The Weekly Current

It’s okay to admit it—the past month has been a rollercoaster unlike any other in trade. Despite the challenges, a collective pat on the back is warranted as we quickly gear up for what March has in store. While the 2018 tariffs under the first Trump administration gave us some idea of what to expect, importers, customs brokers, software companies, and government agencies faced a flurry of impacted countries, shifting tariff percentages, and the invocation of various regulations in January—putting our systems and adaptability to the test.

We quickly learned that the 2025 tariffs under President Trump are issued with short lead times, offer limited recourse, and are broad in scope. However, trade-related orders have also contained elements that were paused for infrastructure considerations or further negotiations with trading partners, requiring the trade community to remain agile while ensuring compliance.

February Tariffs

IEEPA – On February 4, 2025, an additional 10% tariff took effect on nearly all goods of Chinese (or Hong Kong) origin. A 25% tariff was also scheduled for Mexico and Canada on the same day but was placed on a 30-day hold. Tariffs enacted under the International Emergency Economic Powers Act (IEEPA) are based on the declaration of a national emergency. In this case, the national emergency concerning China aims to address the supply chain of synthetic opioids entering the U.S.

The order does not permit drawback relief or exclusions and initially halted de minimis treatment for imports from China. The IEEPA tariffs can be lifted when the President determines that sufficient measures have been taken to address the underlying emergency. For China and Canada, the orders focus on opioids and the flow of illicit drugs, while the Mexico order also addresses illegal migration at the southern border.

Approximately 85% of parcel shipments from China are e-commerce, and bulk carriers handling low-value goods were immediately overwhelmed due to the lack of a processing mechanism for de minimis shipments. As a result, the removal of de minimis treatment was temporarily paused until adequate systems were in place to fully and expediently process and collect tariff revenue, with further guidance anticipated.

March: In Like a Lion…

This week, President Trump was quoted as saying that IEEPA tariff increases for Mexico and Canada are “on time” for March 4. The increases will impose a 25% tariff, with energy and energy resources from Canada facing a 10% tariff. If these tariffs proceed as planned, the trade community will closely monitor their impact on the USMCA (U.S.-Mexico-Canada Agreement), including how the measures could affect cross-border trade and the future of the agreement.

Section 232

Under Section 232 of the Trade Expansion Act of 1962, the President has broad authority to adjust imports if they are determined to threaten U.S. national security. In 2018, the first Trump administration used Section 232 to impose tariffs on steel and aluminum imports, citing national security concerns. The resulting tariffs were initially broad, though multiple countries later negotiated exemptions, quotas, or alternative arrangements.

While the 2018 tariffs on steel and aluminum affected imports from numerous countries, concerns have since grown over increased imports through third countries, both in raw materials and finished goods. As a result, effective March 12, Section 232 tariffs on covered steel and aluminum products will be set at 25%, additional Harmonized Tariff Schedule (HTS) classifications will be added, and several countries—including EU member states, Australia, South Korea, and Brazil—will become subject to the revised tariffs as previous exemptions and alternative arrangements expire. Guidance on documentation and tariff calculations for certain derivative products is still forthcoming.

Will April Be Quiet as a Lamb?

The America First Trade Policy remains a cornerstone of the Trump administration, with stated objectives focused on addressing trade imbalances, strengthening U.S. economic and national security, and protecting American intellectual property abroad.

April will be a critical month as several key agency reports are due to the President, potentially shaping the next phase of U.S. trade policy. These include a review of the feasibility of establishing an External Revenue Service (ERS) to collect tariffs, duties, and other foreign trade-related revenues, assessments of existing free trade agreements, reciprocal trade policies, and reviews of export controls affecting U.S. technology and intellectual property. The potential establishment of an ERS has the trade community watching closely to see how a new collection structure could operate, while reviews of reciprocal trade practices and export controls have trade practitioners advising companies to assess potential impacts on sales, inventory transfers, and licensing requirements.

Section 301 Tariffs

During the first Trump administration, Section 301 of the Trade Act of 1974 was used to impose additional tariffs ranging from 7.5% to 25% on a wide array of Chinese goods. These tariffs were imposed in response to USTR findings regarding China’s practices related to technology transfer, intellectual property, and innovation.

Many of these tariffs remain in effect today, and potential reviews of tariff rates, HTS classifications, and targeted products remain an important area for importers to monitor.

OCEANAIR is actively monitoring these developments and will continue to keep our clients informed.