Week Eight in Trade – First 100 Days of the New Administration

This blog post covers trade developments occurring during the eighth week of the new Trump Administration. It covers events occurring through 12:00 pm Eastern time on Friday, March 14.

Ongoing Tariff Developments

On March 4, 2025 and March 7, 2025, U.S. Customs and Border Protection (CBP) implemented five Presidential Executive Orders governing imports from China, Hong Kong, Canada, and Mexico. CBP is now collecting the following additional tariffs on imports from Mexico, Canada, and China under the International Emergency Economic Powers Act: 

• Additional 25% tariffs on goods that do not satisfy U.S.-Mexico-Canada Agreement (USMCA) rules of origin.
• A lower, additional 10% tariff on energy products imported from Canada that fall outside the USMCA preference.

• A lower, additional 10% tariff on potash imported from Canada and Mexico that falls outside the USMCA preference.
• Additional 20% on goods from China and Hong Kong (increased from 10% on March 4).

Effective March 7, 2025, no additional tariffs are due on goods from Canada and Mexico that qualify for the USMCA preference.

In addition, CBP provided specific guidance on imports of aluminum and aluminum derivative Products as well as import duties on imports of steel and steel derivative products. Guidance regarding steel imports follows President Trump’s February 10, 2025 proclamation imposing 25 percent ad valorem tariffs on all imports of steel articles and derivative steel articles from all countries, effective March 12, 2025. Guidance regarding aluminum imports follows President Trump’s February 10, 2025 proclamation imposing a 25 percent import duty on all imports of aluminum articles and derivative aluminum articles from all countries, also effective March 12, 2025.

Tariff Impacts on Cross-Border Logistics

In response to the tariffs announced (and then delayed) by the United States, cross-border trucking operations reported broad impacts to freight movement between the U.S., Canada, and Mexico. Carriers noted that border crossings across Canada and into Mexico experienced delays, at least some of which are due to higher volumes in anticipation of the impending tariffs. Specifically, CH Robinson reported notable increases in customer requests for USMCA qualification for products that may no longer be duty free under the new 25% IEEPA tariffs, considering the White House announcement that USMCA-complaint goods will benefit from a tariff pause. Additionally, some shippers are adopting innovative customs strategies, separating shipments to limit duties owed on tariff-affected materials, adding complexity to cross-border logistics.

President Trump Targets Chinese Containerships

On March 11, 2025, the U.S. government began investigating China’s dominance in the shipbuilding industry. The House Armed Services Subcommittee on Seapower and Projection Forces is holding a hearing on U.S. shipbuilding, with a public hearing by the Office of the United States Trade Representative scheduled for March 24.

In addition to the service fee imposed on port calls by Chinese-made vessels, the USTR report from January recommended that ocean carriers with 50% or more of their orders placed in Chinese shipyards, or those expecting deliveries within the next 24 months, be charged up to $1 million per vessel each time they enter a U.S. port. These fees could be refunded annually, up to $1 million per entry, for vessels that are built in the United States.

The proposals aimed at limiting China’s dominance in shipbuilding include imposing restrictions on U.S. exports. Initially, 1% of all U.S. products exported by vessel must be transported on U.S.-flagged vessels operated by U.S. operators. Over the course of seven years, these restrictions will incrementally increase to require that at least 15% of all U.S. goods be exported on U.S.-flagged vessels operated by U.S. entities, with 5% of these vessels also needing to be U.S.-built.

On Again, Off Again: Tariff Escalations Between Canada and the United States

After a 24-hour back and forth, President Donald Trump announced late on Tuesday evening, March 11, 2025, that the U.S. would not impose an escalated 50% tariff on Canadian steel and aluminum Tuesday.  This announcement was made after the Government of Ontario also backed down and called off its efforts to impose a surcharge on electricity exports to the United States.

Early Monday, March 10, 2025, Ontario announced a potential 25 percent increase in electricity prices for three northern U.S. states, Minnesota, New York and Michigan, only to suspend the threatened surcharge after conversations with the U.S. Commerce Secretary following President Trump’s threats to escalate steel and aluminum tariffs on Canada by 50%.

Specifically, on Monday Ontario threatened to terminate power supply unless President Trump withdrew his tariff threats. The new surcharge of C$10 per megawatt-hour (approximately $7 USD) would result in an additional $100 monthly charge on household bills and could cost each state $400,000 daily. 

In response, President Trump announced today that his administration would raise steel and aluminum tariffs by an additional 25% on Canada due to the threatened electricity surcharge implemented by the Ontario government, marking the latest development in the escalating trade conflict. The total tariff on steel and aluminum imports from Canada is now expected to be 50%.

Following President Trump’s announcement, the Ontario Premier initially reiterated the possibility of completely cutting off electricity to the U.S. and warned he also was prepared to make the export tax even higher.  Later, the Ontario Premier announced that he agreed to suspend the 25% surcharge on electricity imports into the U.S.  A meeting is reportedly scheduled for Thursday, March 13, 2025, to discuss a renewal of the U.S.-Mexico-Canada free trade agreement. 

Commerce Issues Required Certification; Section 232 Tariffs Now in Effect for All New Derivative Products

As previously reported, on February 10, 2025, President Trump issued Proclamations 10895 and 10896, making significant changes to the existing measures imposed on imports of aluminum and steel on national security grounds pursuant to Section 232 of the Trade Expansion Act of 1962.  Among other changes, the Proclamations added to the list of so-called “derivative” downstream products incorporating aluminum and steel that would be subject to Section 232 duties of 25 percent for all countries except Russia, which would be subject to duties of 200 percent. 

The new derivative products covered by the February 10 Proclamations are listed in the Annexes to Proclamation 10895 (for aluminum) and 10896 (for steel).  The February 10 Proclamations stated that merchandise listed in the Annexes classified under Chapter 73 (for steel) and Chapter 76 (for aluminum) would be subject to duties beginning on March 12, 2025.  The Proclamations further stated that derivatives classified outside of Chapters 73 and 76 would be subject to the additional duties on the date that the Secretary of Commerce certified that adequate systems are in place to fully, efficiently, and expediently process and collect tariff revenue for covered articles.

On March 11, 2025, U.S. Secretary of Commerce Howard Lutnick submitted the required certification for publication in the Federal Register.  Later in the evening of March 11, CBP issued updated Cargo Systems Messaging Service guidance previously issued on March 7 for both steel and aluminum to confirm that all derivatives, including those classified outside of chapter 76, would go into effect for entries made on or after 12:01 AM on March 12, 2025. At this time, CBP has not provided any guidance on the specific method to be used to declare a value for the aluminum or steel content for affected derivative products. 

New Retaliatory Canadian Tariffs

Following President Trump’s imposition of a 25% tariff on steel and aluminum products from various countries, including Canada, on March 12, the Canadian government announced its countermeasures. Effective today, March 13, these measures impose additional surtaxes targeting CAD $29.8 billion worth of goods originating from the United States.

The tariffs are designed to be reciprocal, targeting CAD $29.8 billion worth of imports from the United States. This amount is approximately equal to the value of steel and aluminum products affected by U.S. tariffs, with the surtaxes distributed among various categories as follows: steel (CAD $12.6 billion), aluminum (CAD $3 billion), and additional U.S. Goods (CAD $14.2 billion). The surtaxes are part of a larger plan for CAD $125 billion in retaliatory tariffs that Canada is reportedly preparing to implement.

EU Announces Countermeasures in Response to US Tariffs on Steel and Aluminum

The European Commission announced countermeasures to address the impact on EU businesses and consumers in response to the US reinstating 25% tariffs on steel imports and increase of the existing 10% tariff on aluminum imports to 25%, while extending these tariffs to additional steel and aluminum products on March 12, 2025. These countermeasures will be implemented in two stages, starting with renewing the countermeasures imposed in 2018 and 2020 (previously suspended). These measures, which include tariffs ranging from 4.4% to 50% on certain US products, will come into force on April 1, 2025. To determine whether their supply chains will be affected, companies should review the list of US products subject to the 2018 countermeasures in Regulation (EU) 2018/886, and the list of US products subject to the 2020 countermeasures in Regulation (EU) 2020/502.

For the second stage, the European Commission will propose a new package of countermeasures on US products, which the commission reportedly will implement on or about April 13, 2025. Companies should review the list of US products potentially subject to these new countermeasures (available here) and participate in the Commission’s consultation process, which is open until March 26, 2025 (information on that process is available here). This process allows potentially affected parties to provide input, which will be considered before the new package is adopted.

In parallel, the European Commission remains open to a negotiated solution with the US. European Commissioner for Trade, Maroš Šefčovič, emphasized the Commission’s willingness to engage constructively to reach an agreement that could lead to the suspension of the US tariffs and the EU countermeasures. However, companies should prepare for the upcoming changes by verifying the classification and origin of their products according to EU regulations and participate in the consultation process described above.