In a flurry of recent tariff actions, President Trump paused the reciprocal tariffs for three months, both China and the EU announced measures to counter U.S. tariffs, and three new investigations under section 232 of the Trade Expansion Act of 1962 were formally announced.
Reciprocal Tariffs
President Trump issued an Executive Order on April 9 announcing the U.S. was suspending the country-specific reciprocal tariffs for 90 days for countries that have not retaliated against the U.S. tariffs but leaving the 10% baseline tariffs on all countries in effect in addition to all other duties that might apply (for prior coverage, see the alert dated April 10, 2025). Under the reciprocal tariff policy, some countries are charged only the universal 10% tariff, while others face higher specific reciprocal levies that range from 11% to 49%.
The stated basis for the reprieve on the tariffs was the “reach-out” by 75+ countries (none of which were named by the White House) seeking tariff concessions. Negotiations have begun with several major trading partners as they seek relief from the paused reciprocal tariffs before the July 9 deadline for re-imposition (it has been announced that India and the U.S. have reached agreement on the “terms of reference” for a new trade deal).
The major exceptions to the new reciprocal tariffs are the section 232 “national security” tariffs of 25% on imports of steel and aluminum products, as well as passenger vehicles, light trucks and auto parts, for which the 25% tariffs go into effect no later than May 3. All non-USMCA qualifying imports from Canda and Mexico are also exempt from the reciprocal tariffs given that a 25% IEEPA tariff has been in place since March 4 on products from those two countries.
China is excluded from the 90-day pause altogether. After a series of tariff increases announced by both Washington and Beijing, the final reciprocal tariff rate was raised by President Trump to 145% effective April 9, on top of (1) any existing section 301 tariffs first imposed in 2018; (2) any Normal Trade Relations duties; (3) any antidumping / countervailing duties (based on specific products); and (4) any section 201 “safeguard” tariffs on imports of bifacial solar cells.
In a further development, a Presidential Memorandum issued on April 11 exempted certain semiconductor components, smartphones, laptops, and other electronics (based on their tariff classification code under the Harmonized Tariff Schedule of the United States (HTSUS)) from the 10% universal baseline tariff retroactive to April 5. Specific instructions were issued to U.S. Customs & Border Protection (CBP) to refund any IEEPA tariffs collected during the gap period. (On the same day, CBP released a message confirming the exemptions and providing guidance to importers about declaring the exemptions, as well as actions to take to correct filing entries and requesting refunds.)
It is unclear what will happen after the 90-day period expires while countries negotiate with the Trump administration. If the paused reciprocal tariffs eventually take effect, the Executive Order imposing them states that they “shall apply until such time as [the President] determine[s] that the underlying conditions described above are satisfied, resolved, or mitigated.”
| State of Play of New U.S. Tariffs | |
| Country | Tariff |
| Canada | Exempt from the 10% global tariff Subject to a 25% tariff for non-USMCA-origin goods |
| China | 145% tariff on most goods (in addition to already existing tariffs) Excluded from the 90-day reprieve |
| Mexico | Exempt from the 10% global tariff Subject to a 25% tariff for non-USMCA-origin goods |
| Other countries | 10% universal tariff Country-specific reciprocal tariffs paused for 90 days Temporary exemption for certain semiconductor components, smartphones, laptops, and other electronics 25% duties on steel, aluminum, automobiles, and automotive parts but where these tariffs apply the global and reciprocal tariffs do not apply |
U.S. Trading Partner Responses
Effective April 9, Canada responded to the Trump 25% tariff on autos/auto parts with a 25% counter-tariff on noncompliant USMCA fully-assembled autos imported from the U.S. For USMCA-qualifying autos, the tariff will apply only to the parts that are not of Canadian or Mexican origin. These new retaliatory tariffs are in addition to the tariffs Canada imposed starting on March 4 covering, for example, appliances, wine, bourbon, and orange juice (for prior coverage, see the alert dated March 10, 2025 prepared by BDO in Canada).
The European Commission announced on April 14 that it was suspending EU countermeasures for 90 days in response to President Trump’s decision to pause the reciprocal tariffs for 90 days. EU member states had approved the first set of countermeasures against the U.S. in response to the tariffs imposed on steel and aluminum from the EU on April 9 (which included revisions to the scope of covered products and a re-calibration of the duty rates to a maximum of 25%). A 25% tariff on a broad range of U.S. products would have kicked in on April 15, with a second tranche of products subject to the tariffs a month later. This second list is being finalized during the pause but covers over 1,700 items, including apparel, alcohol, and agricultural products. All EU countermeasures are now suspended until July 14 to allow negotiators time to seek a resolution of the U.S.-EU tariff impasse.
New Section 232 Investigations
In a related development, three new investigations under section 232 of the Trade Expansion Act of 1962 have been announced. Conducted by the Bureau of Industry and Security (BIS) within the Commerce Department, the new investigations cover imports of (1) semiconductors (including downstream products such as smartphones and laptop computers); (2) imports of pharmaceuticals (including finished drug products, medical countermeasures, critical inputs such as active pharmaceutical ingredients, and key starting materials, and derivative products of those items); and (3) imports of processed critical minerals and their derivative products.
The Trade Expansion Act authorizes BIS to examine the impact of these imports on U.S. national security and corresponding economic stability. Although the section 232 investigations must be completed within 270 days of their respective initiation dates, most expect that the final reports recommending options for the president (including tariff and nontariff measures) will be issued sooner. If these investigations follow the path of previous ones, the likely outcome will be to recommend that the president impose new tariffs to counter the damage to U.S. national and economic security caused by these imports.
Importantly, all three investigations are seeking public comments for BIS to consider in making its final recommendations to the president. For instance, the pharmaceutical investigation requests feedback on the following issues no later than May 7:
“(i) the current and projected demand for pharmaceuticals and pharmaceutical ingredients in the United States;
(ii) the extent to which domestic production of pharmaceuticals and pharmaceutical ingredients can meet domestic demand;
(iii) the role of foreign supply chains, particularly of major exporters, in meeting United States demand for pharmaceuticals and pharmaceutical ingredients;
(iv) the concentration of United States imports of pharmaceuticals and pharmaceutical ingredients from a small number of suppliers and the associated risks;
(v) the impact of foreign government subsidies and predatory trade practices on United States pharmaceuticals industry competitiveness;
(vi) the economic impact of artificially suppressed prices of pharmaceuticals and pharmaceutical ingredients due to foreign unfair trade practices and state-sponsored overproduction;
(vii) the potential for export restrictions by foreign nations, including the ability of foreign nations to weaponize their control over pharmaceuticals supplies;
(viii) the feasibility of increasing domestic capacity for pharmaceuticals and pharmaceutical ingredients to reduce import reliance;
(ix) the impact of current trade policies on domestic production of pharmaceuticals and pharmaceutical ingredients, and whether additional measures, including tariffs or quotas, are necessary to protect national security; and
(x) any other factors.”
Comments can be submitted to BIS via the U.S. Government intake portal (www.regulations.gov). For the pharmaceutical investigation, the regulations.gov ID notice number to be referenced in any submission is BIS-2025-0022; comments should also include reference to XRIN 0694-XC120.
BDO Insight
As President Trump continues to ratchet up and then dial down global trade tensions, the actions over the next month will focus on the ongoing negotiations that many countries have requested with the Trump administration. The Director of the National Economic Council recently indicated that 15 countries had made specific offers to the White House and that the administration was setting up a “very orderly process” to prioritize negotiations with certain countries, which he did not identify. President Trump also indicated that certain country-specific exemptions may be possible but did not provide further details.
The overriding question still facing U.S. companies (and nonresident companies, which include many Canadian entities that import into the U.S.) is whether the cost of any new tariffs that might ultimately be paid by the U.S. importer of record can be passed on to U.S. consumers in whole or in part. Canada, Mexico, and China account for more than 40% of all U.S. imports and include motor vehicles, pharmaceuticals, shoes, electronics, lumber, steel and aluminum, and a host of other products ultimately purchased by American retail consumers.
In sum, many view the tariffs as the escalation of an expanding global trade war in which all major trading nations will ultimately become enmeshed. Multinational companies trading in goods should consider mitigation strategies to lessen or eliminate the impact of these significant new tariffs for merchandise imported into the U.S.
How BDO Can Help
The BDO Customs and International Trade team is closely monitoring the rapidly evolving trade landscape relating to the U.S. tariffs (including those now paused) and the retaliatory measures (some now on pause) from the targeted countries.
For further assistance and detailed analysis tailored to your business needs, please contact our team of international trade experts at BDO. We are here to help you assess key vulnerabilities, ensure compliance with new measures, and identify opportunities for tariff relief and supply chain diversification moving forward.
Please visit BDO’s International Tax Services page for more information on how BDO can help.