Trump Administration Issues Modifications to Reciprocal Tariff Rates

Government Relations, Section 232, Trade and Tariffs

President Trump has signed an executive order further modifying the reciprocal tariff rates announced in April 2025.

The order includes Annex I which provides a list of countries and the country-specific reciprocal rates that will apply to them.

These rates will go into effect for imports which are entered on or after August 7, 2025.

Any countries not listed in Annex I will continue to be subject to the 10% baseline reciprocal tariff.

The order does provide the following exception: “goods loaded onto a vessel at the port of loading and in transit on the final mode of transit before 12:01 am eastern daylight time on August 7, 2025, and entered for consumption or withdrawn from warehouse for consumption before 12:01 am eastern daylight time on October 5, 2025, shall not be subject to such additional duty and shall instead remain subject” to the reciprocal tariff previously imposed.

The order indicates that for “certain foreign trading partners” in Annex I with which the United States is still negotiating agreements, the rates provided in Annex I will remain in place until those agreements are concluded and subsequent orders are issued.

The order also provides for a bifurcated reciprocal tariff rate for the European Union:

  1. For goods with a Column 1 (normal) duty rate of less than 15%, the reciprocal tariff shall be 15%.
  2. For goods with a Column 1 (normal) duty rate of 15% or more, the reciprocal tariff shall be zero.

The order also states that an article determined by CBP to have been transshipped to evade these reciprocal tariffs shall be subject to a 40% duty (in lieu of the reciprocal tariff applicable to the country of origin), in addition to any fines, penalties, and other duties, fees, taxes, exactions, or charges.

In addition, the order instructs the Secretary of Commerce and the Secretary of Homeland Security in consultation with the USTR to publish every 6 months “a list of countries and specific facilities used in circumvention schemes, to inform public procurement, national security reviews, and commercial due diligence.”