- with Senior Company Executives, HR and Finance and Tax Executives
- in United States
President Trump’s use of Section 122 of the Trade Act of 1974 to impose global tariffs continues to be challenged. Senators Kaine and Warnock have introduced The Reclaim Trade Powers Act, which would repeal Section 122, the legal basis President Trump used to justify the global 10% tariff. This section was originally designed to address balance-of-payments deficits or significant currency depreciation at a time the U.S. dollar was tied to gold and subject to rapid depletion through foreign central bank actions. Proponents of the legislation believe that with the shift to a floating exchange‑rate system more than 50 years ago, Section 122 has become functionally obsolete and is being applied incorrectly by President Trump.
In a follow-up action in the Court of International Trade case brought by 24 states against the Section 122 tariffs, the plaintiff states in that case will be requesting the CIT issue an injunction to block President Trump’s 10% global tariffs while the case is under consideration. The court has scheduled a three-judge panel to meet on April 10 to hear the state officials’ challenge to the Section 122 tariffs President Trump imposed. This will be heard in tandem with another challenge brough by an importer against the Section 122 tariffs. The CIT could issue its decision on the legality of the Section 122 tariffs by the end of April.
The United States Trade Representative has initiated new Section 301 investigations into acts, policies, and practices of 16 economies relating to structural excess capacity and production in manufacturing sectors. According to the USTR, these investigations will focus on “economies that appear to exhibit structural excess capacity and production in various manufacturing sectors, which can manifest as large or persistent trade surpluses or underutilized or unused capacity.” The economies in question include China, the European Union, Singapore, Switzerland, Norway, Indonesia, Malaysia, Cambodia, Thailand, Korea, Vietnam, Taiwan, Bangladesh, Mexico, Japan, and India. The USTR is inviting public comments on these investigations until April 15, and will hold a public hearing covering each investigated economy starting on May 5.
USTR Greer has also announced that he will soon initiate another Section 301 investigation into countries that do not enforce bans on goods produced with forced labor. This investigation will cover imports from more than 60 countries, and could result in new bans on imports into the U.S. of goods produced with forced labor. These bans may be similar to the existing bans on imports of solar panels and other goods from China's Xinjiang region under the Uyghur Forced Labor Prevention Act. USTR Greer said that he hoped to conclude both sets of Section 301 investigations, including proposed remedies, before the Section 122 tariffs imposed by President Trump expire on July 24, 2026.
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 March 12, 2026:
(
| | U.S. Tariff Measure | Status |
|---|---|---|
|
Global |
10% 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 regarding imports 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 |
Revised 6/4/2025 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: 4/17/2025 Suspended 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 Executive Order Removing “Stacking” of Tariff Programs |
|
Bangladesh Cambodia China EU India Indonesia Japan Malaysia Mexico Norway Singapore South Korea Switzerland Taiwan Thailand Vietnam |
Section 301: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors |
Pending: Section 301 Investigation |
|
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 Order Ending 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 Order Ending Tariffs |
|
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 Order Ending Tariffs |
|
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 CBP Fed Reg Notice Fed. Circuit Administrative Stay Fed. Circuit Order Granting Motion to Stay Executive Order Reducing Tariff Rate Executive Order Ending 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 Order Ending 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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