United States Tariffs Guide for May, 2025

ByAaron Hall Business Law

Note: The following was prepared on May 2, 2025. However, due to the regular changes in tariff law, you should not rely on the accuracy of this information. Instead, consult with your attorney for current information and advice.

Table of Contents

Introduction: Understanding the U.S. Tariff Landscape (May 2025)

Overview of the Multi-Layered U.S. Tariff System

Determining the duties applicable to goods imported into the United States requires navigating a complex, multi-layered system. As of May 2, 2025, importers face not only the baseline tariff rates established in the Harmonized Tariff Schedule of the United States (HTSUS) but also potential additional duties imposed under specific trade remedy laws. Chief among these are tariffs enacted under Section 301 of the Trade Act of 1974, primarily targeting goods originating from China, and tariffs under Section 232 of the Trade Expansion Act of 1962, which apply globally to imports of steel, aluminum, and an expanding list of related derivative products.1 Furthermore, significant additional tariffs were implemented in early 2025 under the International Emergency Economic Powers Act (IEEPA) and Section 232 authority targeting automobiles and parts.

U.S. trade policy is dynamic, subject to administrative actions, investigations, and legislative changes. Recent years, particularly early 2025, have witnessed significant modifications, most notably a radical restructuring and expansion of the Section 232 measures effective March 12, 2025 3, the imposition of broad “reciprocal tariffs” under IEEPA effective April 5, 2025, and new Section 232 tariffs on automobiles effective April 3, 2025. Concurrently, adjustments continue under the Section 301 regime concerning China, with phased tariff increases impacting strategic sectors.1 These actions underscore the importance for businesses involved in international trade to remain vigilant and informed about the current state of U.S. tariff regulations. The imposition of these additional tariffs relies on distinct statutory authorities, reflecting different policy objectives, from addressing unfair trade practices (Section 301) 1 to protecting national security (Section 232) 3 or addressing declared national emergencies (IEEPA).

Importance of the Harmonized Tariff Schedule (HTS) as the Foundation

The Harmonized Tariff Schedule of the United States (HTSUS) serves as the cornerstone of the U.S. tariff system. It provides the comprehensive classification structure and baseline duty rates for virtually all merchandise imported into the country.11 Based on the internationally recognized Harmonized System (HS) nomenclature, the HTSUS assigns specific codes to products, which determine the applicable standard tariff treatment.11 Correctly classifying goods according to the HTSUS is the indispensable first step in the import process; only after establishing the proper HTS classification can an importer accurately determine the applicability of any additional duties, such as those under Section 301, Section 232, or IEEPA.14

Introduction to Additional Tariff Regimes (Section 301, Section 232, IEEPA)

Layered on top of the HTS baseline rates are significant additional tariffs enacted under specific trade laws and executive authorities. Section 301 tariffs, stemming from investigations conducted by the Office of the U.S. Trade Representative (USTR), currently focus almost exclusively on goods imported from China. These tariffs were initially imposed following a USTR determination that China’s practices related to technology transfer, intellectual property, and innovation were unreasonable or discriminatory and burdened U.S. commerce.1

Section 232 tariffs derive from investigations by the Department of Commerce into the national security impact of certain imports. Initially implemented in 2018 on steel and aluminum from most countries, these measures underwent a dramatic expansion in early 2025, increasing the tariff rate on aluminum, eliminating all country exemptions and product exclusion processes, and significantly broadening the scope to include numerous downstream derivative products containing steel or aluminum.3 Section 232 authority was also invoked in April 2025 to impose tariffs on imported automobiles and auto parts. Furthermore, active Section 232 investigations into other sectors, such as copper, semiconductors, and pharmaceuticals, signal the potential for further expansion of this trade tool.4

International Emergency Economic Powers Act (IEEPA) tariffs were implemented in early 2025, citing national emergencies related to trade deficits, border security, and fentanyl trafficking. These include tariffs imposed specifically on China, Canada, and Mexico in February/March, followed by broad “reciprocal tariffs” applied globally (with exceptions) starting in April. IEEPA was also used to effectively eliminate the de minimis duty exemption for low-value shipments from China and Hong Kong.

Report Scope and Objective

This report provides a comprehensive overview of the U.S. tariff structure as it stands on May 2, 2025. It focuses on explaining the HTSUS framework and detailing the status and implications of the major additional duty regimes – Section 301 tariffs on Chinese goods, Section 232 tariffs on steel, aluminum, their derivatives, and automobiles/parts, and the IEEPA-based tariffs including the “reciprocal tariffs” and measures targeting low-value shipments. The analysis incorporates the latest significant changes, particularly the overhaul of Section 232 measures effective March 2025, the implementation of reciprocal and auto tariffs in April 2025, and ongoing modifications under Section 301. The objective is to equip importers, exporters, logistics professionals, trade consultants, and policy analysts with a clear understanding of the current tariff landscape to inform compliance efforts, strategic planning, and risk assessment. While this report cannot reproduce the entirety of the voluminous HTSUS, it will guide users on how to access and navigate official resources in conjunction with understanding the superimposed Section 301, Section 232, and IEEPA measures.

The Harmonized Tariff Schedule (HTS) Framework

Explanation of HTS Structure

The HTSUS is a meticulously organized, hierarchical classification system essential for importing goods into the United States. It is based on the international Harmonized System (HS), ensuring a degree of global uniformity in product classification.11 The HTSUS is structured into Sections, which group related industries or materials, and further divided into 99 Chapters. Each Chapter covers specific product categories (e.g., Chapter 1: Live Animals; Chapter 27: Mineral Fuels; Chapter 72: Iron and Steel; Chapter 87: Vehicles; Chapter 95: Toys, Games and Sports Requisites).12

Within Chapters, classifications become progressively more specific through:

  • Headings: 4-digit codes identifying broader product groups.
  • Subheadings: 6-digit codes aligned with the international HS standard.
  • U.S. Tariff Rate Lines: 8-digit codes specific to the U.S., determining the applicable duty rate.
  • Statistical Reporting Lines: 10-digit codes used for trade data collection.14

For each 8-digit tariff line, the HTSUS typically provides duty rates in several columns. The primary columns are:

  • Column 1 (Rates of Duty): This column contains the standard duty rates applicable to imports from countries with which the U.S. maintains Normal Trade Relations (NTR), formerly known as Most Favored Nation (MFN) status. It is further subdivided into:
  • General: The standard NTR rate.
  • Special: Preferential or duty-free rates applicable under various Free Trade Agreements (FTAs) or specific trade preference programs (e.g., USMCA, AGOA, GSP), provided the goods meet the relevant origin and documentation requirements outlined in the General Notes.19
  • Column 2 (Rates of Duty): This column lists significantly higher statutory rates applicable to imports from countries subject to trade restrictions, currently including Cuba and North Korea. Specific actions have also subjected imports from Russia to Column 2 rates.19

Accessing and Utilizing Official HTS Resources

The definitive and official source for the HTSUS is the U.S. International Trade Commission (USITC), which publishes and maintains the schedule.11 The USITC website (hts.usitc.gov) provides several ways to access this critical information:

  • Online Search Tool: Allows users to search the HTSUS by keyword, HTS code, or phrase.11 The search supports various functionalities like “Contains Any,” “Contains All,” and “Contains Phrase”.24
  • Downloadable PDF Files: The entire HTSUS, or individual Sections and Chapters, can be downloaded in PDF format.12 This includes essential components like the Preface, General Notes, and specific appendices (e.g., Chemical, Pharmaceutical).18
  • Bulk Data Files: For users requiring the full dataset for analysis or integration into systems, the HTSUS is available for download in CSV, Excel, and JSON formats via the U.S. government’s open data portal (Catalog.data.gov).13

The HTSUS is subject to periodic updates and revisions to reflect legal changes, statistical modifications, and international HS amendments. As of early May 2025, the current version might be designated as “2025 HTS Revision 10” or similar.13 The official update frequency is noted as approximately every six months (“R/P6M”), but revisions can occur more frequently.13 Therefore, importers must ensure they are always referencing the most current version of the HTSUS to determine accurate classifications and duty rates.

Understanding General Rules of Interpretation (GRIs) and General Notes

Accurate HTS classification extends beyond simply finding a matching product description. The HTSUS includes legally binding rules that govern its application:

  • General Rules of Interpretation (GRIs): These six rules provide the fundamental principles for classifying goods within the HTSUS hierarchy. They dictate how to proceed when a product might appear classifiable under multiple headings or how to classify incomplete articles, mixtures, or goods put up in sets for retail sale (GRI 3).19 Understanding and correctly applying the GRIs is essential for defensible classification.
  • General Notes (GNs): Located at the beginning of the HTSUS, the General Notes contain overarching rules and definitions applicable throughout the schedule.19 They define key concepts like the Customs Territory of the U.S. (GN 2), explain the different rates of duty (GN 3), and detail the eligibility requirements and specific provisions for various preferential tariff programs, such as the Generalized System of Preferences (GSP, GN 4), the Caribbean Basin Economic Recovery Act (CBERA, GN 7), the United States-Mexico-Canada Agreement (USMCA, GN 11), the African Growth and Opportunity Act (AGOA, GN 16), and numerous bilateral FTAs (e.g., Israel GN 8, Jordan GN 18, Singapore GN 25, Chile GN 26, Australia GN 28, Korea GN 33, Japan GN 36).19 These notes are legally binding and critical for determining final duty liability.

Role of USITC vs. Customs and Border Protection (CBP)

It is crucial to understand the distinct roles of the two primary agencies involved with the HTSUS. The USITC is responsible for publishing and maintaining the HTSUS document itself, ensuring it reflects current U.S. law and international agreements.11 However, the authority to interpret the HTSUS, provide legally binding advice on the classification of specific imported goods, determine duty rates upon entry, and administer the collection of tariffs at U.S. ports of entry rests solely with U.S. Customs and Border Protection (CBP), part of the Department of Homeland Security.11 Importers seeking definitive guidance on classifying a particular product should utilize CBP’s resources, such as the binding ruling program.

Complexity and Risk in HTS Classification

The structure of the HTS, combined with the legally binding GRIs and General Notes, makes tariff classification a complex undertaking. It is far more than a simple lookup exercise. The HTS represents a legal framework, and its interpretation requires careful consideration of product characteristics, relevant section and chapter notes, the GRIs, and potentially prior CBP rulings or court decisions. This complexity arises because the official schedule 11 is governed by these interpretive rules 19 and enforced by CBP 11, which issues guidance on specific applications, such as classifying sets under GRI 3 for Section 301 purposes.21 Consequently, misclassification, even if unintentional, can expose importers to significant risks, including underpayment of duties leading to penalties, customs delays, increased scrutiny, and potential legal challenges. Diligent and informed classification is paramount for compliance.

Section 301 Tariffs: Focus on China (as of May 2, 2025)

Background and Rationale

Section 301 of the Trade Act of 1974 serves as a principal tool for the U.S. government to address foreign trade practices perceived as unfair or harmful to U.S. commerce. It empowers the U.S. Trade Representative (USTR) to investigate such practices and, if confirmed, to take retaliatory action, including imposing tariffs.1

In August 2017, USTR initiated a Section 301 investigation specifically targeting the acts, policies, and practices of the Government of China related to technology transfer, intellectual property (IP), and innovation.1 Following the investigation, USTR concluded in March 2018 that China’s policies in these areas were unreasonable or discriminatory and burdened or restricted U.S. commerce, causing harm to the U.S. economy.1 This finding formed the legal basis for the imposition of additional tariffs on a wide range of imports from China.

Initial Tariff Implementation (Lists 1-4A)

Beginning in July 2018, the U.S. implemented these Section 301 tariffs in stages, imposing additional ad valorem duties on specific lists of products imported from China. This resulted in four main tranches of tariffs:

  • List 1: Effective July 6, 2018, targeting approximately $34 billion in imports, primarily focused on industrial goods and technology components.16
  • List 2: Effective August 23, 2018, covering an additional $16 billion in imports, also largely consisting of industrial goods.16
  • List 3: Effective September 24, 2018 (initially at 10%, later increased to 25%), encompassing roughly $200 billion in imports across a broad spectrum of consumer and intermediate goods.16
  • List 4A: Effective September 1, 2019, applying tariffs (initially 15%, later reduced to 7.5% for many items) to approximately $120 billion worth of imports, heavily weighted towards consumer goods.16 (List 4B was proposed but never implemented).

Collectively, these actions subjected roughly $360-$370 billion worth of annual imports from China (based on trade figures at the time) to additional tariffs ranging from 7.5% to 25%.1 The product scope was extensive, covering categories such as machinery, electronics, chemicals, plastics, furniture, apparel, footwear, and toys.9 USTR maintains official lists identifying the specific 8-digit HTSUS subheadings covered by each action.14

Current Status (May 2025): Tariff Rates and Recent Modifications

As of May 2, 2025, the Section 301 tariffs on Lists 1, 2, 3, and 4A generally remain in effect. However, following a mandatory four-year review concluded by USTR 2, significant modifications were announced, primarily involving substantial tariff increases on specific products deemed critical to U.S. strategic interests, particularly in sectors like green technology, semiconductors, medical supplies, and infrastructure. These increases often took effect on September 27, 2024, or January 1, 2025, with further increases scheduled for January 1, 2026.1

The table below summarizes key modifications announced as part of the four-year review and subsequent actions, reflecting the status as of May 2, 2025. It is important to note that these tariffs apply in addition to the baseline HTSUS rates and potentially other tariffs (see Section VI on Tariff Interactions).

Table 1: Summary of Key Section 301 Tariff Modifications on Imports from China (Status as of May 2, 2025)

Product Group / Description Illustrative HTS Chapters/Subheadings Previous Section 301 Rate (%) New/Current Section 301 Rate (%) Effective Date of Change Snippet Reference
Electric Vehicles (EVs) 87 25% 100% Sep 27, 2024 8
Lithium-ion EV Batteries 8507 7.5% 25% Sep 27, 2024 8
Battery Parts (non-lithium-ion) 8507 7.5% 25% Sep 27, 2024 8
Lithium-ion Non-EV Batteries 8507 7.5% 25% Jan 1, 2026 8
Solar Cells (whether or not assembled) 8541 25% 50% Sep 27, 2024 8
Semiconductors 8541, 8542 25% 50% Jan 1, 2025 8
Certain Steel & Aluminum Products 72, 73, 76 0% or 7.5% 25% Sep 27, 2024 8
Ship-to-Shore Gantry Cranes 8426 0% 25% Sep 27, 2024 8
Syringes and Needles (excl. enteral until 2026) 9018 0% 100% Sep 27, 2024 8
Certain Respirators/Facemasks (non-surgical/surgical) 6307, 9020 7.5% 25% Sep 27, 2024 8
Certain Respirators/Facemasks (non-surgical/surgical) 6307, 9020 25% 50% Jan 1, 2026 8
Rubber Medical/Surgical Gloves 4015 7.5% 50% Jan 1, 2025 8
Rubber Medical/Surgical Gloves 4015 50% 100% Jan 1, 2026 8
Certain Critical Minerals Various 0% 25% Sep 27, 2024 8
Natural Graphite 2504 0% 25% Jan 1, 2026 8
Permanent Magnets 8505 0% 25% Jan 1, 2026 8
Tungsten Products (certain HTS) 8101.94, 8101.99 0% 25% Jan 1, 2025 (or proposed) 1
Polysilicon / Wafers (certain HTS) 2804.61, 3818.00 25% 50% Jan 1, 2025 (or proposed) 1

Note: Effective dates and specific HTS coverage should always be verified with official USTR documentation.

Additionally, the Trump administration, upon returning to office, proposed a further 10% ad valorem duty on all imports from China, potentially impacting goods already subject to Section 301 tariffs, though the status and implementation details of this proposal require ongoing monitoring.9 Section 301 duties are applied based on the country of origin, which must be China (ISO code CN). Goods legitimately originating in Hong Kong (HK) or Macau (MO) are generally not subject to these specific Section 301 duties, unless explicitly included.21 However, other tariffs implemented in 2025 do apply to Hong Kong and Macau (see Sections V.D and V.E).

Exclusion Process Status

To mitigate unintended harm to U.S. businesses reliant on specific Chinese inputs, USTR initially established processes for requesting product-specific exclusions from the Section 301 tariffs for each of the four lists.1 Over 2,200 such exclusions were granted across the lists.1 However, most of these exclusions have since expired. A limited set of 164 exclusions, primarily related to COVID-19 response, were extended but were scheduled to expire on May 31, 2025.2

Following the four-year review, USTR announced a new, but significantly narrower, exclusion process.1 This process, which opened for requests on October 15, 2024, with a submission deadline of March 31, 2025, is limited solely to certain machinery used in domestic manufacturing classified under HTS Chapters 84 (Nuclear reactors, boilers, machinery, etc.) and 85 (Electrical machinery and equipment, etc.).1 This highly restricted scope means that exclusions are not available for the vast majority of products subject to Section 301 tariffs.

Ongoing Investigations and Potential Future Actions

The Section 301 tool remains actively deployed. USTR continues to monitor China’s trade practices and has initiated new investigations:

  • China’s Shipbuilding Sector: In April 2024, USTR launched a Section 301 investigation into China’s practices in the maritime, logistics, and shipbuilding sectors following a petition from U.S. labor unions.1 This could potentially lead to new tariffs or other actions targeting these industries.
  • Nicaragua Labor/Human Rights: In December 2024, USTR self-initiated a Section 301 investigation into Nicaragua’s practices concerning labor rights and human rights, marking a novel application of the statute to these issues.1
  • Legacy Semiconductors: There is potential for a future investigation focused on legacy semiconductors from China.1

Furthermore, USTR continues to monitor situations where Section 301 investigations led to proposed tariffs that were subsequently suspended, such as those concerning Digital Services Taxes (DSTs) imposed by Austria, France, India, Italy, Spain, Turkey, and the United Kingdom.1 These suspensions could potentially be lifted if underlying disputes are not resolved. The EU Large Civil Aircraft dispute also involves suspended tariffs under active monitoring.1

Implications for Importers and Trade Strategy

The evolution of the Section 301 tariffs against China reveals a shift in U.S. strategy. The initial broad application across multiple lists 16 has been refined through the four-year review, resulting in highly targeted, significant tariff increases on sectors central to current U.S. industrial policy goals: green energy (EVs, batteries, solar) 8, advanced technology (semiconductors) 8, and critical supply chains (medical supplies, certain minerals, infrastructure components like cranes).8 This strategic focus, coupled with the concurrent narrowing of the exclusion process primarily to capital equipment for domestic manufacturing 1, suggests a deliberate policy choice. The initial granting of over 2,200 exclusions acknowledged the potential for collateral damage to U.S. interests 1, but the current, highly limited exclusion availability indicates a reduced emphasis on mitigating such impacts for most goods. The policy appears more focused on leveraging the tariffs’ intended effects – namely, incentivizing shifts away from Chinese supply chains or promoting domestic production in targeted areas – even if this results in higher costs for U.S. importers of other goods.1

For businesses sourcing from China, the Section 301 regime represents a substantial and potentially growing layer of cost and complexity. The combination of high tariff rates (up to 100% in some cases) 8, the dynamic nature of the affected product lists and rates 1, and the very limited availability of exclusions 1 creates significant financial pressure and uncertainty. This environment strongly incentivizes companies to continuously monitor USTR actions, meticulously verify the applicability of tariffs to their specific products, and strategically evaluate alternative sourcing locations, such as Vietnam, India, Taiwan, or Thailand, to mitigate risk and cost.9 The impact of Section 301 tariffs is further compounded by other significant tariffs imposed on Chinese goods in 2025 (see Section V).

Section 232 Tariffs: Steel, Aluminum, and Derivatives (as of May 2, 2025)

Background and Rationale

Section 232 of the Trade Expansion Act of 1962 provides the President with the authority to adjust imports via tariffs or other restrictions if the Secretary of Commerce determines, following an investigation, that imports of a particular article threaten to impair U.S. national security.3

In 2018, based on investigations and reports from the Secretary of Commerce, President Trump determined that imports of steel and aluminum were occurring in quantities and circumstances that threatened national security.3 The stated rationale included the need to protect the viability of domestic steel and aluminum producers, ensuring sufficient domestic capacity utilization (with a target of 80%) to meet defense requirements and critical infrastructure needs, particularly in the face of global excess capacity, largely attributed to China.17 Consequently, tariffs of 25% on covered steel products and 10% on covered aluminum products were imposed on imports from most countries, effective March 2018.3

The Paradigm Shift: Radical Changes Effective March 12, 2025

The Section 232 landscape underwent a fundamental transformation in early 2025. Presidential Proclamations 10895 (Aluminum) and 10896 (Steel), issued on February 10, 2025, mandated sweeping changes that took effect at 12:01 AM Eastern Time on March 12, 2025.3 These changes significantly hardened the application of the tariffs:

  1. Increased Aluminum Tariff: The base Section 232 tariff rate on covered aluminum articles and derivative aluminum articles was increased from 10% to 25% ad valorem, aligning it with the steel tariff rate. Imports from Russia remain subject to a 200% tariff.3 These tariffs are applied in addition to any other applicable duties.5
  2. Elimination of All Country Exemptions, Quotas, and Tariff-Rate Quotas (TRQs): Perhaps the most impactful change was the termination of all previously negotiated country-specific exemptions, quotas, and TRQs.3 This means that imports of covered steel and aluminum products from countries that previously enjoyed full exemptions (Australia, Canada, Mexico) or managed trade arrangements (Argentina, Brazil, European Union, Japan, South Korea, United Kingdom) became subject to the full 25% tariff as of March 12, 2025.3 Ukraine’s temporary tariff suspension, previously extended to June 1, 2025, was also effectively terminated by the removal of all exemptions.3
  3. Termination of Product-Specific Exclusion Process: The process administered by the Department of Commerce’s Bureau of Industry and Security (BIS), which allowed U.S. companies to request exclusions for specific steel or aluminum products not available domestically in sufficient quantity or quality, was terminated effective 11:59 PM EST on February 10, 2025.5 No new exclusion requests are being considered or processed.30 Exclusions that had already been granted remain valid only until their original expiration date or until the approved import volume is reached, whichever comes first, with no possibility of renewal.5
  4. Termination of General Approved Exclusions (GAEs): All existing GAEs, which provided standing exclusions for certain categories of products without requiring individual applications, were also terminated effective March 12, 2025.3
  5. Massive Expansion to Derivative Products: The February 2025 proclamations significantly expanded the scope of Section 232 tariffs beyond primary steel and aluminum and the limited list of derivatives added in 2020.5 New, extensive lists of “derivative articles” – downstream products that incorporate steel or aluminum – were added via Annexes to the proclamations.3 These newly covered derivatives, estimated to represent approximately $150 billion in 2024 U.S. import value, span numerous HTS chapters, including many outside of Chapters 72, 73 (Iron/Steel), and 76 (Aluminum).3

Table 2: Overview of Section 232 Tariff Status (May 2, 2025)

Subject Material Base Section 232 Tariff Rate (%) Scope Country Application Status of Country Exemptions/Quotas Status of Product Exclusions Process Snippet References
Steel 25% Primary metal & extensive list of derivatives Global Terminated (March 12, 2025) Terminated (Feb 10, 2025) 3
Aluminum 25% (except 200% for Russia) Primary metal & extensive list of derivatives Global Terminated (March 12, 2025) Terminated (Feb 10, 2025) 3

Application to Derivative Products

The application of the 25% Section 232 tariff to derivative products depends on the specific product and its classification:

  • Derivatives Listed in Feb 2025 Proclamations (Outside Chapters 73/76): For derivative articles identified in the Annexes to Proclamations 10895/10896 that are not classified under HTS Chapter 73 (Articles of Iron or Steel) or Chapter 76 (Aluminum and Articles Thereof), the 25% ad valorem duty applies only to the value of the steel or aluminum content within the imported article, not the total value of the article.3
  • Derivatives Listed in 2020 Proclamation or in Chapters 73/76: For steel derivatives originally listed in Proclamation 9980 (Jan 2020, e.g., certain nails, bumper stampings classified under 8708.29.21) or for any derivative listed in the February 2025 proclamations that is classified under Chapter 73 (for steel) or Chapter 76 (for aluminum), the 25% tariff applies to the entire customs value of the imported merchandise.5

This bifurcated approach for derivatives, particularly the application based on metal content value for many newly covered items, introduces significant complexity for importers. Determining and documenting the specific value of the steel or aluminum content within a finished or semi-finished product requires robust tracking and potentially new accounting methods. While the Department of Commerce certified that a sufficient tariff collection system was in place by the March 12 effective date 6, importers may still face challenges in accurately declaring this value to CBP.32 An exception exists for derivative products processed abroad using steel or aluminum that was originally “melted and poured” (steel) or “smelted and cast” (aluminum) in the United States; these are not subject to the derivative tariffs.3

Process for Adding More Derivative Products

The potential scope of Section 232 derivative coverage may expand further. Effective April 30, 2025, BIS established an interim final rule outlining a process for interested parties (e.g., domestic manufacturers) to formally request that additional downstream products be added to the lists of steel and aluminum derivatives subject to Section 232 tariffs.34 BIS will accept these “inclusion requests” during specific two-week windows opening at the beginning of May, September, and January each year. The first window opened May 1, 2025. Submitted requests are posted for public comment, and BIS aims to make determinations within 60 days.34 This mechanism ensures that the list of affected downstream products could grow over time.

Active Section 232 Investigations Beyond Steel/Aluminum

The application of Section 232 authority is actively expanding beyond steel and aluminum, reflecting a potentially broader interpretation of “national security” threats related to import dependence and supply chain vulnerabilities. As of May 2, 2025, BIS has initiated several new Section 232 investigations 4:

Table 3: Active Section 232 Investigations (as of May 2, 2025)

Investigation Subject Initiation Date Stated National Security Rationale (Summary/Keywords) Snippet Reference
Copper Imports Mar 10, 2025 Defense applications, infrastructure, emerging tech, supply chain vulnerabilities, import dependence/concentration 4
Timber and Lumber Imports Mar 10, 2025 Construction/infrastructure resilience, supply chain (details limited in snippets) 4
Semiconductors & Semiconductor Equipment Imports Apr 1, 2025 Critical infrastructure, technological advancement, supply chain security 4
Pharmaceuticals & Pharmaceutical Ingredients (APIs) Apr 1, 2025 Reliance on foreign supply chains for essential medicines, domestic production capacity, public health security, access to critical medicines 4
Trucks Apr 22, 2025 (Rationale not detailed in snippets, likely related to transport infrastructure, defense mobility, domestic industrial base) 10
Processed Critical Minerals & Derivative Products Apr 22, 2025 (Rationale not detailed in snippets, likely related to dependence on foreign sources for minerals essential for defense, energy, technology) 10

These active investigations follow previous Section 232 probes into sectors like automobiles and parts, uranium, titanium sponge, and neodymium magnets 10, indicating a sustained interest in using this authority to address perceived economic and supply chain security risks. (Note: The Section 232 investigation into automobiles and parts culminated in tariffs implemented in April 2025, discussed in Section V.C).

Implications of the Section 232 Overhaul

The comprehensive changes to the Section 232 regime effective March 2025 represent a significant pivot in U.S. trade policy for steel and aluminum. By eliminating all country-specific accommodations (exemptions, quotas) 3 and shutting down the product exclusion safety valve 5, the U.S. government transformed Section 232 from a measure with built-in flexibility and avenues for relief into a rigid, broadly applied tariff barrier. This shift reflects a clear prioritization of protecting the domestic steel and aluminum industries, aiming to close loopholes allegedly exploited by third countries 17, even at the cost of removing previously negotiated arrangements with key allies.5 The simultaneous increase in the aluminum tariff to 25% further reinforces this hardened stance.5

The decision to vastly expand the scope to include potentially hundreds of billions of dollars worth of downstream derivative products 3 fundamentally alters the economic impact of the Section 232 tariffs. While the initial tariffs primarily affected direct users of steel and aluminum, the inclusion of derivatives shifts the burden onto a much wider array of manufacturing sectors that incorporate these metals into finished or semi-finished goods – including automotive, appliances, construction, machinery, and consumer products.3 This broadening reach, combined with the added complexity of calculating duties based on metal content value for many items 3, significantly increases supply chain costs and administrative burdens across the economy.

Furthermore, the initiation of new Section 232 investigations into diverse sectors like copper, timber, semiconductors, and pharmaceuticals 4 signals a broadening interpretation of “national security” under the statute. The rationales cited increasingly encompass economic security concerns, supply chain resilience, import dependence, and critical infrastructure needs.4 This suggests Section 232 may evolve into a more frequently used tool to pursue industrial policy objectives and protect domestic industries deemed vital for economic security, creating substantial uncertainty for importers across numerous sectors beyond metals.

Finally, the abrupt termination of negotiated exemptions and quotas for close allies like Canada, Mexico, the EU, UK, Japan, and South Korea 5 is likely to cause significant diplomatic friction. These arrangements were often reached after intense negotiations and involved reciprocal concessions, including the suspension of retaliatory tariffs against U.S. exports.3 Re-imposing tariffs on these partners reverses previous de-escalation efforts and creates strong incentives for renewed retaliation. Indeed, the EU allowed its suspension of retaliatory tariffs to expire in April 2025 in direct response to the U.S. action 35, signaling a potential return to trade disputes with key trading partners.

Additional Tariff Measures Implemented in 2025

Beyond the long-standing Section 301 regime and the significantly revised Section 232 measures for metals, the first few months of 2025 saw the implementation of several other major tariff actions under different authorities, dramatically reshaping the U.S. import landscape.

Overview of 2025 Tariff Actions Beyond Section 301/232

Early 2025 witnessed a rapid succession of executive actions imposing new tariffs, primarily leveraging the International Emergency Economic Powers Act (IEEPA) and Section 232 authority for automobiles. These actions included initial IEEPA tariffs targeting specific countries, followed by broad “reciprocal tariffs” applied globally, new Section 232 tariffs on autos, and the elimination of the de minimis exemption for certain imports.

IEEPA-Based Tariffs (Pre-Reciprocal)

Invoking national emergencies related to border security and fentanyl trafficking, President Trump utilized IEEPA authority to impose tariffs in February and March 2025:

  • China: A 10% tariff on all imports from China became effective February 4, 2025. This rate was subsequently increased to 20%, effective March 4, 2025.
  • Canada and Mexico: A 25% tariff on imports from Canada and Mexico was announced effective February 4, but implementation was paused for 30 days. The tariffs took effect March 4. However, these were quickly modified on March 6 to exempt goods qualifying for preferential treatment under the United States-Mexico-Canada Agreement (USMCA), while non-qualifying goods remained subject to 25% tariffs (or 10% for certain Canadian energy/potash).

These initial IEEPA tariffs set the stage for the broader actions that followed in April and contribute to the cumulative tariff burden, particularly for China (see Section VI).

Section 232 Tariffs on Automobiles and Auto Parts

Based on a determination that imports of automobiles and certain auto parts threaten to impair national security, President Trump imposed new tariffs under Section 232 authority:

  • Rate and Scope: A 25% ad valorem tariff applies to imported automobiles (passenger vehicles, SUVs, CUVs, minivans, cargo vans, light trucks) and certain specified auto parts.
  • Effective Dates: The tariff on fully assembled automobiles took effect at 12:01 a.m. EDT on April 3, 2025. The tariff on covered auto parts is scheduled to take effect May 3, 2025.
  • USMCA Considerations: For automobiles and parts qualifying for preferential treatment under USMCA, provisions exist (or are being developed) to potentially apply the 25% tariff only to the non-U.S. content value, provided sufficient documentation is submitted and approved.
  • Exemption from Reciprocal Tariffs: Importantly, automobiles and auto parts subject to these Section 232 duties are explicitly exempt from the broader “reciprocal tariffs” discussed below.

Broad “Reciprocal Tariffs” (IEEPA)

On April 2, 2025, President Trump issued Executive Order 14257, declaring a national emergency based on large trade deficits and implementing a sweeping “Reciprocal Tariff” policy under IEEPA authority.

  • Baseline Tariff: A 10% additional ad valorem tariff was imposed on nearly all imported goods from all countries, effective 12:01 a.m. EDT on April 5, 2025. This is reported under HTSUS heading 9903.01.25.
  • Higher Country-Specific Rates: The order initially established higher reciprocal tariff rates (ranging from 11% to 50%) for 57 specific countries/territories, scheduled to replace the 10% baseline effective April 9, 2025.
  • Suspension (Except China): Following international reactions, an Executive Order issued on April 9 suspended the implementation of these higher country-specific rates for 90 days, until July 9, 2025. During this suspension period, imports from these 56 countries remain subject to the 10% baseline tariff under HTSUS 9903.01.25.
  • China’s Escalating Rate: China was the sole exception to the suspension. Its initial reciprocal rate of 34% (effective April 9) was rapidly increased in response to Chinese retaliation. An EO on April 8 raised it to 84% (effective April 9), and another EO on April 9 raised it further to 125% (effective April 10). This 125% rate, reported under HTSUS 9903.01.63, applies in addition to the 20% IEEPA tariffs imposed earlier, resulting in a total additional duty of 145% for most Chinese goods as of May 2, 2025.
  • Exemptions: Several categories of goods are exempt from these reciprocal tariffs:
  • Goods subject to Section 232 tariffs (steel, aluminum, autos, auto parts) are reported under HTSUS 9903.01.33 and are exempt.
  • Products listed in Annex II of the April 2 EO (including copper, pharmaceuticals, semiconductors, lumber, certain critical minerals, energy products) are reported under HTSUS 9903.01.32 and are exempt.
  • Goods from Canada and Mexico (covered by separate IEEPA/USMCA provisions).
  • Goods from countries subject to Column 2 duty rates (e.g., Cuba, North Korea).
  • Goods in transit before April 5, 2025 (reported under HTSUS 9903.01.28, deadline May 27).
  • U.S. Content: For goods containing at least 20% U.S. content (by value), the reciprocal tariffs apply only to the non-U.S. content value (reported under HTSUS 9903.01.34).

Understanding the Term “Reciprocal Tariffs” in the 2025 Context

The term “reciprocal tariffs” as used in the April 2025 Executive Orders represents a significant departure from its historical meaning in international trade policy.

  • Administration’s Rationale: The Trump administration framed these tariffs as a response to a perceived “lack of reciprocity” in global trade relationships, citing disparate tariff rates, non-tariff barriers, and other economic policies in foreign countries that allegedly contribute to persistent U.S. trade deficits. The stated goal was to “rebalance global trade flows” and promote “fairness” 37 by imposing tariffs intended to counteract these perceived imbalances.40 The administration invoked IEEPA, declaring the trade deficit situation a national emergency.
  • Calculation Method: Despite the “reciprocal” label, the tariff rates were not calculated by directly matching the specific tariff rates that other countries apply to U.S. exports on a product-by-product basis.43 Instead, the administration used a formula based primarily on the bilateral goods trade deficit between the U.S. and each trading partner.42 The USTR acknowledged that directly calculating the effects of all foreign tariff and non-tariff barriers was “complex, if not impossible,” and argued that the trade deficit could serve as a proxy for their combined effects.42 This method resulted in rates ranging from the 10% baseline up to 50% for certain countries.
  • Contrast with Historical Reciprocity: Traditionally, “reciprocal tariffs” or “reciprocal trade agreements” referred to negotiated, mutual reductions or adjustments of tariffs between countries.38 This principle was foundational to U.S. trade policy since the Reciprocal Trade Agreements Act of 1934 39 and underpinned multilateral negotiations within the GATT/WTO system.39 These historical agreements involved a give-and-take process aimed at achieving mutually beneficial market access.38
  • Key Differences: The 2025 “reciprocal tariffs” differ fundamentally from historical practice in several ways:
  • Unilateral vs. Negotiated: They were imposed unilaterally by the U.S. based on its own assessment and calculations, not through bilateral or multilateral negotiation and agreement.54
  • Calculation Basis: The calculation was tied to trade balance figures rather than mirroring specific foreign tariff rates.42
  • Goal: The primary stated goal was deficit reduction and addressing broadly defined “unfairness,” rather than negotiated, balanced trade liberalization.
  • Legal Framework: They were implemented under emergency powers (IEEPA), bypassing traditional trade agreement negotiation frameworks and drawing criticism for operating outside established international trade rules.

Therefore, while termed “reciprocal,” these 2025 tariffs represent a distinct policy approach based on unilateral action and trade balance calculations, differing significantly from the negotiated, mutually agreed-upon tariff adjustments historically associated with the term “reciprocity” in trade policy.57

Elimination of De Minimis Exemption for China/Hong Kong

Leveraging IEEPA authority via Executive Orders (including EO 14256, 14259, 14266), the administration effectively eliminated the Section 321 “de minimis” provision for low-value shipments (under $800) originating from mainland China and Hong Kong:

  • Action: Instead of entering duty-free, these shipments became subject to substantial duties.
  • Duty Rates: The applicable duty is the higher of a 120% ad valorem rate or a specific duty per postal item.
  • Specific Duty Schedule: The specific duty per item was set at $100 effective May 2, 2025, scheduled to increase to $200 effective June 1, 2025.
  • Rationale: This action was explicitly linked to preventing circumvention of the broader tariffs imposed on China.

Navigating Tariff Determination and Interactions

The Critical Role of HTS Classification and Country of Origin

Successfully navigating the U.S. tariff system hinges on two fundamental determinations: the correct Harmonized Tariff Schedule (HTS) classification and the accurate Country of Origin of the imported goods. As established, the HTS classification, derived by applying the General Rules of Interpretation (GRIs) and relevant Section/Chapter notes, determines the baseline duty rate (Column 1 or Column 2).11

Equally critical is establishing the correct Country of Origin, as this determines the applicability of geographically targeted tariffs like Section 301 (primarily China) 21, the specific IEEPA tariffs on China, Canada, and Mexico, the country-specific reciprocal tariff rates (even if suspended), and eligibility for preferential rates under FTAs or trade programs. It is essential to note that tariffs are based on the country where the goods underwent substantial transformation, not merely the country from which they were shipped or exported.21 Incorrect classification or origin determination can lead to incorrect duty payments and significant compliance issues.

Additive Nature of Tariffs and Stacking Rules

A key principle in the current U.S. tariff environment is that additional duties imposed under Section 301, Section 232, and IEEPA are generally cumulative, or “stack”. They are applied in addition to the baseline HTSUS duty rate found in Column 1 (General or Special) or Column 2.5

Therefore, calculating the total potential duty liability for a given import requires a sequential assessment:

  1. Determine the correct 10-digit HTSUS code.
  2. Identify the applicable baseline duty rate (Column 1 General, Column 1 Special, or Column 2).
  3. Determine the correct Country of Origin.
  4. Check if the HTS code and Country of Origin (China) fall under any active Section 301 list and identify the applicable additional tariff rate.
  5. Check if the product meets the definition of a covered steel or aluminum article or derivative under Section 232 and identify the applicable additional tariff rate (25%, applied to full value or metal content value as appropriate).
  6. Check if the product is an automobile or auto part subject to Section 232 tariffs (25%).
  7. Check if the product is subject to IEEPA tariffs (e.g., the 20% rate on China from Feb/Mar, or the 10% baseline reciprocal tariff, or the 125% reciprocal tariff on China).
  8. Apply the rules governing tariff interactions (see below) to determine the final cumulative rate.
  9. Calculate the total duty based on the applicable value(s).

Specific Interactions, Exemptions, and Precedence (EO 14289)

While tariffs generally stack, specific executive actions, agency guidance, and a dedicated Executive Order (EO 14289) establish important exceptions and rules of precedence:

  • Section 232 Goods Exempt from Reciprocal Tariffs: As noted, articles subject to Section 232 duties (steel, aluminum, autos, auto parts) are explicitly excluded from the reciprocal tariffs imposed under EO 14257. Importers report HTSUS 9903.01.33 for these goods in the context of reciprocal tariff reporting.
  • Annex II Goods Exempt from Reciprocal Tariffs: Products listed in Annex II of EO 14257 (copper, pharmaceuticals, semiconductors, etc.) are also exempt from reciprocal tariffs.
  • Canada/Mexico Exemptions: Goods from Canada and Mexico are subject to their own specific tariff regime (based on IEEPA/USMCA status) and are exempt from the general reciprocal tariffs.
  • EO 14289 – Addressing Tariff Stacking (April 29, 2025): Recognizing the potential for excessive cumulative rates, President Trump issued EO 14289 to establish rules for how tariffs imposed under different authorities (specifically, Section 232 Autos, IEEPA Border/Fentanyl, Section 301, and IEEPA Reciprocal Tariffs) should interact when applied to the same article. This order, effective retroactively to March 4, 2025, aims to prevent full “stacking” in certain scenarios by setting precedence rules. While the full details require careful review of the EO and implementing HTSUS notes, the general intent is to apply the highest applicable rate among certain conflicting tariff regimes, rather than summing all of them, though some combinations may still be additive. For example, the order clarifies that articles subject to the IEEPA Border/Fentanyl tariffs (like the 20% on China) are also subject to the additional IEEPA Reciprocal Tariffs (like the 125% on China), confirming the 145% cumulative rate. However, interactions involving Section 232 or Section 301 might follow different precedence rules outlined in the order. Importers must consult the specific provisions of EO 14289 and related HTSUS Chapter 99 notes to determine the correct final duty rate when multiple tariff regimes potentially apply.
  • De Minimis: The elimination of the de minimis exemption applies specifically to low-value shipments from China and Hong Kong, subjecting them to unique high duty rates instead of other applicable tariffs.

Role of Customs and Border Protection (CBP)

U.S. Customs and Border Protection (CBP) plays the central role in the practical application and enforcement of all U.S. tariff laws at the border.11 CBP officers make the final determinations regarding HTS classification, country of origin, valuation, and the applicability and calculation of all duties, including baseline HTS rates and additional tariffs under Section 301, Section 232, and IEEPA.

Importers seeking certainty on complex classification or origin issues can utilize CBP’s binding ruling program. CBP also disseminates important operational guidance and updates through channels like the Cargo Systems Messaging Service (CSMS), which has been crucial for implementing the rapid tariff changes in 2025. Staying informed about CBP notices and rulings is critical for maintaining compliance.

Implications of Layered Tariffs and Multiple Authorities

The current U.S. tariff system, characterized by multiple layers of duties (HTS, Section 301, Section 232, IEEPA Reciprocal, IEEPA Border/Fentanyl, etc.) requires a rigorous, multi-step analysis to determine the final landed cost of imported goods. Compliance demands more than simply looking up an HTS rate; it necessitates understanding the specific applicability criteria (HTS code, origin, product definition) for each potential tariff regime and how they interact according to exemptions and precedence rules like those in EO 14289. This complexity significantly increases the compliance burden and risk for importers, potentially leading to substantial financial impacts, with average tariff rates reaching historically high levels.

Furthermore, the increasing reliance on various statutory authorities – Section 301 of the Trade Act of 1974, Section 232 of the Trade Expansion Act of 1962, and the International Emergency Economic Powers Act (IEEPA) – to implement tariffs via executive action creates a complex web of trade measures. Each action may come with its own specific rules regarding scope, application, and interaction with other measures. Navigating this intricate legal and regulatory landscape often requires specialized expertise in customs law and trade compliance to avoid costly errors.

Conclusion and Key Considerations for Importers

Summary of the U.S. Tariff Environment (May 2, 2025)

As of May 2, 2025, the U.S. tariff environment is marked by unprecedented complexity and significantly heightened protectionist measures across numerous sectors.54 The Harmonized Tariff Schedule (HTS) remains the foundation, but importers must navigate a dense overlay of additional duties:

  • Section 301: Primarily targeting China with rates up to 100% on strategic goods.1
  • Section 232 (Metals): A rigid 25% global tariff on steel, aluminum, and a vast list of derivatives, with no country exemptions or product exclusions.3
  • Section 232 (Autos): A 25% global tariff on imported automobiles and soon, auto parts.
  • IEEPA (Reciprocal): A 10% baseline tariff on most global imports, escalating to 125% for China (plus earlier IEEPA duties), with specific exemptions.
  • IEEPA (De Minimis): Elimination of the $800 duty-free threshold for shipments from China/Hong Kong, replaced by very high duties.

The radical overhaul of Section 232 metals tariffs, the introduction of broad reciprocal and auto tariffs, and the specific targeting of low-value Chinese shipments represent major shifts in U.S. trade policy.54 The dynamism is further highlighted by ongoing Section 301 reviews, active Section 232 investigations into new sectors 4, and complex rules governing tariff interactions.

Emphasis on Continuous Monitoring and Due Diligence

The highly fluid and complex nature of U.S. trade policy necessitates constant vigilance. Tariff rates, product coverage under various regimes, exemption criteria, interaction rules, and administrative guidance can change rapidly through actions by USTR, Commerce, CBP, or the White House.55 Importers must establish robust internal processes or leverage external expertise to continuously monitor official announcements and regulatory updates to ensure ongoing compliance and accurate cost forecasting in this high-stakes environment.

Recommendations for Importers

Navigating the current U.S. tariff landscape requires a proactive and meticulous approach. Key considerations include:

  1. Prioritize Accurate HTS Classification: Invest the necessary resources to ensure correct HTS classification for all imported goods. Utilize the GRIs, Section/Chapter Notes, and official HTS publications. For complex items, consider seeking legally binding rulings from CBP.
  2. Rigorously Verify Country of Origin: Implement strong procedures to determine and document the correct country of origin based on substantial transformation rules, as this is critical for Section 301, IEEPA, and reciprocal tariff applicability, as well as FTA eligibility.47
  3. Systematically Assess All Applicable Tariffs: Develop comprehensive checklists or automated systems to determine if imported goods are subject to Section 301 (if from China), Section 232 (metals or autos/parts), IEEPA (border/fentanyl or reciprocal), or de minimis rules (if low-value from China/HK). Pay close attention to specific product definitions and criteria (e.g., steel/aluminum derivatives, auto parts scope).
  4. Apply Interaction Rules Correctly: Carefully analyze the applicability of exemptions (e.g., Sec 232 goods from reciprocal tariffs) and the precedence rules established by EO 14289 when multiple tariff regimes seem to apply, to avoid over- or under-payment of duties.
  5. Incorporate Tariffs into Landed Cost: Ensure that all applicable duties – baseline HTS and all additional tariffs determined after applying interaction rules – are accurately factored into landed cost calculations, pricing strategies, and budgeting. The potential for cumulative rates exceeding 100% (especially for China) necessitates careful financial planning.
  6. Conduct Strategic Supply Chain Reviews: The high cost and lack of relief mechanisms associated with Section 232 metals tariffs, the broad impact of reciprocal tariffs, the targeted Section 301 pressure, and the new auto tariffs warrant a thorough review of supply chain vulnerabilities. Evaluate the feasibility and benefits of diversifying sourcing locations 9, increasing U.S./North American content, or restructuring logistics.
  7. Engage Trade Expertise: Given the extreme complexity of classification, origin rules, multiple overlapping tariff regimes, interaction rules, and the potential for rapid changes, consulting with experienced customs brokers, trade attorneys, or international trade consultants is highly advisable.46
  8. Monitor Official Government Sources: Regularly check the primary source websites for updates: USITC (hts.usitc.gov) for HTS revisions, USTR (ustr.gov) for Section 301 actions, BIS/Commerce (bis.doc.gov, commerce.gov) for Section 232 developments, White House (whitehouse.gov) and Federal Register (federalregister.gov) for Executive Orders/Proclamations, and CBP (cbp.gov) for enforcement guidance (especially CSMS messages) and rulings.

Final Thought

The U.S. tariff landscape in May 2025 presents unprecedented challenges for businesses engaged in international trade.46 Multiple layers of high tariffs, complex application and interaction rules, the elimination of previous relief mechanisms for steel and aluminum, and ongoing policy uncertainty demand exceptional levels of due diligence, rigorous compliance management, and strategic adaptation from importers seeking to manage costs and mitigate risks in this dramatically altered environment.

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