US imposes new tariffs on Canada, Mexico and China
Date of Update: March 7, 2025
important
CA update:
On March 6, 2025, President Trump issued an Executive Order postponing until April 2, 2025, the tariffs imposed on imports from CA that went into effect on March 4, 2025. Articles that are entered free of duty as a good of Canada under the terms of general note 11 to the (HTSUS), including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTSUS, as related to USMCA, shall not be subject to the additional ad valorem rate of duty. There was also a specific mention that the additional rate of duty on potash that is not subject to USMCA, shall be reduced to 10 percent in lieu of 25 percent. A subsequent CSMS from CBP was published shortly after with further entry filing instructions.important
MX update:
On March 6, 2025, President Trump issued an Executive Order postponing until April 2, 2025, the tariffs imposed on imports from MX that went into effect on March 4, 2025. Articles that are entered free of duty as a good of Mexico under the terms of general note 11 to the (HTSUS), including any treatment set forth in subchapter XXIII of chapter 98 and subchapter XXII of chapter 99 of the HTSUS, as related to USMCA, shall not be subject to the additional ad valorem rate of duty. There was also a specific mention that the additional rate of duty on potash that is not subject to USMCA, shall be reduced to 10 percent in lieu of 25 percent. A subsequent CSMS from CBP was published shortly after with further entry filing instructions.On March 3, 2025, President Trump announced new tariff actions against Canada, Mexico and China (and Hong Kong) to implement additional tariffs effective March 4, 2025. These actions are in follow up to previous Executive Orders (EO) issued February 1, 2025, applying additional tariffs on imported goods from the three countries. Details of the initial orders were covered in a previous Regulatory Insights article. These tariffs were scheduled to become effective initially on February 4, 2025.
Overview of prior actions
The initial tariff actions called for an additional 10% ad valorem duty on all goods imported from China, 25% duty on all goods imported from Mexico, and 25% duty on all goods imported from Canada (with a stipulation for energy products and resources, which would have a duty rate of 10%).
The reason for the tariffs was to address the illicit flow of opioids (fentanyl) across the US northern and southern borders, as well as illegal immigration.
Both the Mexico and Canada tariffs were delayed for 30 days based on initial actions taken by both countries to address the cross-border concerns. The China tariffs were not delayed and the
10% additional tariffs on all goods imported from China became effective at 12:01 am on February 4, 2025
.Although de minimis shipments were initially included in the EO, a subsequent EO was issued postponing application on de minimis until the Secretary of Commerce deemed a system was in place to accurately manage those entries. This is still pending.
China took various retaliatory measures, Canada prepared measures but held off on moving forward, and Mexico took a wait-and-see approach based on on-going dialogue with the Trump Administration.
New actions taken
On March 3, 2025, President Trump issued updated Executive Orders for all three countries. The
EOs state that the tariffs will be applied with respect to goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 am EST on Tuesday, March 4, 2025
.The tariffs will be applied as follows:
- Mexico – Additional 25% ad valorem duty on all imports from Mexico
- Canada – Additional 25% ad valorem duty on all imports from Canada
- Additional 10% ad valorem duty on all energy products and resources as defined by 30 U.S.C. 1606(a)(3).
- China (and Hong Kong) – Additional 10% ad valorem duty on all imports from China (this is in addition to the prior 10% applied in February, bringing the additional duty rate to 20%)
- The tariffs will be applied with respect togoods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 am EST on Tuesday, March 4, 2025.
- All goods will be subject to anadditional ad valorem rate of dutydependent on the country of origin (10-25% for CA & MX, and 10% for CN).
- The Secretary of Homeland Security shall determine the modifications necessary to the Harmonized Tariff Schedule of the United States (HTSUS) and has made such modifications to the HTSUS through notice in the Federal Register. As with the earlier China tariffs, CBP will be using Chapter 99 headings for identification of applicable tariffs. Details can be found in the respective links for each country shown above.
- The rates of duty established by these orders arein addition toany other duties, fees, exactions, or charges applicable to such imported articles.
- No drawbackshall be available with respect to the duties imposed pursuant to this order.
- Duty-freede minimistreatment under 19 U.S.C. 1321 is available for the articles described in the FRN until such time that the Secretary of Commerce provides further guidance.
- With respect toFTZs, articles that are products of Canada, except those that are eligible for admission under “domestic status” as defined in 19 CFR 146.43, which are subject to the duties imposed by this order and are admitted into a US FTZ on or after 12:01 a.m. eastern time on March 4, 2025, must be admitted as “privileged foreign status” as defined in 19 CFR 146.41. Such articles will be subject upon entry for consumption to the rates of duty related to the classification under the applicable HTSUS subheading in effect at the time of admittance into the United States foreign trade zone.
- Should the country retaliate against the United States in response to this action through import duties on United States exports or similar measures, the President may increase or expand in scope the duties imposed under this order to ensure the efficacy of this action.
New retaliatory measures
Canadian Prime Minister Justin Trudeau responded to the U.S. tariffs
by saying that his country will impose 25 percent tariffs on C$155 billion worth of imports from the U.S. in two phases and that these tariffs will remain in place until the U.S. eliminates its tariffs against Canada. The first phase, which took effect March 4, 2025
, covers C$30 billion worth of goods, including orange juice, peanut butter, wine, spirits, beer, coffee, appliances, apparel, footwear, motorcycles, cosmetics, and pulp and paper. The specific items are detailed within the Phase 1 Targeted Goods List. The second phase, which is slated to take effect March 25, will include passenger vehicles and trucks, steel and aluminum products, certain fruits and vegetables, aerospace products, beef, pork, dairy, recreational vehicles, and recreational boats. If the US tariffs are not removed, additional non-tariff remedies will be pursued.President Sheinbaum of Mexico has indicated that Mexico will take retaliatory measures. She added that Mexico’s Government will respond with tariff and non-tariff measures, but these will not be
announced until Sunday, March 9, 2025
, when an “informative assembly” in the Zócalo of Mexico City, where she will announce the tariff plan against the US.China, who had taken previous retaliatory steps (see our prior article), implemented additional steps on March 4, 2025.
- A new 15% tariff will be imposed on chicken, wheat, corn and cotton. For the specific commodity range, see Appendix 1.
- A 10% tariff will be imposed on sorghum, soybeans, pork, beef, aquatic products, fruits, vegetables, and dairy products. For the specific range of commodities, see Appendix 2.
- Goods that have been shipped from the place of departure before March 10, 2025 and imported between March 10, 2025 and April 12, 2025 shall not be subject to the additional tariffs.
- Additionally, 15 new US companies were added to the Export Control List. Export of dual-use items to these entities is prohibited and any existing activities with these companies must be stopped immediately.
- China has also taken steps to prohibit Illumina (on the Unreliable Entities List) from exporting gene sequencers to China, as well as adding 10 new US entities to the list.
- Opened an anti-dumping investigation on non-dispersion-shifted single-mode optical fibers originating in the United States.
- China has suspended imports of US lumber effective immediately.
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