Dear Valued Client,
President Trump stated today that the previously announced 25% tariff on Canada (10% on certain energy-related products) and Mexico will take effect on March 4. This decision follows a temporary 30-day pause in the implementation of these tariffs, which was granted earlier in February after Canada and Mexico agreed to increase border security measures and engage in further discussions on combating drug trafficking.
No official notice has been published in the Federal Register regarding implementation instructions, including the announced March 4 effective date.
Canadian Prime Minister Justin Trudeau has warned that the tariffs would prompt an “immediate and extremely strong response” from Canada, including retaliatory tariffs on U.S.-origin goods – likely those initially initiated and later revoked after President Trump placed a temporary pause on the implementation of the tariffs on Canadian-origin goods. These previously announced Canadian retaliatory tariffs include almost 400 agricultural products such as poultry, pork, and dairy products, several row crop products (including wheat, barley, and rice), some fresh fruits and vegetables such as oranges, tomatoes, and green beans, and various processed food products like chocolates, pasta, and soup.
While Mexico has not officially announced retaliatory tariffs if the U.S. tariffs on Mexican-origin products go forward, earlier reports claimed that Mexico was preparing retaliatory tariffs on such products as pork, cheese, fresh produce, manufactured steel, and aluminum.
It remains to be seen whether negotiations between the U.S., Canada, and Mexico will avert or delay the effective date of these new tariffs.
In addition to the March 4 start date for the IEEPA-based 25% tariffs on Canadian- and Mexican-origin products,
President Trump’s Truth Social post stated that the existing IEEPA-based 10% tariff on Chinese-origin products that went into effect earlier this month would be doubled to 20%, also as of March 4; presumably, the new double rate will apply to products of Hong Kong as well As in the tariffs on Canada and Mexico, the stated basis for the tariffs on Chinese-origin products is a declared national emergency stemming from the flow of fentanyl into the U.S. (for China, its production and exportation of both fentanyl and precursor chemicals for fentanyl). No official notice has been published in the Federal Register regarding implementation instructions, and it remains to be seen whether negotiations with China will avert or delay the effective date for this doubling of the tariff rate.
Presumably, the current guidance, updated by CBP on February 25, 2025, will continue to apply. The initial Federal Register notice on the 10% IEEPA tariffs on China sets forth the effective date and time and limited exclusions, such as for goods on the water.
Additional Tariffs
On February 18, 2025, President Trump stated that he is likely to impose tariffs of approximately 25% on automobile, semiconductor, and pharmaceutical imports, with an announcement expected as soon as April 2. Notably, President Trump commented that the beginning rate for such tariffs would be 25% and would then rise substantially over the following year. The stepped increase in the tariff rate is intended to give the White House time to negotiate with foreign manufacturers to move production to the US, presumably in exchange for tariff relief.
Here is a compiled summary below of the certain significant tariff-related actions. Both currently in effect and proposed.
| Tariff Rate | Authority | Effective Date | Scope | Exclusions/Exemptions | |
| China | 7.5%, 25%, 50% or 100% | Section 301 | 2018 onward | A large percentage of classifications | Limited exclusions |
| China and Hong Kong | 10% increasing to 20% on March 4 | IEEPA | February 4, 2025 | Universal | Limited exclusions for donations for humanitarian relief, informational materials, and Chapter 98 provisions |
| Canada | 25% /
10% |
IEEPA | March 4, 2025 | Universal (25%)/
Energy Products (10%) |
TBD (with the exception of limited exclusions for donations of humanitarian relief and informational materials, none included in Executive Order imposing tariffs) |
| Mexico | 25% | IEEPA | March 4, 2025 | Universal | TBD (with the exception of limited exclusions for donations of humanitarian relief and informational materials, none included in Executive Order imposing tariffs) |
ALL COUNTRIES tariff rate of Section 232 – 25% / 10% will not be effective until Commerce certifies that an effective system is in place to collect the tariffs.
Current 10% Section 232 tariffs on aluminum and limited universe of derivative aluminum articles will rise to 25% on March 12. In addition, country-specific exceptions (by agreement, quota, etc.) and GAEs will terminate, also on March 12
Reciprocal tariffs on all countries are TBD
