By: Mollie D. Sitkowski, Partner @ Faegre, Drinker, Biddle & Reath LLP
This article was last updated on June 25, 2025
The United States has enacted a complex web of tariffs in 2025 under multiple legal authorities, each targeting different economic and geopolitical concerns. The authorities predominately include the International Emergency Economic Powers Act (IEEPA), Section 232 of the Trade Expansion Act of 1962, and Section 301 of the Trade Act of 1974 The 232 tariffs include steel, aluminum, and automotive products. Further, the IEEPA tariffs are blanket tariffs issued pursuant to national emergencies related to fentanyl and “unfair trade practices.” Below is a detailed breakdown of each.
IEEPA Tariffs
IEEPA allows the President to regulate commerce during national emergencies. It has never been utilized for tariffs before 2025, and the President’s authority to issue tariffs pursuant to IEEPA currently being litigated in multiple courts.
Fentanyl-Related IEEPA Tariffs
The IEEPA Fentanyl tariffs were announced on February 1, 2025. They went into effect on February 4, 2025, but were modified.
- China (including Hong Kong): 20% tariff on all goods of Chinese origin, effective March 4, 2025. Originally 10%, but it was doubled due to “non-cooperation on fentanyl enforcement.”
- Canada & Mexico: 25% tariff on all goods of Canadian or Mexican origin, effective March 4, 2025.
Exemptions: Imports from Canada and Mexico which qualify for duty-free treatment under the U.S.-Mexico-Canada Agreement (“USMCA”) are exempt effective March 7, 2025. Goods subject to the Section 232 steel, aluminum, or automobile tariffs are not subject to Canada or Mexico IEEPA Fentanyl tariffs.
Universal/Reciprocal IEEPA Tariffs
These tariffs are commonly known as reciprocal tariffs within the news. Originally, rates were allocated on a country specific basis. However, there has been a pause and a reduction within the tariffs.
- Base Tariff: 10% on all imports from all countries, effective April 5, 2025.
- China-Specific: 125% reciprocal tariff announced but paused until August 12, 2025.
Exemptions: Certain goods classified in certain tariff classifications which are or will be subject to 232 investigations, and thus, likely subject to separate 232 tariffs
*U.S.-Origin Content Rule: Only the non-U.S. portion of a product is subject to the reciprocal tariff if at least 20% of its value is U.S.-originating.
Section 232 Tariffs
Section 232 of the Trade Expansion Act authorizes tariffs to protect national security. Steel and aluminum tariffs were originally enacted at 25% on March 12, 2025 for items from all countries classified in certain tariff classifications. However, on June 4th the amount was increased to 50%, except for the UK. Additionally, aluminum of Russian origin is subject to a 200% tariff. Please find the most recent update here. There are some exemptions for the 232 steel and aluminum tariffs.
It should be noted that now derivative articles and steel/aluminum articles in Chapters 73 and 76 will be subject to 50% (or 25% for UK) tariff only on their steel/aluminum content; although if the steel and aluminum content is not known, CBP has stated that importers should pay tariffs on the full value of the import. Steel articles classified in Chapter 72 are still subject to tariffs based on their entire value.
Exemptions: Derivative steel and aluminum articles are not subject to tariffs if the steel was melted and poured in the United States or the aluminum was smelted and poured in the United States. Additionally, if the good is subject to auto tariffs it is not subject to 232 aluminum or steel tariffs.
Next, 232 auto tariffs went into effect on April 3, 2025 while the tariffs on auto parts went into effect on May 3, 2025. They apply to all countries, but are assessed based on tariff classification and use in the amount of:
- Passenger vehicles and light trucks: 25% (varying on total value and portion that is non-US content)
- Parts: 25%
Exemptions: If the automobile is 25 years or older the tariff does not apply. If the automobile is USMCA certified, the importer will only pay on the non-US origin content after receiving approval from The Department of Commerce; USMCA-eligible parts are also exempt.
*An import subject to Section 232 auto tariffs will not be subject to (1) Canada/Mexico IEEPA fentanyl tariffs; and (2) Section 232 aluminum or steel tariffs.
Section 301 Tariffs (Trade Enforcement)
Section 301 of the Trade Act of 1974 targets unfair trade practices, especially by China.
Scope: Tariffs remain in place on hundreds of Chinese goods, including electronics, machinery, and consumer products.
Overlap: Many of these goods are now also subject to IEEPA and reciprocal tariffs, creating a layered tariff burden.
Exemptions: Case-by-case exclusions still apply, often based on national interest or supply chain concerns.
