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Tariff Update: Country-Specific Reciprocal Tariffs and Sectoral Tariffs under Section 232 Investigations

by | Jul 10, 2025 | News | 0 comments

From AFOA General Counsel, Olsson Frank Weeda:

A summary of yesterday’s significant trade developments.

Country-Specific Reciprocal Tariff

President Trump issued a social media post on the country-specific reciprocal tariff pause expiration date stating that “all money will be due and payable starting August 1, 2025 – No extensions will be granted.”

No additional country-specific tariff letters were issued; a White House Fact Sheet summarizes the actions taken thus far by the Administration.

President Trump noted to reporters that the U.S. may lower the rates stated in the tariff letters issued yesterday, depending upon offers made by the covered countries during negotiations.

The European Union Letter should be issued within the next two days, according to statements made by President Trump during today’s Cabinet meeting.

U.S. Customs issued operational guidance (CSMS # 65573545 – GUIDANCE: Extending the Modification of the Reciprocal Tariff Rates) advising trade to continue to use provision 9903.01.25 to declare the current 10% duty until August 1, 2025.

Country-Specific Reciprocal Tariff and Stacking

As noted in Monday’s update (below), the letters issued state that the tariff rates are separate from “Sectoral Tariffs.”  No clarity has been issued by the administration regarding this statement. It is unclear whether this language is a simple acknowledgement that under the April 2nd Executive Order, which initially imposed the reciprocal tariffs, all articles and derivatives of steel and aluminum, all automobiles and automotive parts, and all articles that may become subject to duties pursuant to future actions under section 232 of the Trade Expansion Act of 1962 are exempt from reciprocal tariffs (and therefore remain subject to their own “Sectoral Tariff” rates under Section 232), or whether this language instead suggests that the reciprocal tariffs may be stacked on top of (imposed in addition to) Section 232 tariffs imposed on specific commodities once the suspension on the imposition of country-specific reciprocal tariffs ends on August 1.

We note that President Trump’s June 3, 2025 proclamation clarified that where derivative articles of steel or aluminum subject to Section 232 tariffs contain non-steel or aluminum content, reciprocal tariffs do apply, but only to the non-steel or non-aluminum content of derivative product imports alone.  Executive Order issued on April 29, 2025 and U.S. Customs’ operational guidance (CSMS # 65236574), which clarify tariff stacking, do not include reciprocal tariffs. While these exemptions and current policy made be amended, more clarity from the Administration is needed on how Section 232 tariffs interact with reciprocal tariffs once the suspension on country-specific reciprocal tariffs is lifted.

Sectoral Tariffs under Section 232 Investigations Discussed During Today’s Cabinet Meeting

Copper Tariffs: The President indicated an intention to impose a 50% tariff on copper imports. However, no corresponding Executive Order, Proclamation or documentation has been released to date. The specific date for the enforcement of this tariff, moreover, was not disclosed. It is unclear whether copper derivatives will be part of the scope of the tariff action.

Pharmaceuticals Tariffs: The President announced a proposed implementation timeline of 12–18 months for “a very, very high rate,” potentially as high as 200% on all imported drugs.

Additional Duties on BRICS Nations

Brazil, Russia, India, China, and South Africa are expected to receive an additional 10% duty increase, said President Trump. The BRICS grouping issued a public statement criticizing the U.S. tariff policy. The Administration has reiterated this position via social media.

We will continue to circulate an end-of-day summary of significant trade developments throughout the week and share further updates as letters are issued.