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On June 3, 2025, the White House announced that President Trump had signed a proclamation raising import tariffs on steel and aluminum products to 50%. This measure, based on Section 232 of the Trade Expansion Act of 1962, went into effect on June 4, 2025.

The new tariffs apply only to the steel and aluminum portion of imported goods, while the non-steel and non-aluminum portion is subject to other tariffs. The proclamation also includes changes to the Harmonized Tariff Schedule of the United States (HTSUS) and mandates strict compliance with reporting requirements for steel and aluminum content.

For imports from the UK, tariffs will remain at 25% for the time being until possible adjustments are made under the US-UK trade agreement on July 9, 2025.

The USTR has determined that the exemptions under Section 301 - Investigation of China's Acts, Policies, and Practices Relating to Technology Transfer, Intellectual Property, and Innovation - should be extended. The exemptions were originally set to expire on 31 May 2025. Specifically, the USTR determined that a three-month extension of the 164 exemptions extended in May 2024 and the 14 exemptions granted in September 2024 is appropriate. The extensions apply to goods released for consumption or withdrawn from free circulation from 1 June 2025 to 31 August 2025.

On 29 May 2025, the US Court of Appeals for the Federal Circuit temporarily stayed an earlier decision by the US Court of International Trade (CIT). This decision had found that the tariffs imposed worldwide by the Trump administration using the International Emergency Economic Powers Act (IEEPA) did not fulfil the legal requirements of an "unusual and extraordinary threat". Moreover, the IEEPA tariffs against Canada, Mexico and China were not aimed at the underlying emergencies. The CIT had also emphasised that the primary authority to impose tariffs lies with Congress. Now that the CIT decision has been stayed by the Court of Appeals, the IEEPA duties are temporarily reinstated and will remain in place pending the outcome of the appeal.

U.S. Customs and Border Protection has published a notice of implementation of tariff changes under Executive Order 14289 to eliminate overlapping and past addition of duties on certain imported articles.

Effective 16 May 2025, the Harmonised Tariff Schedule of the United States (HTSUS) will be amended for the affected articles. The amendments provide for prioritisation of tariff measures to prevent overlap.

The notice also specifies the conditions under which goods receiving preferential treatment under the United States-Mexico-Canada Agreement (USMCA) will be exempt from certain additional duties. In addition, importers can apply for a refund of duties paid that are not required under the new regulation.

The governments of the United States and China issued a joint statement today following the negotiation of a trade agreement aimed at reducing tariffs and eliminating retaliatory measures. According to a White House fact sheet, the agreement provides that by 14 May 2025, both countries will suspend their 34% tariffs announced in April 2025 for 90 days, while maintaining a 10% tariff during that time, and remove additional tariffs and other retaliatory measures imposed later in April 2025. Following the entry into force of these changes, both countries have agreed to create a mechanism to continue important discussions on trade and economics.

The White House announced that a trade agreement has been reached between the US and the UK in which the first 100,000 vehicles imported annually from UK manufacturers will be subject to a 10% tariff, while additional vehicles will be subject to a 25% tariff, and alternative arrangements to the Section 232 tariffs on steel and aluminium will be negotiated. The Economic Prosperity Deal (EPD) aims to remove barriers to trade, strengthen economic exchange and reduce tariffs, particularly on beef and pharmaceuticals, while also focussing on digital trade, economic security and intellectual property rights. The agreement comes into force immediately, but is not legally binding and will be expanded over time.

On 29 April 2025, the White House issued a proclamation from President Trump regarding the adjustment of tariffs on imports of automotive components into the United States. According to a White House fact sheet, the proclamation offers offsets for a portion of the tariffs on vehicles assembled in the US.

Manufacturers will receive tariff offsets in the following amounts:

• From 3 April 2025 to 30 April 2026: Compensation equal to 3.75% of the manufacturer's suggested retail price (MSRP) for vehicles produced in the US. This is the total amount of duty that would be due if a 25% duty were applied to parts representing 15% of a vehicle's MSRP.
• From 1 May 2026 to 30 April 2027: A countervailing duty of 2.5% of the MSRP of U.S. production, which is the total amount of duty that would be due if a 25% duty were applied to parts representing 10% of a vehicle's MSRP.

The proclamation provides that the Secretary of Commerce will establish a process within 30 days for manufacturers to apply for an import adjustment offset.

U.S. Customs and Border Protection (CBP) has announced new tariff rules for imports from China and Hong Kong. As of 2 May 2025, the de minimis rule will be suspended for products from China with a value of up to USD 800. New duties include either a 120% ad valorem duty or a specific duty of USD 100 per mail item, which will be increased to USD 200 from 1 June 2025. All goods sent via the international postal network will be affected. These measures follow the national state of emergency declared on 20 January 2025 due to the threat of illegal drugs and immigration. The state of emergency has been extended to take into account China's failure to control suppliers of chemical precursors. Companies should prepare for increased import costs and adjust their logistics strategies accordingly.

Following the suspension of reciprocal US tariffs against the EU and the reduction of these tariffs to 10% for a period of 90 days, the European Union (EU) has also decided to suspend its countermeasures against US trade tariffs for 90 days in order to gain time for negotiations.

Suspension of additional duties for certain electronic devices originating in China

Reciprocal tariffs largely reduced to a minimum tariff of 10%

Increase in the tariff rate for trade surpluses: For countries that have a particularly high trade surplus with the United States, an individual, increased tariff rate will be introduced from 9 April. The specific list of countries affected and the corresponding tariffs are set out in of the Executive Order. The additional duty for all exports from the EU to the USA is therefore 20 per cent.

US content rule and exemptions: The new Executive Order provides for exemptions for goods shipped before 5 April 2025. In addition, a "US content rule" will be introduced, which states that duties will only be levied on the non-US portion of a product if at least 20 per cent of the value of the product originates from the USA. This rule is intended to ensure that multinational supply chains with a substantial proportion of US components receive preferential treatment.

The above measures should be seen separately from the tariffs previously imposed by the US on Canada, Mexico and China, which led to these countries announcing countermeasures.

Introduction of a minimum tariff: A new US Executive Order of 2 April 2025 significantly expands the previous measures by introducing a general minimum tariff of 10 percent on all imports, regardless of product category and country of shipment. This represents a significant tightening of the previous tariffs as a wider range of products are affected.

Publication of an executive order: On 26 March 2025, President Trump publishes a new executive order announcing a 25 percent tariff on US imports of motor vehicles and motor vehicle parts.

• From 3 April 2025, the 25 percent tariff is to apply to vehicles imported into the USA and
• is expected to be extended to vehicle components (such as engines, powertrains, electrical components) on 3 May 2025.

With respect to the previously announced tariffs of 25 percent on motor vehicles and motor vehicle parts and steel and aluminium products, the latest regulation does not make any changes to the tariffs. However, specific exemptions and adjustments are introduced that aim to mitigate the impact on certain product categories. In particular, the introduction of the "US content rule" offers companies whose products contain a significant proportion of US components the opportunity to apply the tariffs only to the non-US content of origin.

In addition to these steel and aluminium products, which are already subject to Section 232 tariffs, motor vehicles and parts, which have been subject to a 25 percent tariff since 3 April, are also exempt from the additional tariffs. Other exemptions include pharmaceuticals, semiconductors, energy products and critical minerals, as well as humanitarian relief goods. A detailed list of these exemptions can be found in of the above-mentioned Executive Order.

Imposition of tariffs: On 12 March 2025, the US will impose additional tariffs on imports of steel and aluminium from all countries into the US, including products that may contain steel or aluminium. Specifically, the measures will lead to:

• Re-impose a 25 per cent tariff on steel products and products made from them (e.g. steel pipe, wire and tin foil) and terminate all previous country agreements.
• Raising the tariff from 10 percent to 25 percent for aluminium and increasing the tariff for other steel and aluminium products.

The tariffs affect a wide range of products, including cookware, window frames, machinery, certain electrical appliances and furniture. These measures were first announced by the US on 12 February 2025 and will affect EU exports to the US worth around �26 billion (5 percent of total EU goods exports to the US).

EU response: The EU is responding by announcing that the countermeasures originally introduced against the US in 2018 and 2020, but then suspended, will be reinstated with effect from 1 April 2025. However, the EU is postponing the date of reinstatement until mid-April. These measures were taken in response to the steel and aluminium tariffs introduced during Donald Trump's first term in office, but were then suspended when the US agreed to suspend its measures against EU exporters within a certain quota.

The EU countermeasures mean that

• the EU imposing additional tariffs on a range of US imports, including Harley-Davidson motorbikes, bourbon, orange juice, jeans, steel and aluminium.
• A two-week consultation will be launched to identify additional US products to be subject to new EU tariffs. It is expected that these new tariffs will be introduced by mid-April.

The products proposed to be affected include a combination of industrial and agricultural products (steel and aluminium products, textiles, leather goods, household appliances, tools, plastics, wood products, poultry, beef, certain seafood, nuts, eggs, dairy products, sugar and vegetables).