On February 6, 2026, President Trump signed an executive order, Addressing Threats to the United States by the Government of Iran, which authorizes the imposition of tariffs on goods imported from any country that “directly or indirectly purchases, imports, or otherwise acquires goods or services from Iran.” The order is effective at 12:01 a.m. EST on February 7, 2026 and was issued pursuant to the International Emergency Economic Powers Act (“IEEPA”). The executive order aims to hold Iran accountable for “its pursuit of nuclear capabilities, support for terrorism, ballistic missile development, and regional destabilization that endanger American security, allies, and interests.”

While the order does not establish a fixed tariff rate, it references a 25% tariff as an example for imports from countries found to be trading with Iran. The Secretary of State is tasked with setting the specific tariff rate, while the Secretary of Commerce will determine whether foreign countries are engaging in such transactions, including through indirect trade via intermediaries or third countries.

If such activity is identified, the Secretary of State, in consultation with other senior officials, will recommend to the President whether and to what extent tariffs should be imposed. The executive order also grants flexibility to modify or suspend tariffs in response to new information, foreign retaliation, or significant policy changes by Iran or affected countries. According to an accompanying White House fact sheet if “Iran or an affected country takes significant steps to align with the United States on national security, foreign policy, and economic matters,” tariffs may be adjusted accordingly.

The Husch Blackwell International Trade Team will continue to monitor these developments and provide timely updates as new information becomes available.