth Social that the U.S. has agreed with China to supply magnets and rare earth elements, and that student visas would be issued to Chinese citizens. Further specifics on both agreements have yet to be disclosed.

The delay affects specific tariff provisions in the Harmonized Tariff Schedule (HTSUS), which will remain suspended until the new effective date. Currently, the separate tariff suspension related to China under Executive Order 14298 remains unchanged.

For more information please visit: Extending the Modification of the Reciprocal Tariff Rates – The White House

U.S. Customs and Border Protection (CBP) has issued new guidance on how to report the country of smelt and cast on derivative aluminum imports for products subject to Section 232 aluminum measures when the importer does not know the country of smelt and cast.

Effective June 28, 2025, if the country of smelt and/or cast is unknown for such imports, then the importers should report “unknown” in lieu of the International Organization for Standardization (ISO) code for the unknown smelt and cast country.

When reporting “unknown”, importers will be required to report HTS 9903.85.67 or 9903.85.68, as applicable. These entries will be assessed the 200 percent Section 232 duties on imports of aluminum from Russia.

Detailed documents about the accompanying updates in ACE and the Entry Summary Error Dictionary are available on the ACE CATAIR webpage in the Draft Chapters: Future Capabilities section. This effort will deploy to the Certification and Production environments on June 28, 2025. More information related to Section 232 entry filing requirements can be found on the CBP website here.

Currently, we do not know if these changes will apply retroactively. A.N. Deringer, Inc. will continue to monitor the Federal Register, White House, and U.S. Customs and Border Protection official notifications, as well as the alerts posted by our partners and stakeholders, to keep our customers apprised of U.S. tariff changes and relevant policy changes.

Source: CBP

On June 12, the U.S. Department of Commerce announced in the Federal Register that household appliances will be subject to the steel and aluminum tariffs at the current rate of 50%, beginning on June 23, 2025. The tariffs assessed on these derivative products will be based on the value of the steel content in each appliance.

The specific derivative products noted in the Federal Register include:
• Refrigerators with freezers;
• Dryers;
• Washing machines;
• Dishwashers;
• Chest and upright freezers;
• Cooking stoves, ranges and ovens;
• Food waste disposals; and
• Welded wire racks.
A.N. Deringer, Inc. will continue to monitor the Federal Register, White House, and U.S. Customs and Border Protection official notifications, as well as the alerts posted by our partners and stakeholders, to keep our customers apprised of U.S. tariff changes and relevant policy changes.

Sources: Reuters, Federal Register

On June 10, the Court of Appeals for the Federal Circuit continued the stay it previously put in place regarding the Court of International Trade’s May 28th decision declaring the IEEPA tariffs unauthorized. The appeals court has scheduled an oral argument on the appeal’s merits on July 31, 2025, at 10:00 am and asked the parties to propose deadlines to submit their written arguments. Consequently, CBP will continue to collect the fentanyl tariffs initiated in February 2025, along with the reciprocal tariffs that started in April 2025, for the foreseeable future.

On June 11, U.S. and Chinese trade negotiators wrapped up two days of intensive talks. As reported by The Wall Street Journal, this deal was based in part on Beijing’s promise to speed export licenses of rare-earth minerals, whilst the trade negotiations continued between the two nations. The U.S. side, led by Treasury Secretary Scott Bessent and Commerce Secretary Howard Lutnick, negotiated to accelerate China’s exports of rare earths and magnets containing them. The Chinese delegation, led by Vice Premier He Lifeng, a trusted Xi aide, negotiated for the U.S. side to significantly loosen restrictions on the sale of technology and other products to China.

Reuters noted that a “White House official said the agreement allows the U.S. to charge a 55% tariff on imported Chinese goods. This includes a 10% baseline ‘reciprocal’ tariff, a 20% tariff for fentanyl trafficking and a 25% tariff reflecting pre-existing tariffs. China would charge a 10% tariff on U.S. imports, the official said.”

A.N. Deringer, Inc. will monitor U.S. Customs and Border Protection (CBP) messaging as well as the Federal Register for clarifications, guidance, and effective date(s).

Sources: The Wall Street Journal, Reuters

Following through on a social media post from this past weekend, U.S. President Trump issued a Presidential Proclamation on June 3, 2025 that declares an increase from 25% to 50% on imported steel and aluminum effective 12:01 a.m. ET June 4, 2025.

The proclamation has key changes importers will need to heed, including:

• Mexico and Canada: Imported steel and aluminum goods subject to the Section 232 tariffs will not be subject to the fentanyl tariffs on Canadian and Mexican origin goods.  Previously, goods subject to fentanyl tariffs on Canadian and Mexican origin goods were exempt from steel and aluminum Section 232 tariffs. The stacking order has been swapped. This means that the 50% duty rate for steel and aluminum imports now has priority over fentanyl tariffs on Canadian and Mexican goods, effective today.
• Products containing derivatives: According to trade attorney Michael Roll, the “White House previously had said, in the case of aluminum and steel derivative products that the non-aluminum/non-steel portion of such goods would not be subject to any reciprocal tariffs, but today's announcement states that reciprocal tariffs will, in fact, apply to the non-aluminum/non-steel portion of the goods..."  
  • For derivative steel and aluminum goods with non-steel or non-aluminum content – exemption from the IEEPA Reciprocal duties under 9903.01.33 is no longer in effect as of today for the non-metal portion of the good.  However, products of Canada and Mexico are still exempt from reciprocal duties under their country-specific exemptions.
  • All non-metal content of a good that was split to pay Section 232 duty now has to pay the IEEPA Reciprocal Baseline duty of 10% under Harmonized Tariff System code 9903.01.25, unless another exemption from reciprocal duties applies.
• Chapter 73 and Chapter 76 duty due only on steel and aluminum content: All articles and derivative articles classified in Chapter 73 and Chapter 76 subject to 232 duties, the 50% duty (25% for products of the UK) is to be reported with the Chapter 99 classification based upon the value of the subject metal content. This means that articles classified in Chapters 73 and 76 that previously had duty due on the full value of the article can now declare the value of the subject metal content for 232 duty calculation purposes and the non-metal content will be subject to reciprocal duties.
• Foreign Trade Zones (FTZs): Goods previously entered into an FTZ under "privileged foreign status" (which previously applied the tariff rate to the goods based on the date of admittance into the FTZ), and that are listed in Annex II of the Proclamation (which will be published in the Federal Register) are now subject to the duty rate that is in effect on the date the goods are withdrawn from the FTZ and entered for consumption.
• United Kingdom: The Section 232 tariffs on aluminum and steel from the United Kingdom will remain at 25% - for all other countries that previously faced a 25% Section 232 tariff on aluminum and steel, including derivative products, the rate will double to 50% starting today.
• Enforcement: The White House warned that importers who submit underreported declarations may be subject to severe consequences, including maximum penalties for noncompliance.

Deringer also notes that today is a key deadline for importers wishing to communicate opposition to the Department of Commerce increasing the list of aluminum and steel derivative products.  Should the Department follow through with expanding the list, existing aluminum and steel products (including derivatives) will be subject to 50% tariff rate.  Harris & Roll has published a helpful and ‘unofficial’ list of the HTSUS codes currently being proposed for inclusion in the aluminum and steel tariffs, while the official posting of the proposed expansions may be found here.

A.N. Deringer, Inc. will continue to monitor the Federal Register, White House, and U.S. Customs and Border Protection official notifications, as well as the alerts posted by our partners and stakeholders, to keep our customers apprised of U.S. tariff changes and relevant policy changes.

Sources: NCBFAA, Roll & Harris LLP

On May 30th, President Trump announced the doubling of aluminum and steel tariffs from 25% to 50%, effective June 4th. Importers must wait for the official legal documents to confirm this decision. The increased tariffs will impact not only aluminum and steel products classified in chapters 72, 73, and 76 of the Harmonized Tariff Schedule of the United States (HTSUS) but also a broad range of aluminum and steel derivative products currently facing the 25% tariff.

It is anticipated that the Department of Commerce will significantly expand the list of affected products. This means that, in addition to existing aluminum and steel products (including derivatives) being subject to 50% tariffs, more products are likely to be included under the increased tariffs soon.

There is still time to comment on the proposed expanded coverage of aluminum and steel tariffs, but importers must act quickly, as the deadline for filing comments is June 4th.

There has been no official issuance from CBP and Deringer is awaiting further instructions regarding implementation. A.N. Deringer, Inc. will continue to update our customers and stakeholders accordingly.