IEEPA Tariffs on Canada, China & Mexico | Sandler, Travis & Rosenberg, P.A.

President Trump issued in executive orders in February and March 2025 imposing and increasing additional tariffs on imports from Canada, China, and Mexico following his declaration of a national emergency with respect to the flow of narcotics and illegal immigrants across U.S. borders.

New! Late on March 6, those actions were modified for Canada and Mexico to exclude imports that qualify for duty-free treatment under the U.S.-Mexico-Canada Agreement and to lower the additional tariff on potash to 10 percent.

ST&R offers a three-pronged approach to avoiding, mitigating, and/or recovering these and other tariffs on imported goods. For more information on the impact of the new tariffs, and which of these strategies might be most effective for your business, please contact ST&R.

Below is the status of tariffs on each country.

Tariffs on Canada

Status: In Effect as of 12:01 am ET on March 4, 2025

New! USMCA & Potash Exemptions (March 6 Modifications): 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” as related to the USMCA are exempted from the additional tariff.

Further, the additional tariff on imports of potash from Canada has been lowered to 10 percent.

These changes are to take effect for covered goods entered or withdrawn from warehouse for consumption on or after 12:01 am EST on March 7. While administration officials have said the tariff suspensions are only valid until April 2, the EOs and Federal Register notices include no termination date for them.

Tariff rates - A ten percent tariff on energy and energy resources from Canada, as well as a 25 percent tariff on imports of all other products of Canada. These tariffs are in addition to any other applicable duties, fees, exactions, or charges.

Affected goods - The ten percent tariff on energy imports from Canada applies to crude oil, natural gas, lease condensates, natural gas liquids, refined petroleum products, uranium, coal, biofuels, geothermal heat, the kinetic movement of flowing water, and critical minerals. The 25 percent tariff applies to all other products of Canada.

There are limited exceptions for humanitarian donations and informational materials. There is no mention of a process for excluding specific goods from the tariffs.

De Minimis - As part of the original, February 1st Executive Order, de minimis entry was not available. However, an amended Executive Order on March 2 temporarily allows de minimis until "notification by the Secretary of Commerce to the President that adequate systems are in place to fully and expediently process and collect tariff revenue."

Additional Details-

Drawback is not available
Articles that are products of Canada, except those that are eligible for admission under domestic status, that are subject to these tariffs and are admitted into a U.S. foreign-trade zone on or after 12:01 a.m. EDT on March 4 (with certain exceptions) must be admitted as privileged foreign status. Upon entry for consumption such articles will be subject to the duty rates related to the applicable HTSUS subheading in effect at the time of admittance into the FTZ.

Official Documents

CSMS #64336037: GUIDANCE - Update on Additional Duties on Imports from Canada - USMCA Qualifying Producrts and Potash (March 6, 2025)
Federal Register: Implementation of Additional Duties on Products of Canada Pursuant to the President's Executive Order 14193, Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border (March 11, 2025)
Executive Order: Amendment to Duties to Address the Flow of Illicit Drugs Across Our Northern Border (March 6, 2025)
Federal Register: Notice of Implementation of Additional Duties on Products of Canada Pursuant to the President's Executive Order 14193, Imposing Duties to Address the Flow of Illicit Drugs Across Our Northern Border (March 6, 2025)
CSMS #64297449: GUIDANCE: Additional Duties on Imports from Canada (March 3, 2025)
Executive Order: Amendment to Duties to Address the Flow of Illicit Drugs Across Our Northern Border (March 2, 2025)
Executive Order: Progress on the Situation at Our Northern Border (February 10, 2025)
CSMS #63991510: GUIDANCE: Pause on Application of Additional Duties on Imports from Canada (5:50 pm EST February 3, 2025)
Executive Order: Progress on the Situation at Our Northern Border (February 3, 2025)
This message has been retracted per CSMS 63991510 above
CSMS # 63988467: GUIDANCE: Additional Duties on Imports from Canada (2:22 pm EST February 3, 2025)
Note this is modified by Executive Order on February 3 above
Executive Order: Imposing Duties to Address the Flow of illicit Drugs Across our Northern Border (February 1, 2025)

Tariffs on China

Status: In Effect as of 12:01 a.m. ET on February 4, 2025

Information on the 7.5% - 25% Section 301 tariffs on China first implemented in 2018 can be found on our Section 301 Tariffs on China page.

On March 3, President Trump issued an Executive Order increasing the IEEPA tariff on China and Hong Kong to twenty percent for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 Eastern time on March 4, 2025.

The original IEEPA tariff of an additional ten percent on imports from China and Hong Kong was in effect from 12:01 am eastern time on February 4th, 2025 through March 3, 2025.

Tariff Rates - A twenty percent tariff is imposed on imports of all products of China (including Hong Kong). These tariffs are in addition to any other applicable duties, fees, exactions, or charges.

Affected Goods - This tariff is imposed on imports of all products of China (including Hong Kong). These tariffs are in addition to any other applicable duties, fees, exactions, or charges.

De minimis

As part of the original, February 1st Executive Order, de minimis entry was not available for imports subject to the additional tariffs, and formal entry was required for all mail shipments.

However, on February 7th, President Trump amended the Executive Order dated February 5th that temporarily reinstates de minimis for products of China and Hong Kong until "notification by the Secretary of Commerce to the President that adequate systems are in place to fully and expediently process and collect tariff revenue."

Additional Details

The tariffs will not be imposed on affected goods that were loaded on a vessel or in transit on the final mode of transport before 12:01 a.m. EDT on Feb. 1 provided they are entered or withdrawn from warehouse for consumption before 12:01 a.m. EDT on March 7.
Tariff exemptions for goods entered under applicable HTSUS Chapter 98 provisions will be available.

Official Documents

Tariffs on Mexico

Status: In Effect as of 12:01 am ET on March 4, 2025

New! USMCA & Potash Exemptions (March 6 Modifications): 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” as related to the USMCA are exempted from the additional tariff.

Further, the additional tariff on imports of potash from Mexico has been lowered to 10 percent.

Tariff Rates - A 25 percent tariff is imposed on imports of all products of Mexico. These tariffs are in addition to any other applicable duties, fees, exactions, or charges.

Affected Goods - The tariff applies to all articles that are products of Mexico. There are limited exceptions for humanitarian donations and informational materials. There is no mention of a process for excluding specific goods from the tariffs.

Additional Details -

Drawback is not available
Articles that are products of Mexico, except those that are eligible for admission under domestic status, that are subject to these tariffs and are admitted into a U.S. foreign-trade zone on or after 12:01 a.m. EDT on March 4 (with certain exceptions) must be admitted as privileged foreign status. Upon entry for consumption such articles will be subject to the duty rates related to the applicable HTSUS subheading in effect at the time of admittance into the FTZ.

Official Documents