Trump Tariff Tracker – December 26

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The U.S. Trade Representative ("USTR") concluded its investigation under Section 301 of the Trade Act of 1974, which was launched during the Biden Administration, regarding China's targeting of the semiconductor industry for dominance, but refrained from imposing immediate tariffs on China. Effective December 23, 2025, the USTR determined that China’s acts, policies, and practices regarding semiconductors are actionable under Section 301. However, the notice from the USTR says that the appropriate responsive action is to wait to impose tariffs in 18 months on June 23, 2027, at a rate to be announced not fewer than 30 days prior to that date. Beijing responded by saying in a statement that it “firmly opposes” this measure taken by the United States.

U.S. trading partners continue to pursue trade agreements with the Trump Administration as a way to minimize the tariff impact on their economies. India’s Ministry of External Affairs announced that it is increasing its negotiations with the U.S. to resolve differences related to tariffs, market access and regulatory concerns under the India–U.S. bilateral trade agreement that was announced in principle earlier this year. Both India and the U.S. have touted the  trade agreement as an important step towards increasing bilateral trade and investment, especially in the manufacturing, technology and services sectors.

Indonesia announced that it has concluded material negotiations with the U.S. and is set to sign a trade agreement with the U.S. in January. Under the announced deal, import duties on Indonesian goods entering the U.S. will be set at 19 percent. This is a decrease from the earlier reciprocal tariff rate of 32 percent, but was short of the Indonesian government’s request for zero tariffs.

The U.S. Department of Commerce’s International Trade Administration announced that it will be implementing a process by which interested parties can propose automotive parts to be subject to the Section 232 tariffs. This process will provide for recurring two-week windows in January, April, July, and October, in which parties can make submissions to the Commerce Department requesting additional automotive parts to be added to the list of items subject to the Section 232 tariffs. The first two-week window will begin January 1, 2026, and will last until January 14. 2026. Additional information on this process and the opportunity for public comment can be found in the Department’s Federal Register notice by clicking here.

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 December 26, 2025:

        U.S. Tariff Measure Status
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)

USTR Fed Reg Notice

USTR Fed Reg Notice of Action

Global 

[Canada & Mexico Exempt]

Reciprocal tariffs – 10% ad valorem duty

Country specific duty rates of 15% to 50% ad valorem

Certain goods excluded

 

In Effect Pending Court Resolution

Revised 11/20/2025

Implemented 4/2/2025

Presidential Memorandum

Executive Order Establishing Tariffs

Executive Order Revising Tariffs

CBP Bulletin on Excluded Electronics

Executive Order Reducing China Tariff Rates

CIT Ruling Slip Op. 25-66

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 

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 

DOC Initiation and Request for Public Comments

Proclamation on Sec. 232 Duties

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

USTR Fed. Reg. Notice

USTR Fed. Reg. Notice of Proposed Suspension

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

Proclamation on Sec. 232 Duties

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 

DOC Request for Public Comments

Proclamation on Sec. 232 Duties

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

Commerce Fed Reg Notice

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

CBP Guidance on Additional Steel Derivative Products

Commerce Notice of Inclusion of Additional 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

Commerce Fed Reg Notice

Executive Order Removing “Stacking” of Tariff Programs

Proclamation Increasing Tariff Rate

Executive Order Implementing US-UK Trade Deal

Commerce Notice of Inclusion of Additional Products

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 Fed Reg Notice 

USTR Notice of Action/Proposed Action, Request for Comments, and Notice of Public Hearing

USTR Request for Comments on Proposed Modification

USTR Fed. Reg. Notice of Proposed Suspension

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

Executive Order Implementing US-UK Trade Deal

Global  All goods imported from any country that imports Venezuelan oil – discretionary 25% ad valorem duty may be imposed

Implemented 4/2/2025 

Executive Order 

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

In Effect Pending Court Resolution

Implemented: 3/4/2025; 

4/2/2025 (updated) 

Executive Order

CBP Fed Reg Notice

Executive Order Suspending

Executive Order Update

CIT Ruling Slip Op. 25-66

Fed. Circuit Administrative Stay

Fed. Circuit Order Granting Motion to Stay

Mexico 25% ad valorem duty on all non-USMCA-qualifying products of Mexico

In Effect Pending Court Resolution

Implemented: 3/4/2025; 

4/2/2025 (updated) 

Executive Order

CBP Fed Reg Notice 

Executive Order Suspending

Executive Order Update

CIT Ruling Slip Op. 25-66

Fed. Circuit Administrative Stay

Fed. Circuit Order Granting Motion to Stay

China 10% ad valorem duty on all products of China (reduced from original rate of 20%)

In Effect Pending Court Resolution

Implemented: 3/4/2025

Executive Order

CBP Fed Reg Notice 

CIT Ruling Slip Op. 25-66

Fed. Circuit Administrative Stay

Fed. Circuit Order Granting Motion to Stay

Executive Order Reducing Tariff Rate

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

DOC Initiation and Request for Public Comments

Global  Robotics and Industrial Machinery – potential tariffs on imports of robotics and industrial machinery

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

Global 

Wind Turbines – potential tariffs on imports of wind turbines and their parts and components

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

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

USTR Fed Reg Notice 

Public Hearing Transcript

Global Unmanned Aircraft Systems – potential tariffs on imports of unmanned aircraft systems (UAS) and their parts and components

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

Global   Polysilicon – potential tariffs on imports of polysilicon and its derivatives

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

Global Aircraft and Engines – potential tariffs on imports of commercial aircraft and jet engines, and aircraft/engine parts

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments

Global Critical  Minerals – potential tariffs on imports of processed critical minerals and derivative products

Pending: Section 232 Investigation

Executive Order

DOC Initiation and Request for Public Comments

Global Semiconductors – potential tariffs on imports of semiconductors, SME, and derivative products

Pending: Section 232 Investigation 

DOC Initiation and Request for Public Comments

Global Pharmaceuticals– potential tariffs on imports of pharmaceuticals, pharmaceutical ingredients, and derivative products

Pending: Section 232 Investigation

DOC Initiation and Request for Public Comments 

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.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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