President Trump Announces “Reciprocal” Tariffs Beginning 5 April 2025

On 2 April 2025, President Trump announced a series of “reciprocal” tariffs on US imports from all countries.  The tariffs apply at different rates by country, starting at a baseline of 10% and reaching as high as 50%.

The tariffs, which are being implemented under the authority of the International Emergency Economic Powers Act (IEEPA), will go into effect at a rate of 10% on 12:01 am ET on 5 April 2025.  For some countries (see the complete list at the end of this alert), the 10% tariff baseline will increase to a higher per-country rate effective 12:01 am ET on 9 April 2025.

The latest tariffs are intended to address the customs duties and related VAT and non-tariff barriers imposed by each covered trading partner on US exports, as summarized in the National Trade Estimate Report issued by the Office of the US Trade Representative on 31 March 2025.

The reciprocal tariffs announced on 2 April 2025 will not apply to:

• Certain news publications and other similar media;
• Goods that are already subject to c Section 232 tariffs on steel, aluminum, and autos/auto parts;
• Certain metals and minerals, pharmaceuticals, semiconductors, lumber, electronics, energy, and other products identified in Annex II to the president’s Executive Order;
• Imports from countries such as North Korea and Cuba subject to “Column 2” customs duty rates; and
• Any goods that later become subject to tariffs pursuant to future Section 232 trade actions.

Additionally, for goods that incorporate US content, the reciprocal tariffs will apply only to the non-US content – provided at least 20% of the value of the good is US content (defined as produced or substantially transformed in the United States).  Thus, for example, a good that incorporates 15% US content will be dutiable at its entire value, whereas a good incorporating 25% US content will be dutiable at 75% of its value.

Goods from Canada and Mexico that qualify for tariff-free treatment under USMCA will not face additional tariffs.  Any goods from Canada or Mexico that do not qualify for USMCA will continue to be subject to the tariffs of 10% (for certain energy and mineral products) or 25% (all other products) that were announced in February 2025.  In the event the President decides to terminate these 10-25% tariffs, goods from Canada or Mexico that do not qualify for USMCA treatment will be subject to a 12% reciprocal tariff.

In addition to the latest reciprocal tariffs, goods from China and Hong Kong will continue to be subject to the 20% tariffs implemented in February and March pursuant to the President’s IEEPA authority as well as (for most products from China) existing Section 301 tariffs of 25%.  Further, starting 2 May 2025 at 12:01 a.m. ET, US tariffs will apply to products from China and Hong Kong that are imported through the Section 321 “de minimis” exception for low value shipments to a single US recipient on a single day. 

According to President Trump, the United States will consider removing the latest reciprocal tariffs if US trading partners lower their tariff rates on US exports and take other steps to open their markets to US products.  Countries that retaliate against the latest US tariffs may face even higher tariff rates.

Companies importing goods from the covered countries should carefully evaluate the list of covered imports and consider appropriate measures to determine their tariff exposure and potentially mitigate risks arising from the tariffs. 

Countries Subject to “Reciprocal” Tariffs Higher than 10% (Effective 9 April 2025)