- with Senior Company Executives and HR
- in United States
- with readers working within the Oil & Gas industries
Overview
On January 12, 2026, President Trump announced via Truth Social: "[e]ffective immediately, any Country doing business with the Islamic Republic of Iran will pay a Tariff of 25% on any and all business being done with the United States of America. This Order is final and conclusive." See Truth Social Post. The proposed tariff measure imposes a 25% ad valorem duty on imports from any country that maintains trade relations with Iran. We note that no implementing order or regulatory guidance has been issued as of yet, leaving the scope and enforcement of this announcement uncertain. For a comprehensive list of tariffs imposed or revised by the Trump Administration, please refer to our Tariff Tracker.
Scope and Potential Impact
The tariff has not been formally implemented at this time. The announcement from President Trump also does not define what constitutes "doing business" with Iran. It is unclear whether minor transactions or indirect dealings would trigger the tariff. Countries potentially affected could include China, India, Turkey, the UAE, Iraq, and Russia, all of which reportedly maintain significant trade with Iran. See Trump Threatens Tariffs on Countries 'Doing Business' With Iran | TIME.
If implemented, the tariff may apply in addition to existing duties. China for example already faces combined rates approaching 47%, raising the prospect of potential further disruption to global supply chains and renewed trade tensions. See Trump shaves China tariffs in deal | Reuters.
President Trump previously relied on the International Emergency Economic Powers Act ("IEEPA") to impose tariffs now under review by the Supreme Court. Whether this new measure invokes the same authority remains unclear. Without a formal executive order or Customs guidance, enforcement mechanisms are uncertain and may be subject to legal challenge. We note numerous pending lawsuits challenge the legal basis for using IEEPA to authorize tariffs. Most notably, in V.O.S. Selections v. Trump, certain importers challenged the lawfulness of tariffs imposed by the Trump Administration under IEEPA. Both the Court of International Trade and the Federal Circuit have since held that IEEPA does not authorize the imposition of tariffs. Those rulings are now before the Supreme Court of the United States, which heard oral argument on November 5, 2025, but has not issued an opinion.
Key Takeaways
The announcement reflects a continued use of tariffs as a foreign policy tool by the current Trump Administration. Absent formal implementation, the measure currently operates more as a political signal of pending action. We are closely monitoring developments and will update this post if formal tariffs are ultimately implemented.
Importers and exporters with exposure to affected jurisdictions should closely monitor for official guidance and assess potential risk. We are available to discuss specific inquiries on the implications of this announcement.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
