Update (14^th April 2025):

This Trade Alert summarizes several updates on the U.S. and China retaliation tariffs and associated actions.

Current Status on U.S. Tariffs on Chinese-Origin Products

• Over the last few weeks, the U.S. has imposed significant tariffs that are subject to numerous exclusions. Some of these tariffs are stacking, while others are not. The below summarizes the various U.S. Tariffs placed on Chinese-origin goods imported into the U.S.
• All Chinese-origin products are subject to a 20% tariff levied by the U.S. in March 2025. Further, certain commodities are subject to Section 301 Tariffs at varying rates.
• Steel or Aluminum products, Automotive and Automotive Parts will be subject to at least a 25% tariff, plus the 20% tariff from March, and plus any applicable Section 301 tariff.
• Other than semiconductors, copper, pharmaceuticals, energy/energy products, and lumber articles, and newly announced exclusions (more details below), all other Chinese-origin products will be subject to a 125% tariff, plus a 20% tariff from March, plus any applicable Section 301 tariff.
• Below are two tables that summarize the U.S. tariffs on Chinese-origin goods:

*Exclusions that apply to only the reciprocal tariffs include copper, pharmaceuticals, semiconductors (see below for details), and lumber articles covered in Annex II to the Reciprocal Tariff EO. Other exclusions include bullion; energy/energy products and minerals that are not available in the U.S.; all other articles that may become subject to future Section 232 tariffs in the future; and the value of US-origin content if the imported article is composed of at least 20% US content by value.

U.S. Issues Clarifications on Excluded Products

In addition to the excluded products listed in Annex II to the Reciprocal Tariff Executive Order, on April 11, President Trump issued an Executive Order adding additional products that will be excluded from all reciprocal tariffs, including the 10% baseline tariffs now in effect. U.S. Customs and Border Protection also provided additional guidance related to these exclusions, including how to claim these exclusions on imports. Any duties paid according to the reciprocal tariffs after April 5th, 2025 are eligible for a refund. Below is a list of additional excluded semiconductor products:

Chinese Retaliatory Tariffs on U.S. Origin Products and Chinese Guidance on Country of Origin Regarding Semiconductors

• Reciprocal Tariff Retaliation: On April 10, China imposed a 125% on all U.S.-origin products imported into China, Hong Kong, and Macau.
• IC Origin: On April 10, China issued statements on how to determine the country of origin (COO) for semiconductor products. These statements seemingly allude to using “tape out” at COO for integrated circuits. This could have significant impacts as it relates to China’s tariffs on U.S.-origin products. However, these statements have yet to be formalized.  

We will share additional communications and issue Trade Alerts as we receive official actions (such as Executive Orders or Federal Register notices) or actionable information.

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Update (9^th April 2025):

This Trade update summarizes the pause on U.S. reciprocal tariffs as well as U.S. and China retaliation responses.

Pause on U.S. Reciprocal Tariffs

• On April 9, President Trump announced that the U.S. would pause the implementation of the reciprocal tariffs on all countries for ninety (90) days, excluding China. However, in this same announcement, President Trump indicated that the universal baseline tariff of 10% will remain in effect. President Trump also raised the reciprocal duty on Chinese-origin goods to 125%, effective immediately. Canadian- and Mexican-origin goods that qualify for the USMCA remain unaffected. As more information becomes available, we will issue additional trade alerts.

 China Retaliation

• Initial Retaliation: In response to the U.S. 20% tariff on all Chinese-origin goods imposed on March 4, China imposed a 15% tariff on coal and LNG products, as well as a 10% tariff on crude oil, agricultural machinery, and large engine cars. China also retaliated by imposing export controls on various raw earth minerals, initiated investigative actions against U.S. companies, and added companies to its Unreliable Entities List.
• Reciprocal Tariff Retaliation. On April 4, China added 16 U.S. entities to its export control list and an additional 11 entities to its unreliable entities list. On April 7, China imposed a 34% tariff on all U.S.-origin products imported into China, Hong Kong, and Macau. On April 9, China increased its proposed 34% tariff to 84%.

We anticipate continuing escalation in the coming days and weeks. We will share additional communications and issue Trade Alerts as we receive official actions (such as Executive Orders or Federal Register notices) or actionable information.

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Original Alert (2nd April 2025)

On April 2, 2025, President Trump signed the Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits Executive Order (“Reciprocal Tariff EO”) and the Further Amendment to Duties Addressing the Synthetic Opioid Supply Chain in the People’s Republic of China as Applied to Low-Value Imports Executive Order (“China De Minimis EO”). This Trade Alert summarizes the Reciprocal Tariff EO and the China De Minimis EO.

Reciprocal Tariff EO

• Scope: The EO declares a US national emergency arising from economic conditions due to U.S. goods trade deficits with trading partners and subsequently imposes tariffs on all U.S. trading partners.
• Tariff Rates and Implementation Dates: A 10% “baseline” tariff will apply to all imports from all countries, which will enter effect on April 5, 2025. “Reciprocal” tariffs, an increase to the baseline tariffs for countries with which the U.S. has large trade deficits (see below list), will enter effect on April 9, 2025. These tariffs are additive to other tariffs already in place against specific countries. For example, a semiconductor product of China is now subject to a minimum 79% tariff, plus any additional anti-dumping or countervailing duties (34% reciprocal tariff + 20% IEEPA tariffs + a Section 301 tariff of 50%). The tariff rates in the below list include the 10% “baseline” tariff rate and the country-specific “reciprocal” tariff rate.
• Additional Provisions: The Reciprocal Tariff EO also states that the U.S. may “increase the tariff if trading partners retaliate or decrease the tariffs if trading partners take significant steps to remedy non-reciprocal trade arrangements and align with the [U.S.] on economic and national security matters.”
• Exemptions: The following goods are exempted from the baseline and reciprocal tariffs:
   
  • Products of Canada and Mexico that are USMCA-qualifying goods (see below for further information)
  • Steel and aluminum articles (inclusive of derivatives) already subject to Section 232 tariffs
  • Automobiles and automotive parts already subject to Section 232 tariffs
  • Copper, pharmaceuticals, semiconductors, and lumber articles covered in Annex II to the Reciprocal Tariff EO (to which Section 232 tariffs will likely be applied shortly)
  • bullion
  • energy/energy products and minerals that are not available in the U.S.
  • all articles from trading partners that the U.S. does not have normal trade relations, including Cuba, North Korea, Russia, and Belarus
  • all other articles that may become subject to future Section 232 tariffs in the future
  • The value of US-origin content if the imported article is composed of at least 20% US content by value
• Canada and Mexico: Canada and Mexico are excluded from the baseline tariff and the reciprocal tariffs, as they are already covered by the separate 25% IEEPA tariff. However, if the current IEEPA tariffs on Canada and Mexico are terminated, a new tariff of 12% on goods that do not enter under USMCA preferences would enter into effect automatically (energy and energy resources and potash would also be excluded from the tariff)
• De Minimis: Customs de minimis entry for shipments valued under $800 will continue to be available, “until notification by the Secretary of Commerce to the President that adequate systems are in place to fully and expeditiously process and collect duty revenue applicable pursuant to this subsection for articles otherwise eligible for de minimis treatment.” After Commerce provides such notification, de minimis entry will be prohibited.

Country-Specific Reciprocal Tariffs

• Below is a list of the countries that have additional U.S. duty rates levied with those associated duty rates (inclusive of the 10% “baseline” tariff rate and the country-specific “reciprocal” tariff rate).

China De Minimis EO

• Scope: The China De Minimis EO removes the duty-free treatment of shipments valued less than $800 originating from China/Hong Kong/Macau.
• Implementation Date: The removal of the de minimis exemption will apply to relevant imports on or after May 2, 2025.

We anticipate continuing escalation in the coming days and weeks. We will share additional communications and issue Trade Alerts as we receive official actions (such as Executive Orders or Federal Register notices) or actionable information.