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Update on the Trump Administration’s Sweeping Actions on Tariffs

Los Angeles, Calif. (May 20, 2025) - Since his second term began in January 2025, President Donald J. Trump has issued a flurry of executive orders that imposed sweeping global tariffs, including new tariffs on China, Mexico, and Canada, on steel and aluminum imports, and on certain automobile parts. On April 2, 2025 (referred to as “Liberation Day”), President Trump announced reciprocal tariffs on countries across the globe, calculated as responses to their tariffs or unfair trade practices .

President Trump suspended the Liberation Day tariffs for 90 days starting April 9, 2025, with the understanding that the Administration would negotiate trade individual trade deals with countries otherwise subject to tariffs. The suspension on Liberation Day tariffs, however, did not apply to tariffs on Chinese goods, which increased to 145 percent. In retaliation, China imposed 125 percent tariffs on U.S. goods.

On April 15, 2025, Lewis Brisbois published a Legal Alert entitled “Navigating the Trump Administration’s Sweeping Actions on Tariffs.” This Legal Alert provides an overview of key updates since the prior alert's publication.

BIS Steel and Aluminum Inclusions Process

On April 30, 2025, the Bureau of Industry and Security of the United States Department of Commerce ( “BIS”) issued an interim final rule on Adoption and Procedures of the Section 232 Steel and Aluminum Tariff Inclusions Process (the “IFR”). The IFR “establishes the process for including additional derivative aluminum and steel articles within the scope of the ad valorem duties authorized by the President under Section 232 of the Trade Expansion Act of 1962, as amended (Section 232).” Specifically, BIS will open three submissions windows of two weeks each to receive aluminum and steel derivative inclusion requests and, after consideration and public comments, will make a positive or negative determination concerning each request. Comments on the IFR itself (not the later submissions) are due by June 16, 2025.

Potential Foreign Film Tariffs

On May 4, 2025, Trump posted on Truth Social that he was “authorizing the Department of Commerce, and the United States Trade Representative, to immediately begin the process of instituting a 100% Tariff on any and all Movies coming into our Country that are produced in Foreign Lands.” President Trump’s rationale for this proposed set of tariffs—Trump has not issued an executive order yet—is that the United States film industry is suffering and that foreign nations threaten the United States with propaganda films. It is unclear what methodology would apply in implementing the new tariff, e.g., if based on revenues, how could that be determined at the time of “import”?

UK Trade Deal

On May 8, 2025, President Trump announced the US-UK Economic Prosperity Deal (the “EPD”). Among other things, the EPD will allow U.S. imports of up to 100,000 UK-made automobiles at a 10 percent tariff rate. The UK will remove its 20 percent tariff on U.S. beef and implement a preferential duty-free quota of 13,000 metric tons of U.S. beef, in exchange for the U.S. reallocating 13,000 metric tons of its “other countries” tariff rate quota for beef. The UK will also offer a preferential duty-free tariff rate quota for 1.4 billion liters of U.S. ethanol. The UK will be required to meet U.S. requirements on steel and aluminum supply chains where products are exported to the U.S., and, if the UK meets such requirements, it will receive a quota at most favored nations rates for UK steel and aluminum, as well as certain derivative products.

China’s Temporary Trade Deal

Perhaps most significantly, on March 12, 2025, President Trump announced a trade deal with China and issued an executive order entitled “Modifying Reciprocal Tariff Rates to Reflect Discussions with the People’s Republic Of China” (the “China Tariff Order”). Among other things, the U.S. will remove tariffs it imposed on April 8 and 9 against China, but will leave in place duties imposed prior to April 2, 2025, including tariffs imposed pursuant to sections 301 of the Trade Act, section 232 of the Trade Expansion Act, most favored nations tariffs, and tariffs imposed under the International Emergency Economic Powers Act concerning the fentanyl national emergency. In return, China will remove the retaliatory tariffs and suspend or remove the non-tariff countermeasures taken against the U.S. since April 2, 2025. Additionally, both China and the U.S. will suspend their 34 percent tariffs for a 90-day period, but retain reciprocal 10 percent tariffs during the suspension period.

Key Takeaways

The tariff landscape is rapidly changing. Liberation Day tariffs that were suspended are set to take effect in July. In the coming weeks, U.S. businesses can expect to see additional trade deals—both permanent and temporary—between the United States and key trade partners. While some of these tariffs are being imposed without the possibility of exemptions, others allow for standardized opportunities to mitigate the impacts of these measures, and it is clear that some moderation is occurring in response to pushback from affected businesses or sectors.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editors of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.

Author:

Griffen J. Thorne, Partner

Editors:

Andrew Pidgirsky, Partner and Co-Chair of Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice

Jane C. Luxton, Managing Partner - Washington, D.C.

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