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In response to the Supreme Court invalidating the use of IEEPA to impose tariffs, President Trump issued an Executive Order on February 20, ending the IEEPA based tariffs imposed by Executive Orders.This included the reciprocal tariffs; fentanyl-related tariffs on China, Canada and Mexico; and the tariffs directed against dealings with Brazil, Cuba, Iran, Russia and Venezuela.
At the same time, President Trump issued a proclamation invoking his authority under section 122 of the Trade Act of 1974 to impose tariffs to correct the U.S.'s balance-of-payments deficit.The new tariffs were originally set at 10 percent, but are being increased to 15 percent according to President Trump.These tariffs will apply broadly to imports to the U.S., with some notable exceptions, including:
- all goods and parts of goods that currently are or later become subject to Section 232 tariffs;
- USMCA compliant goods of Canada and Mexico;
- textiles and apparel goods that enter duty-free under the Dominican Republic-Central America Free Trade Agreement; and
- specified goods needed for the U.S. economy, including certain critical minerals, fertilizers, agricultural products, electronics, passenger vehicles, pharmaceuticals,aerospace products and informational materials and accompanied baggage.
These Section 122 tariffs are scheduled to take effect on February 24, and will last for a period of 150 days.
Also in response to the Supreme Court striking down the IEEPA-based tariffs, U.S. Trade Representative Greer announced Friday that the USTR will begin several new investigations under Section 301 of the Trade Act of 1974.He noted that these new Section 301 investigations will target most major U.S. trading partners and address key trade concerns, including pharmaceutical product pricing, industrial overcapacity, forced labor practices, and alleged discrimination against American technology companies and digital goods.The Trump Administration has already used Section 301 investigations to target Chinese electronics and shipping interests, and Nicaragua.
Customs and Border Protection ("CBP") has issued a notice to importers in the Cargo Systems Messaging Service that as a result of the Supreme Court Rulingit is reviewing the collection of the IEEPA tariffs and will provide additional information and technical guidance for import filers as soon as it becomes available.CBP has made no reference to a process for refunds of collected IEEPA tariffs.
Keeping track of all the tariffs that have been promulgated or proposed during the Trump Administration continues to be a head-spinning task.To help follow the proliferation of tariffs in the Trump Administration, I have put together the following list of each of the tariff measures that have been implemented, pending, or proposed since January 20,2025.
Here is the developing landscape of U.S. tariffs as of February 23, 2026:
| U.S. Tariff Measure | Status | |
| Global |
15% ad valorem duty on imports into the U.S. pursuant to Sec. 122 of the Trade Act of 1974. Imports of certain specified items excluded Imports of USMCA-qualifying products of Canada and Mexico excluded |
Implemented:2/20/2026 |
| Global | Semiconductors –25% ad valorem duty on imports of specified semiconductors and derivative products |
Implemented: 1/14/2026 |
| Global | Critical Minerals – trade negotiations directed regardingimports of processed critical minerals and derivative products |
Implemented: 1/14/2026 |
| Nicaragua |
Section 301: Acts, Policies, and Practices Related to Labor Rights, Human Rights and Fundamental Freedoms, and the Rule of Law January 1, 2026 -0% ad valorem duty on all products of Nicaragua not under CAFTA-DR January 1, 2027 –10% ad valorem duty on all products of Nicaragua not under CAFTA-DR January 1, 2028 –15% ad valorem duty on all products of Nicaragua not under CAFTA-DR |
Implemented: 12/12/2025 (effective 1/1/2026) |
| Global |
Medium & Heavy Duty Trucks –25% ad valorem duty on imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts 10% ad valorem duty on imports of buses and motor coaches |
Implemented 10/17/2025 |
| China |
Section 301: Cranes/Cargo Handling Equipment –100% ad valorem duty on imports of STS cranes and other cargo handling equipment |
Implemented 10/16/2025 (effective 11/9/2025) Suspended 11/10/2025 |
| Global |
Lumber –10% ad valorem duty on imports of softwood timber and lumber 25% ad valorem duty on imports of certain upholstered wooden products 25% ad valorem duty on imports of kitchen cabinets and vanities Reduced tariffs on subject imports from U.K., the E.U., and Japan |
Implemented 9/29/2025 Executive Order Initiating Sec. 232 Investigation DOC Request for Public Comments |
| Global | Copper –50% ad valorem duty on imports of semi-finished copper products and intensive copper derivative products |
Implemented: 7/30/2025 Executive Order Initiating Investigation |
| Global |
Steel –50% ad valorem duty on imports of steel articles and derivative products with no exemptions or exclusions 25% ad valorem duty on imports of steel articles and derivative products from the United Kingdom. Certain aerospace products from the United Kingdom exempt. |
Revised6/4/2025 Implemented: 3/12/2025 Proclamation on Sec. 232 Duties Executive Order Removing "Stacking" of Tariff Programs Proclamation Increasing Tariff Rate Executive Order Implementing US-UK Trade Deal Commerce Fed Reg Notice Adding Derivative Products |
| Global |
Aluminum –50% ad valorem duty on imports of aluminum articles and derivative products with no exemptions or exclusions 25% ad valorem duty on imports of aluminum articles and derivative products from the United Kingdom. Certain aerospace products from the United Kingdom exempt. |
Revised 6/4/2025 Implemented: 3/12/2025 Proclamation on Sec. 232 Duties Executive Order Removing "Stacking" of Tariff Programs Proclamation Increasing Tariff Rate |
| China | Section 301: Chinese Vessels – Port Entry Fees on Chinese owned or built vessels, and foreign-built car carriers. |
Implemented: 4/17/2025Suspended 11/10/2025 USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing |
| Global |
Automobiles –25% ad valorem duty on imports of automobiles (with certain allowances for USMCA-qualifying autos) and certain automobile parts (with limited tariff offsets). Import quota and reduced tariffs for automobiles and automobile parts from the United Kingdom. |
Implemented 4/3/2025 (effective 5/3/2025 for automobile parts) Proclamation on Sec. 232 Duties Proclamation with HTS Amendments Proclamation Establishing Tariff Offsets on Parts |
| Global | Personal Protective and Medical Equipment – potential tariffs on imports of personal protective equipment, medical consumables, and medical equipment, including devices |
Pending: Section 232 Investigation |
| Global | Robotics and Industrial Machinery – potential tariffs on imports of robotics and industrial machinery |
Pending: Section 232 Investigation |
| Global |
Wind Turbines – potential tariffs on imports of wind turbines and their parts and components |
Pending:Section 232 Investigation |
| Brazil |
Section 301: Brazil's Acts, Policies, and Practices Related to Digital Trade and Electronic Payment Services; Unfair, Preferential Tariffs; Anti-Corruption Enforcement; Intellectual Property Protection; Ethanol Market Access; and Illegal Deforestation |
Pending: Section 301 Investigation |
| Global | Unmanned Aircraft Systems – potential tariffs on imports of unmanned aircraft systems (UAS) and their parts and components |
Pending:Section 232 Investigation |
| Global | Polysilicon – potential tariffs on imports of polysilicon and its derivatives |
Pending: Section 232 Investigation |
| Global | Aircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts |
Pending:Section 232 Investigation |
| Global | Pharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products |
Pending: Section 232 Investigation |
|
Global [Canada & Mexico Exempt] |
Reciprocal tariffs –10% ad valorem duty Country specific duty rates of 15% to 50% ad valorem Certain goods excluded |
STRUCK DOWN: 2/20/2026 Revised 11/20/2025 Implemented 4/2/2025 Executive Order Establishing Tariffs Executive Order Revising Tariffs CBP Bulletin on Excluded Electronics Executive Order Reducing China Tariff Rates Fed. Circuit Administrative Stay Fed. Circuit Order Granting Motion to Stay Executive Order Implementing US-UK Trade Deal Executive Order Extending Effective Date of Country-Specific Tariffs Executive Order Suspending Duty-Free de minimis Treatment Executive Order on Brazil Tariffs Executive Order Modifying Reciprocal Tariffs Executive Order on India Tariffs Executive Order Extending China Tariff Rates Executive Order Implementing US-Japan Trade Deal Executive Order Modifying Reciprocal Tariff Coverage Implementing Elements of EU Framework Agreement Executive Order Modifying Reciprocal Tariff Rates for China Executive Order Modifying Reciprocal Tariff Rates on Certain Agriculture Executive Order Modifying the Scope of Tariffs on Brazil Executive Order Modifying Tariffs on India Executive OrderEnding Tariffs |
| Canada |
10% ad valorem duty on non-USMCA-qualifying energy and potash 25% ad valorem duty on all other non-USMCA-qualifying products of Canada |
STRUCK DOWN: 2/20/2026 Implemented: 3/4/2025; 4/2/2025 (updated) Fed. Circuit Administrative Stay Fed. Circuit Order Granting Motion to Stay Executive OrderEndingTariffs |
| Mexico | 25% ad valorem duty on all non-USMCA-qualifying products of Mexico |
>STRUCK DOWN: 2/20/2026 Implemented: 3/4/2025; 4/2/2025 (updated) Fed. Circuit Administrative Stay Fed. Circuit Order Granting Motion to Stay Executive OrderEndingTariffs |
| China | 10% ad valorem duty on all products of China (reduced from original rate of 20%) |
STRUCK DOWN: 2/20/2026 Implemented: 3/4/2025 Fed. Circuit Administrative Stay Fed. Circuit Order Granting Motion to Stay Executive Order Reducing Tariff Rate Executive OrderEnding Tariffs |
| Global | All goods imported from a country determined to be directly or indirectly purchasing, importing, or otherwise acquiring any goods or services from Iran, since February 7, 2026 – discretionary variable rate ad valorem duty may be imposed |
STRUCK DOWN: 2/20/2026 Implemented:2/6/2026 Executive Order Ending Tariffs |
| Global | All goods imported from a country determined to have sold/provided oil to Cuba since January 30, 2026 – discretionary variable rate ad valorem duty may be imposed |
STRUCK DOWN: 2/20/2026 Implemented: 1/29/2026 Executive Order Ending Tariffs |
| Global | All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed |
STRUCK DOWN: 2/20/2026 Implemented 4/2/2025 Executive OrderEnding Tariffs |
| Canada | Aircraft – potential 50% ad valorem duty on imports from Canada | Proposed: 1/29/2026, announced by President Trump on Truth Social |
|
Denmark Finland France Germany Netherlands Norway, Sweden U.K. |
10% ad valorem duty on imports from designated countries relating to Greenland, to be effective Feb. 1, 2026 with increase to 25% on June 1, 2026 | Proposed: 1/17/2026, announced by President Trump on Truth Social, walked back on 1/21/2026 |
| Global | 100% tariff on movies produced outside of the United States | Proposed: 5/4/2025 and 9/29/2025, announced by President Trump on Truth Social |
| Global | 100% ad valorem duty as "secondary tariffs" on countries that do business with Russia. | Proposed: 7/14/2025, announced by President Trump |
| Global | 200% ad valorem duty on imports of pharmaceuticals (currently subject to Sec. 232 investigation) | Proposed: 7/8/2025, announced by President Trump at cabinet meeting |
| E.U. | 25% ad valorem duty on all products of the E.U. | Proposed: 2/26/2025, superseded by Reciprocal Tariffs |
This list will be updated weekly as new tariffs are implemented and new targets for tariffs are identified by President Trump and the administration.
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.
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