First 100 Days of Trade

On April 2, 2025 we reported that imports from China valued at $800 or less would no longer qualify for de minimis treatment starting May 2, 2025. On April 9, 2025 we reported the increase in tariffs and fees for imports of small value packages from China following issuance of Executive Order Amendment to Reciprocal

On April 9, 2025, President Trump issued an Executive Order titled “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment”, increasing the reciprocal tariff rates for China to 125%. Importantly, country-specific reciprocal rates for 83 countries that took effect on April 9, 2025, have been paused for a period of 90

On April 8, 2025, President Trump, acting under the authority of the International Emergency Economic Powers Act of 1977 (“IEEPA”), issued an Executive Order (“EO”) titled “Amendment to Reciprocal Tariffs and Updated Duties as Applied to Low-Value Imports from the People’s Republic of China.” The EO modifies the previous April 2, 2025 Executive Order by

On April 8, 2025 U.S. Customs and Border Protection (“CBP”) issued a Cargo Systems Messaging Service (“CSMS”) Message # 64680374which sets forthadditional guidance on the reporting of reciprocal tariffs set to take effect on April 9, 2025. This guidance is an update to CSMS # 64649265 previously issued on April 4, 2025.

The President 

On April 5, 2025, U.S. Customs and Border Protection (“CBP”) issued guidance through the Cargo Systems Messaging Service (“CSMS”) that duty drawback is available for the 10% universal baseline tariffs that take effect on April 5, 2025.

The CSMS stated CBP will issue separate guidance for the country-specific tariffs that take effect April 9, 2025.

President Trump Issues Universal Reciprocal Tariff and Higher Individualized Rates for Certain Countries

On April 2, 2025, President Trump issued an Executive Order (“EO”) imposing a 10% universal tariff on imports from all countries (with certain exceptions) pursuant to the International Emergency Economic Powers Act of 1977 (“IEEPA”).  These tariffs will take effect at 12:01

As reported in our prior update on April 2, President Trump issued an Executive Order (“EO”) imposing sweeping tariffs on a broad range of imports from virtually all trading partners. 

The text of the EO references two annexes.  According to Sections 2 and 3(a) of the EO, Annex I sets forth the country-specific reciprocal tariff

On April 2, 2025, President Trump issued an Executive Order (“EO”) imposing a 10% universal tariff on imports from all countries (with certain exceptions described below) pursuant to the International Emergency Economic Powers Act of 1977 (“IEEPA”).  These tariffs will take effect at 12:01 a.m. eastern standard time on April 5, 2025.

The tariff rates

On April 2, 2025, President Trump published the Annex of automobiles and automobile parts subject to tariffs pursuant to Section 232 of the Trade Expansion Act of 1962.  This follows the President’s March 26, 2025 Proclamation announcing the forthcoming 25% tariffs on certain vehicles and related parts, which we previously reviewed here.  This Annex

On April 2, 2025, the Department of Commerce’s Bureau of Industry and Security issued a draft Federal Register notice adding cans of beer and empty aluminum cans to the list of aluminum “derivative” products subject to tariffs pursuant to Section 232 of the Trade Expansion Act of 1962.  Today’s announcement is a follow-on to the