Publish Date

May 21, 2025

Regulating Imports With a Reciprocal Tariff

Mexico Tax Update

In an effort to restore balance in global trade and reinforce domestic economic and national security, the United States has enacted a new tariff regime. This policy introduces broad ad valorem duties on imported goods, with specific provisions targeting countries with nonreciprocal trade practices. The measure is part of a larger strategy to revitalize American industry, ensure fair competition and reduce vulnerabilities in critical supply chains.[1]

The table below provides a chronological summary of key actions, affected countries and products, applicable rates, and enforcement status.

Announcement Date Country Affected Measure / Action Products Affected Tariff Rate (%) Application Status
February 1, 2025
Mexico & Canada
Emergency tariff plan under International Emergency Economic Powers Act (IEEPA); general pressure on USMCA compliance
Finished steel
25%
Suspended February 3
Mexico & Canada
Same action; lower rate on strategic imports
Unalloyed/semi-finished aluminum
10%
Canada
Energy exception to avoid domestic disruption
Natural gas, crude oil, potash
10%
March 4, 2025
Mexico & Canada
Reactivation of tariffs due to failure to implement bilateral terms.
Finished steel
25%
In force
Aluminum, alloyed parts
10%
In force
Canada
Preferential tariff confirmed on strategic energy imports.
Oil, gas, potash
10%
In force
Mexico & Canada
Selective 25% on non-USMCA compliant goods
Non-automotive industrial products
25%
In force
March 27, 2025
Mexico & Canada
Official imposition of 25% tariff on automobiles and auto parts, under Section 232 citing national security grounds; part of “North American Production Repatriation Act,” signed same day
Automobiles, auto parts (general, not limited to USMCA rules)
25%
Effective March 27
April 2, 2025
Global
Executive Order 14257 signed: 10% base tariff, discretionary higher rates for non-reciprocal trade
All imports
10% (base)
Effective April 5
April 2, 2025
China
Under Executive Order 14257 and opioid provisions, additional sanctions[2]
All Chinese-origin goods

145% total

Paused May 14

April 9, 2025

Nonreciprocal countries
Country-specific tariffs announced (except China)
Listed imports (Annex I)

up to 25%

Paused April 10

April 10, 2025

Nonreciprocal countries
90-day pause for compliance review and transition[3]
Same as above

Pause in effect

May 12, 2025

China
90-day pause on Chinese tariffs pursuant to the modification of Executive Order 14257
All Chinese-origin goods

34%  base levy

Effective May 14

July 9, 2025

Nonreciprocal countries
Expected end of 90-day suspension (subject to review)
All imports (technical scope)

Varied

TBD

August 12, 2025

China
Expected end of 90-day suspension of the Chinese reduction
All imports (technical scope)

Varied

TBD

Certain goods will be exempt from these additional reciprocal tariffs. Among these exemptions are imports deemed necessary for national security under 50 U.S.C. 1702(b) (e.g. personal communications: emails, phone calls, messages; informational materials: publications, films, etc.; humanitarian donations: food, medicine, clothing; and travel-related transactions), as well as steel and aluminum products that are already subject to Section 232 tariffs. Automobiles and automotive parts facing existing Section 232 tariffs will also be excluded, along with critical products such as copper, pharmaceuticals, semiconductors, lumber, and energy resources. Additionally, goods already classified under Column 2 of the Harmonized Tariff Schedule (HTSUS) and any future products designated under Section 232 will not be affected.[4]

These new duties will be imposed in addition to any other applicable taxes or tariffs unless stated otherwise.

Special provisions apply to imports from Canada and Mexico due to national emergencies concerning illicit drugs and migration; however goods originating under the U.S.-Mexico-Canada Agreement (USMCA) will continue to benefit from preferential trade terms. On the other hand, non-originating goods from these countries will be subject to an additional 25 percent tariff, except for energy resources and potash from Canada, which will face a lower 10 percent tariff. If the emergency tariffs are lifted, non-originating goods from Canada and Mexico will instead be subject to a 12 percent tariff, excluding energy products and specific components finished in the U.S.

Foreign trade zone admissions for covered goods must use “privileged foreign status” classification unless they qualify for “domestic status.” De minimis tariff exemptions remain available temporarily but can be revoked once the U.S. Department of Commerce confirms systems are in place for collecting duties efficiently.

Following the signing of Executive Order 14257 on April 2, 2025, the United States significantly escalated its tariff measures against China. While the order initially established a 10 percent base tariff on all imports and authorized country-specific increases, the case of China quickly evolved. In the days following, a series of retaliatory actions between both countries triggered a rapid escalation. By April 11, 2025, the cumulative tariff burden on most Chinese-origin goods reached 145 percent, combining existing duties with new penalties for perceived unfair trade practices and national security concerns. Additionally, low-value shipments (de minimis) from China, typically exempt from duties, became subject to elevated tariffs — part of a broader effort to prevent evasion and enforce strategic controls. These enhanced duties were extended to cover goods from Hong Kong and Macau as well, reinforcing the administration’s stance on enforcement integrity.

The United States is enforcing a revised and expanded tariff framework introduced under Executive Order 14257. A universal 10 percent ad valorem duty is currently applied to most imports, with additional country-specific tariffs in effect, most notably a 145 percent cumulative tariff on Chinese-origin goods. Goods from nonreciprocal trading partners are still subject to enhanced duties, although enforcement for some countries remains paused pending review. The Harmonized Tariff Schedule of the United States (HTSUS) has been formally updated through Revision 10, issued by the USITC, to reflect these changes. Exemptions remain in place for critical sectors and national security goods, while de minimis privileges are being reevaluated. Overall, the new system reflects a structural shift away from Most-Favored-Nation norms and toward a policy framework grounded in reciprocity, strategic autonomy and supply chain security.


[1]“Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits,” The White House, Executive Orders, updated April 2, 2025, https://www.whitehouse.gov/presidential-actions/2025/04/regulating-imports-with-a-reciprocal-tariff-to-rectify-trade-practices-that-contribute-to-large-and-persistent-annual-united-states-goods-trade-deficits/

[2]“Fact Sheet: President Donald J. Trump Closes De Minimis Exemptions to Combat China’s Role in America’s Synthetic Opioid Crisis,” The White House, Fact Sheets, April 14, 2025, https://www.whitehouse.gov/fact-sheets/2025/04/fact-sheet-president-donald-j-trump-closes-de-minimis-exemptions-to-combat-chinas-role-in-americas-synthetic-opioid-crisis/

[3]“CBP Guidance on Foreign Trade Zones and Privileged Foreign Status,” U.S. Customs and Border Protection, Trade Notices, updated April 2025, https://content.govdelivery.com/accounts/USDHSCBP/bulletins/3db42c8

[4]“2025 Executive Order 14257: Annex II – Exemptions and Tariff Classifications,” Federal Register, Office of the Federal Register (Public Inspection), April 2, 2025, https://public-inspection.federalregister.gov/2025-06063.pdf

https://www.alvarezandmarsal.com/thought-leadership/regulating-imports-with-a-reciprocal-tariff