Update as of August 1, 2025:

As U.S. trade policy continues to evolve this week, we’re closely tracking the latest developments to keep our clients informed and ready to respond strategically and tactically. Please note that the updates below reflect the trade environment at the time of posting and may be subject to change.

KEY DATES AND TRADE ACTIONS

Effective August 1, 2025

IEEPA Fentanyl: Canada

• Tariff on Canadian non-USMCA goods increased from 25% to 35%.
• Goods determined by CBP to have been transshipped to evade Canadian tariffs will be reclassified and subject to a 40% duty rate.
• Link to Executive Order

IEEPA Fentanyl: Mexico

• 90-day extension of current trade terms with Mexico.
• Tariff increase from 25% to 30% (originally effective August 1) is paused.

Section 232: Copper

• 50% tariff on the copper content of semi-finished copper products and intensive copper derivative products.
• As of posting, there is no overlap in subject HTS classifications between the Section 232 steel and aluminum, and copper lists.
• Exemptions:
  1. Goods already subject to Section 232 duties on automobiles and auto parts.
  2. Goods under the subject HTS classifications with no copper content.
• The Secretary of Commerce will review additional derivative copper articles for potential inclusion within 90 days.
• Link to Proclamation

Effective August 6, 2025

IEEPA Brazil

• 40% duty on certain imports from Brazil, resulting in a total IEEPA tariff rate of 50% (including the 10% universal tariff).
• Exemptions:
  1. Goods loaded before 12:01 a.m. EDT on August 6 and arriving before 12:01 a.m. EDT on October 5.
  2. Goods listed in Annex I.
  3. Goods covered under 50 U.S.C. 1702(b).
  4. Goods already subject to Section 232 duties.
• Link to Executive Order

Effective August 7, 2025

IEEPA Reciprocal

• For countries listed in Annex I, modified duty rates will apply.
• For all other countries, the universal 10% duty rate remains in effect.
• For goods of the European Union:
  1. If the general duty rate (Column 1 of the HTSUS) is less than 15%, the total duty rate (Column I and IEEPA reciprocal) will be 15%.
  2. If the general duty rate is 15% or higher, the additional IEEPA reciprocal tariff will be zero.
• Exemptions:
  1. Goods in transit before 12:01 a.m. EDT on August 7 and arriving before 12:01 a.m. EDT on October 5.
• Goods determined by CBP to have been transshipped to evade the IEEPA tariffs will be reclassified and subject to a 40% duty rate.
• Link to Executive Order

Effective August 29, 2025

De Minimis Treatment

• Duty-free de minimis treatment is suspended for all countries, regardless of value, country of origin, mode of transportation, or method of entry.
• See our blog post on de minimis for further details.
• Link to Executive Order