The Clean Tech Tariff Tracker
February -> March 2025
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Last month I said there would be time to dig into tariffs. Well the time is now! Over the past several weeks, the White House has announced and teased a slew of new tariffs with major ramifications for the energy sector. Between the acronym and number soup (IEEPA, 232, 301, AD/CVD, etc.) and what’s been threatened, withdrawn, enacted, and hit with retaliatory tariffs by our trading partners, it’s easy to get confused.
That’s why we’re publishing a tariff tracker that we’ll update regularly to make sure you have a one stop shop to make sense of how tariffs can impact the energy sector. Our hope is that this can be a living document that you can bookmark and keep coming back to as needed.
What we’re covering:
Tariffs announced and threatened by the Trump Administration that have a direct impact on energy markets. Steel and aluminum? You bet. Economy-wide tariffs on our trading partners? Absolutely.
Tariffs stack like building blocks, so we’re also including the trade actions taken by the Biden Administration that are still in place - particularly those that heavily impacted the energy sector, such as last year’s Section 301 actions that increased tariffs on a cross section of Chinese clean tech imports like solar, batteries and minerals.
Other trade restrictions like the Uyghur Forced Labor Prevention Act (UFLPA), which has been used to block imports of Chinese products - including critical minerals and polysilicon used in solar panels - that are at risk of being tainted by forced labor.
What we’re not covering:
Tariffs that don’t have a direct impact on energy markets ( 👋 Hi softwood lumber!).
Where you come in: Hit us up if we’re missing something! There’s a lot to cover here, so if you see a gap, let us know!
Government Financing Update: We’re taking a pause on the Financing Report this month as the Trump Administration is getting up to speed and has not announced major new investments or opportunities.
The DC CleanTech Tariff Tracker
Tariffs and Trade Restrictions in Effect
Updated April 12, 2025
🌎 Country: Global “reciprocal” tariffs
📜 Legal Authority: The White House Executive Order cited the International Emergency Economic Powers Act (IEEPA)
📆 Date of Entry into Force: April 5 - April 10
📈Tariff Rate: 10% to nearly all trading partners on almost all imported goods, starting Saturday April 5. Reciprocal tariffs that were slated to start April 9 for 60 named countries based on the U.S. trade deficit and the dollar value of U.S. imports from that country were delayed for 90 days. These tariffs would range from 11% to 50% and are not in addition to the 10% baseline applied to nearly all countries. On April 8, President Trump announced an additional 50% tariff on Chinese imports in response to China’s retaliatory 34% tariff on U.S. imports, and on April 9 the White House announced a 125% tariff on Chinese imports in response to China’s further retaliatory tariffs on U.S. goods.
Analysis
These new tariffs are generally additive to existing tariffs, such as Section 301 tariffs and the Trump IEEPA tariffs targeting China for its role in the fentanyl crisis. For example, the import of a Chinese wind turbine hub would be subject to a 25% 301 tariff, a 20% IEEPA/Fentanyl tariff, a 34% reciprocal tariff, and a 91% “retaliatory” tariff, plus the standard Most Favored Nation tariff rate (which varies by country and product, generally between 1-10%). That amounts to at least a 170% tariff on key wind turbine imports from China.
Legal durability: On April 3, a lawsuit was filed arguing that tariffs are not a policy tool granted to the President under IEEPA.
Exceptions
The tariffs do not apply to Canada or Mexico, which have already been targeted with tariffs of 25% for all imports that do not meet USMCA rules of origin standards
For imports that include U.S. content, the U.S. content is exempt from the new tariffs, as long as it is at least 20% of the value of the imported product.
Products listed in Annex II to the Executive Order, including copper, pharmaceuticals, semiconductors, lumber articles, certain critical minerals, and energy and energy products (including oil, uranium and enriched uranium among others) are also excluded.
🪨For example, some types of battery minerals including cobalt, lithium, nickel, manganese and some tariff lines of natural graphite will not be subject to tariffs.
On April 11, U.S. Customs and Border Protection issued updated guidance exempting smartphones, computer monitors and various electronic parts from the reciprocal tariffs.
The tariffs do not stack on top of existing sector specific tariffs, including products subject to 232 tariffs (steel and aluminum), the recent tariffs on autos and auto parts, and potential new 232 tariffs like those being considered on pharmaceuticals, semiconductors, and copper.
Retaliation:
🇨🇳China has matched U.S. tariffs tit for tat, announcing 125% tariffs against U.S. goods on April 11. China had initially imposed a 34% tariff on all goods imported from the United States, which it increased to an 84% tariff following the Trump Administration’s April 8 imposition of an additional 50% tariff on Chinese imports. Beijing is also implementing export restrictions on 7 types of rare earth elements, placing 16 U.S. entities to its export control list, and adding 11 U.S. firms to its “unreliable entity” list.
🇪🇺The EU has said it was “preparing for further countermeasures to protect our interests and our businesses if negotiations fail”. French President Emmanuel Macron called on French businesses to not invest in the United States until things have been “clarified”. The EU is working on a phased approach to its retaliatory plans, with the first stage aimed at responding to the Trump Administration’s 232 steel and aluminum tariffs, which it announced on April 9. Subsequent stages will address the auto tariffs and the 20% across the board tariffs, with a formal proposal by the Commission expected by mid-May if a negotiated settlement with the United States is not reached.
Updated May 5, 2025
🇨🇦 Country: Canada
📜 Legal Authority: The White House announcement cited IEEPA
📆 Date of Entry into Force: March 4 - March 6
📈Tariff Rate: 25%, except for energy products and potash, which are tariffed at 10%
Analysis: From March 7 - April 2 the tariffs will only apply to goods that are not U.S.-Mexico-Canada (USMCA) Free Trade Agreement compliant. After April 2, the White House has threatened to broaden the tariffs to all imports.
USMCA only covers about 38% of goods from Canada. Notably, a significant portion of the automotive industry is not covered under USMCA and trades under the most favored nation import tariff of 2.5% because many of those goods do not satisfy the USMCA “rules of origin” - a standard requiring that goods made up of parts from several countries contain at least 75% North American content. Some imports likely could meet USMCA rules of origin, but companies haven’t subjected themselves to being qualified because there was no substantial penalty for not doing so. Under the March 6 actions, those imports would be assessed an additional 25% tariff.
According to a White House official, not all Canadian energy exports to the United States comply with USMCA and will therefore be hit with a 10% tariff. Canada is a major exporter of uranium to the United States. Canada also exports electricity to the Midwest and Northeast United States, and crude oil which is refined in the Midwest. This could cause energy costs to rise in those regions, adding to already higher prices sparked by increasing demand driven by an uptick in manufacturing and data center load.
On April 29 President Trump signed an Executive Order that clarified that these tariffs do not stack with the 232 tariffs on imports of autos and auto parts.
Retaliation: The tariffs risk sparking a trade war with one of America’s biggest trading partners. Canada responded with retaliatory 25% tariffs on $21 billion of U.S. exports, including orange juice, peanut butter, coffee, appliances, footwear, cosmetics, motorcycles and certain pulp and paper products.
The province of Ontario threatened a 25% retaliatory tariff on the energy it exports to the United States, costing businesses and residents in Michigan, Minnesota, and New York up to $400,000 per day, but later backed down. Quebec is considering taking similar measures, which could raise power prices further across the northeast United States.
Canada has threatened a further $87 billion in tariffs in three weeks on American products like electric vehicles, fruits and vegetables, diary, beef, pork, electronics, steel and trucks.
🇲🇽 Country: Mexico
📜 Legal Authority: The White House announcement cited the International Emergency Economic Powers Act (IEEPA)
📆 Date of Entry into Force: March 7
📈Tariff Rate: 25%, except potash, which is tariffed at 10%
Analysis: The tariffs risk sparking a trade war with one of America’s biggest trading partners, which will likely have consequences across the broader economy.
From March 7 - April 2 the tariffs will only apply to goods that are not U.S.-Mexico-Canada (USMCA) Free Trade Agreement compliant. After April 2, the White House has threatened to broaden the tariffs to all imports.
USMCA only covers about 50% of goods from Mexico. According to a White House official, not all Mexican energy exports to the United States comply with USMCA and will therefore be hit with a 10% tariff. Mexico exports crude oil to the United States where it is processed at the Deer Park refinery in Texas. The import of that Mexican crude would be hit with a 25% tariff.
On April 29 President Trump signed an Executive Order that clarified that these tariffs do not stack with the 232 tariffs on imports of autos and auto parts.
Retaliation: Mexico threatened to retaliate with major tariff actions prior to President Trump walked back his initial promise to tariff all Mexican imports instead of those not covered by USMCA.
🇨🇳 Country: China
📜 Legal Authority: The White House announcement cited the International Emergency Economic Powers Act (IEEPA)
📆 Date of Entry into Force: February 4
📈Tariff Rate: 20% (a 10% tariff was announced on February 4, 2025, and an additional 10% on March 4, 2025)
Analysis: The tariffs risk sparking a trade war with one of America’s biggest trading partners, which will likely have consequences across the broader economy.
China dominates the production of LFP batteries used for stationary and grid storage, as well as the markets for several critical mineral supply chains used in clean energy technologies. Prices for those technologies could increase as a result of the tariffs. Remember, these tariffs stack, so the 20% tariff will be added to the 301 Tariffs (covered below). For an EV battery that means a 70% tariff (50% under Section 301 + 20% under this IEEPA action). Domestic producers of critical minerals and solar products will likely celebrate the news, while the domestic deployment sector will be burdened by higher prices.
While China is a major solar producer, the United States imports most of its solar panels from Cambodia, Malaysia, Thailand, and Vietnam.
Retaliation: Following the February 4 announcement, China responded by leveling 15% tariffs on U.S. LNG and coal and a 10% tariff on crude oil, large cars, and pickup trucks. After the March 4 salvo, Beijing added 10- 15% tariffs against U.S. agricultural products and tightened trade restrictions on U.S. companies. China specifically listed tungsten, tellurium, bismuth, molybdenum, and indium, as well as the technologies and information related to processing and producing them. These minerals are considered critical in industrial and defense applications, solar cell manufacturing, and the semiconductor industry.
Additionally, global market participants from the EV and industrial sector report that China has weaponized its dominant position in critical mineral markets by halting global exports of graphite dating back to February, shortly after the first 10% tariff was announced. China instituted export controls on graphite in 2023, and tightend them in December 2024, but exports had continued to flow until February, 2025.
Updated April 9, 2025
🌎 Country: Global tariffs on Steel and steel derivative products and aluminum and aluminum derivative products.
📜 Legal Authority: The Federal Register Notice (FRN) cited Section 232 of the Trade Expansion Act of 1962, as amended
📆 Date of Entry into Force: March 12
📈Tariff Rate: 25%
Analysis:
Steel: For certain derivative products the tariff does not apply if the steel is melted and poured in the United States. For certain derivative products, the tariff only applies to the value of the steel content in the article. For other derivative products (covered in 169 tariff lines listed in the Annex of the FRN) the entire 25% tariff will be applied. These include the following items used in the energy sector:
Electrical transmission towers
Windmill towers and monopiles
Steel doors for offshore wind turbines
Pressure containers used in the oil and gas sector
Parts of overhead cranes used in the oil and gas sector
This action will also raise the price of steel generally, as tariffed imports raise costs and demand increases for limited domestic steel supply.
Aluminum: For certain derivative products the tariff does not apply if the aluminum is smelted and casted in the United States. For other derivative products (covered in 124 tariff lines listed in the Annex of the FRN) the entire 25% tariff will be applied.
Aluminum foils used in lithium-ion battery manufacturing will be impacted, as will solar panel mounts, which are covered in the tariffs for derivative products. This action will raise the price of aluminum generally, as tariffed imports raise costs and demand increases for limited domestic products.
On April 29 President Trump signed an Executive Order that clarified that the steel and aluminum tariffs under Section 232 do not stack with the 232 tariffs on imports of autos and auto parts. The EOs also clarified that a product that is subject to 232 steel tariffs would also be subject to the 232 aluminum tariffs, so long as the good in question meets all necessary conditions to have tariffs applied under both.
Retaliation:
🇨🇦 On March 12, 2025 Canada announced retaliatory tariffs of 25% on $20 billion of U.S. imports, including computers, sports equipment, and cast iron products, effective on March 13, 2025.
🇪🇺On April 9, 2025 the EU approved a $24.3 billion package of retaliatory tariffs between 10%-25% on a range of U.S. goods, including tobacco, motorcycles, poultry, steel, and aluminum. The tariffs will be phased in over three stages this year. The first set of tariffs will enter into force on 15 April, with most of the duties being applied from 16 May. Import taxes on some other goods, including soybeans and nuts, will kick in on 1 December.
🇨🇳 China has not announced specific actions yet, but has pledged to take “all necessary measures” to protect its interests.
🇨🇳 Country: China
📜 Legal Authority: Section 301 of the Trade Act of 1974, as amended per the Federal Register Notice
📆 Date of Entry into Force: September 27, 2024, with tariffs on semiconductors, lithium-ion non-electrical vehicle batteries, permanent magnets, tungsten, polysilicon, and wafers, and natural graphite increasing in 2025 and 2026.
📈Tariff Rate:
🚗 Electric Vehicles: 100%
🔋Lithium-ion EV batteries: 25%
🔋Lithium-ion batteries for grid and stationary storage, heavy duty transportation and other applications: 25% in 2026
🏭 Steel and aluminum: 25%: Note: These tariffs are assessed on top of the aforementioned 232 steel and aluminum tariffs.
🪨 Natural graphite: 25% in 2026
🪨 Other critical minerals: 25%
☀️Solar cells: 50%
☀️Solar wafers and polysilicon: 50% effective January 1, 2025
🪨 Tungsten: 25% effective January 1, 2025
📡 Semiconductors: 50% effective January 1, 2025
Analysis: In 2024, the Biden Administration added to the first Trump Administration’s 301 tariffs on China, with a major focus on clean tech imports, including for EVs, solar cells, lithium ion batteries, and critical minerals. The Biden Administration sought to balance supporting the domestic clean tech manufacturing sector, which it hoped would make use of Inflation Reduction Act tax credits, and the domestic clean energy deployment sector, which relies on cheap inputs from China. That explains the Administration’s decision to postpone tariffs on graphite and lithium-ion batteries used for grid and stationary storage after U.S. importers advocated for these delays arguing there were insufficient ex-China supplies available to meet demand.
EV imports from China are essentially non-existent, and the Biden Administration’s 100% tariff on Chinese EVs (which the Trump IEEPA 20% tariffs pile on top of) will ensure that remains to be the case. The biggest risk to the clean tech deployment sector is around lithium-ion batteries for stationary storage. The Biden 301 tariffs do not enter into force until 2026 for those products, but President Trump could move the implementation date forward. Despite (or perhaps because of the delay in tariffs) there is not yet sufficient ex-China supply to meet demand.
President Trump has ordered the USTR to review the Biden Administration’s 301 tariff actions and provide recommendations for any additional actions by April 1, 2025.
Retaliation: In 2024, China banned the exports of critical minerals gallium, germanium and antimony to the United States. In response to the first-term Trump 301 tariffs, China leveled tariffs against thousands of U.S. products ranging from 5-25% and including agricultural goods, coal, fuel, buses, medical equipment, machinery, textiles, and chemicals.
🇨🇳 Country: China
📜 Legal Authority: Section 201 of the Trade Act of 1974, per the Biden White House Fact Sheet
📆 Date of Entry into Force: May 2024
📈Tariff Rate: 15%
☀️ Bifacial solar panels are now tariffed at 15% under section 201. Note: This tariff stacks with the China 301 and IEEPA actions.
Analysis: The first Trump Administration imposed 201 tariffs on imported solar panels but the U.S. Court of International Trade later reinstated an exclusion of bifacial solar modules from those tariffs. The Biden Administration ended the bifacial exemption in May 2024, reinstating a 15% tariff on imported bifacial panels.
At the same time, the Biden Administration raised the tariff-rate quota (TRQ) on solar cells from China, increasing the availability of cells used by U.S. domestic panel producers, given the lack of domestically sourced alternatives.
🇨🇳 Country: China
📜 Legal Authority: Enforcement of Circumvention of Antidumping and Countervailing Duties (AD/CVD) on Solar Cells and Modules from China
📆 Date of Entry into Force: June 2024
📈AD/CVD Rates: Anywhere from 15.24%-238.95% depending on the company.
Analysis: The U.S. Department of Commerce and U.S. International Trade Commission (ITC) found that certain Chinese producers were shipping their solar products through Cambodia, Malaysia, Thailand, and/or Vietnam for minor processing in an attempt to avoid paying antidumping and countervailing duties (AD/CVD) that had been assessed on Chinese solar exports to the United States in 2015.
Given the high solar prices (due in part to covid supply chain issues) and the lack of sufficient domestic manufacturing, in June 2022 the Biden Administration announced a solar “bridge” where the anti-circumvention duties would not be enforced until June, 2024.
The ultimate impact of this action was relatively minor. Affected companies had been relocating their supply chains to produce non-circumventing solar products by the time enforcement took effect in 2024.
Updated May 5, 2025
🇰🇭🇲🇾🇹🇭🇻🇳 Countries: Cambodia, Malaysia, Thailand and Vietnam
📜 Legal Authority: Petition by U.S. Companies for an AD/CVD investigation into Crystalline PV Cells, whether or not assembled into modules
📆 Date of Entry into Force: On April 21, 2025 Commerce announced its final affirmative determination in the AD/CVD investigation. The ITC will issue its final determination on June 2, 2025 as to whether the domestic industry has been harmed by dumped or subsidized imports. It is expected that the ITC will reach an affirmative determination. When it does, the issuance of orders to collect duties will take place on June 9, 2025.
📈AD/CVD Rates: Final CVD rates range from de 14.64% to 3,404%, depending on the company and country. The large Chinese headquartered companies received relatively heavy CVD rates including:
38.38%, Jinko Malaysia
263.74%, Trina Solar Thailand
68.15%, JA Solar Vietnam
230%, Boviet Solar Technology Vietnam
Final AD rates range from 0% to 271% depending on the company and country. Only Hanwha Q Cells Malaysia received a 0% dumping margin. Major Chinese headquartered solar companies received relatively high dumping margins (except for Jinko Malaysia, which only received an 8.59% dumping margin) including:
111.45%, Trina Thailand
58.07%, JA Solar Vietnam
82.65%, Boviet Solar Technology Vietnam
82.65, Trina Solar Vietnam
Analysis: Unlike the anti-circumvention investigation against Chinese companies, these petitioners allege direct dumping and illegal subsidization of solar exports to the United States in the four Southeast Asian countries.
AD/CVD investigations follow a strict schedule to determine if U.S. industry is harmed by dumping (AD) or illegal subsidization (CVD) and are generally shielded from political interference. Duties are assessed against imports commensurate with the rate of illegal dumping or subsidization uncovered during the investigation. Duties can be assigned from the point of the issuance of the preliminary determination.
Petitioners (or indeed any interested party) can file an Administrative Review after one year from the issuance of the order which would recalculate the dumping and countervailing duties and adjust them up or down depending on the behavior of the companies and countries in scope of the investigation. Those duties would then be applied retroactively - for up to a year or more back - with the importer paying for any increase of duties (with interest). Importers therefore have essentially unlimited risk for duties on imports from companies within scope of an investigation, making the AD/CVD a powerful tool for domestic manufacturers.
🇨🇳 Country: China
📜 Legal Authority: Uyghur Forced Labor Prevention Act (UFLPA)
📆 Key Dates: On June 21, 2022 the Department of Homeland Security (DHS) published the UFLPA Entity List, barring listed companies from China from exporting goods to the United States. Since then, the Entity List has been updated several times, adding dozens more companies.
Analysis: The UFLPA bars imports to the United States of goods made wholly or in part with supply chains tainted by forced labor. According to the law, any good made wholly or in part in the Xinjiang Uyghur Autonomous Region is subject to a rebuttable presumption of being tainted by forced labor due to the prevalence of forced labor against the Uyghur population there. Xinjiang is a major hub of Chinese solar, coal, mining, automotive supply chains. Many solar importers have adjusted to comply with the UFLPA, but new additions to the entity list and to the list of sectors for high priority enforcement could impact solar, critical mineral, and storage imports once again.
UFLPA entity list designations are determined by officials at the DHS, the U.S. Customs and Border Protection (CBP), and the State Department, among other departments and agencies, and may be subject to political pressure under the Trump Administration. While in the Senate, Trump Administration Secretary of State Marco Rubio called for stricter enforcement of the UFLPA to include adding battery companies CATL and Gotion, which could affect battery storage prices and attachment rates.
Updated May 5, 2025
🌎 Country: Global tariffs on automobiles and automobile parts
📜 Legal Authority: Section 232 of the Trade Expansion Act of 1962, per the White House Proclamation
📆 Date of Entry into Force: April 3, 2025 for automobiles, and no later than May 3, 2025 for auto parts, except for USMCA-compliant imports, which will face tariffs once Commerce establishes a process to apply tariffs to their non-U.S. content.
📈Tariff Rate: 25%
Analysis:
🚗 Applies to imported passenger vehicles, light trucks and automobile parts (engines, transmissions, powertrain parts, and electrical components which enumerated in the Annex to the Federal Register Notice). For the EV sector, this includes EV batteries and battery cells.
🇨🇦 🇲🇽 Importers under USMCA can certify their U.S. content so that the 25% tariff only applies to the value of their non-U.S. content. The White House will allow USMCA-compliant automobile parts to remain tariff-free until the Secretary of Commerce establishes a process to apply tariffs to their non-U.S. content.
🇨🇳 While the auto tariffs don’t stack with the reciprocal tariffs, IEEPA/Fentanyl tariffs placed on Canada and Mexico, or 232 tariffs on steel and aluminum, they do stack with the 301 and IEEPA/Fentanyl tariffs placed on China. That means U.S. imports of EV batteries and cells imported from China will be tariffed at nearly an 80% rate (25% 232 auto part tariff + 25% 301 tariff +20% IEEPA/Fentanyl + ~7.5% MFN). It’s worth noting that China is our largest supplier for EV batteries, representing 65% of the nearly $4 billion in shipments to the United States in 2024.
💰Car prices could rise by thousands of dollars, particularly after existing inventories are exhausted. Roughly half of all vehicles sold in the United States are imported, as are nearly 60% of the parts in vehicles assembled in the United States.
🚗 For the EV sector, the move may ultimately benefit Tesla, which manufactures its vehicles for sale in the U.S. domestically, vis-a-vis its competitors like GM and Ford, which manufacture EVs in Mexico.
📅 By June 24, 2025 the Secretary of Commerce will establish a process for including additional auto parts for tariffs.
Partial Tariff Relief Announced:
On April 29, 2025 the White House issued the Executive Order “Amendments to Adjusting Imports of Automobiles and Automobile Parts into the United States, that allows automakers to qualify for tariff relief for a proportion of the cost of their imported components that are used for vehicles manufactured in the United States, though those benefits will be phased out over the next two years. Under the EO, manufacturers will be eligible to apply for offsets to the Section 232 tariff in the amount of (1) 3.75 percent of the aggregate manufacturer’s suggested retail price value of all automobiles they assemble in the U.S. from April 3, 2025, through April 30, 2026, and (2) 2.5 percent of the aggregate MSRP value of all automobiles they assemble in the U.S. from May 1, 2026, through April 30, 2027.
Retaliation:
🇨🇦 Canada responded with a 25% import tariff on vehicles imported from the United States
🇪🇺 The EU is working on a phased approach to its retaliatory plans, with the first stage aimed at responding to the Trump Administration’s 232 steel and aluminum tariffs. Subsequent stages will address the auto tariffs and the 20% across the board tariffs.
Updated May 5, 2025
🇨🇳 Country and Sector: China Maritime Sector Tariffs
📜 Legal Authority: Section 301
📆 Key Dates: Requests to appear at the hearing on proposed tariff actions are due by May 8, 2025. The hearing will take place on May 19, 2025. The deadline to submit comments is May 19, 2025.
📈Tariff Rate: Chinese vessel operators and owners and vessel operators Chinese built vessels will soon incur a service fee that increases over five phases:
From April 17-October 13, 2025: $0
From October 14-April 16, 2026: $50/net ton service fee on vessel operators and owners of China; Service fee of either $18 per net ton for the arriving vessel or $120 for each container discharged for vessel operators of Chinese built vessels
From April 17, 2026-April 16, 2027: $80/net ton service fee on vessel operators and owners of China; Service fee of either $23 per net ton for the arriving vessel or $153 for each container discharged for vessel operators of Chinese built vessels
From April 17, 2027-April 16, 2028: $110/net ton service fee on vessel operators and owners of China; Service fee of either $28 per net ton for the arriving vessel or $195 for each container discharged for vessel operators of Chinese built vessels
From April 17, 2028 - onwards: $140/net ton service fee on vessel operators and owners of China; Service fee of either $33 per net ton for the arriving vessel or $250 for each container discharged for vessel operators of Chinese built vessels
Liquified Natural Gas carriers: the USTR will also require that a certain percentage of liquified natural gas (LNG) exports to the United States be transported exclusively on U.S. vessels, but this requirement does not begin until April 17, 2028 (see Annex IV). The requirement starts at 1% but gradually increases to 15% by April 17, 2047.
Public Comment on Ship to Shore (STS) Cranes and Cargo Handling Equipment: Per Executive Order 14269 of April 9, 2025 (“Restoring America’s Maritime Dominance”), the Federal Register notice proposes additional duties on STS cranes and cargo handling equipment of China to 100%. For all these proposed tariff actions, the USTR is requesting public comments from interested parties.
Tariffs Proposed and AD/CVD Investigations Initiated
🇨🇳 Country: China
📜 Legal Authority: Petition by U.S. Companies for an AD/CVD investigation into graphite Active Anode Material from China
📆 Key Dates: On January 8, Commerce announced the initiation of the AD/CVD investigation of Active Anode Material from China. On January 31, 2025 the ITC voted to continue its investigation, ruling that the establishment of a domestic industry “is materially retarded by reason of imports of active anode material from China” that is sold in the United States at a less than fair value and subsidized by the government of China.
📈AD/CVD Rates: Commerce initiated the case with a prospective dumping margin of 823%-915%.
Analysis: Active anode material is a critical component in lithium-ion batteries. China dominates global production, controlling 100% of some processing supply chains. The CVD preliminary determination is expected on May 20, 2025, and the AD preliminary determination could come as early as May, but the deadline will likely be extended until July.
🌎 Country: Global tariffs on copper imports
📜 Legal Authority: Section 232
📆 Date of Entry into Force: Unclear, but During his speech to Congress on March 5, 2025, President Trump signaled that he had already decided to level a 25% tariff on copper imports, though no official action has been announced. The deadline for Commerce to complete investigation is December 5 (could be completed prior to that date); if Commerce makes an affirmative finding, the President will determine whether he concurs and if so, take remedial action 90 days after the competition of the investigation.
📈Tariff Rate: Likely 25%
Analysis:
The tariffs would cover all forms of copper, including mined copper, copper concentrates, refined copper, copper alloys, scrap copper, and derivative product.
On February 25, 2025, President Trump signed an executive order directing Commerce to launch an investigation into how copper imports threaten America’s security and economy.
On March 13, Commerce published a request for comments from stakeholders related to the copper investigation. Responses are due April 1.
Copper is a critical mineral used in EVs, lithium-ion batteries, power generation technologies, electricity transmission and distribution, and in the oil and gas extraction sector. Tariffs on copper risk making the production of electricity and extraction of energy more expensive.
🌎 Country and Sector: Global: National Security Investigation of Imports of Processed Critical Minerals and Derivative Products
📜 Legal Authority: Section 232
📆 Key Dates: Deadline to submit comments is May 16; Commerce Department 232 Report is due to the President by October 19, 2025.
📈Tariff Rate: TBD
Analysis: On April 15, 2025, the President issued Executive Order 14272, Ensuring National Security and Economic Resilience through Section 232 Actions on Processed Critical Minerals and Derivative Products, instructing the Secretary of Commerce to initiate an investigation under Section 232 to determine the effects on national security of imports of processed critical minerals and derivative products. On April 22, 2025, the Secretary of Commerce initiated the Section 232 investigation. The scope of the investigation covers all 50 critical minerals on the USGS list, as well as uranium, and the derivative products of those minerals.
232 Investigations generally result in long, dense reports following hundreds, and in some cases many thousands of public comments. Commerce is now essentially responsible for 51 232 reports, 1 for each critical mineral. These reports must also cover potentially thousands of derivative products. And this is only one of 6 current 232 investigations Commerce is in the process of undertaking. While Commerce will benefit from previous 232 reports on similar topics (2019 report on uranium, 2018 report on aluminum, 2021 report on Vanadium, 2022 report on Neodymium-Iron-Boron Permanent Magnets, etc), this is still an immense workload and one that will be further complicated by the massive federal staffing reductions. For example, Commerce may not be able to rely on support from critical minerals experts at the USGS, DOE, and elsewhere as many of those subject matter experts are among the thousands that reportedly opted to take the deferred resignation buyout.
The clean tech sector could be greatly impacted by the outcome. Rare earth elements and other critical minerals are key inputs in EVs, lithium-ion batteries, wind turbines, and other advanced energy applications.
The nuclear sector is also deeply interested in the outcome. Enriched uranium imports from Russia are already banned (and exceptions to the import restriction will cease in 2028). Adding 232 tariffs on other importers, particularly in Europe and China, would send a strong investment signal to domestic producers.
Updated May 9, 2025
🌎 Country and Sector: Global: National Security Investigation of Imports of Trucks
📜 Legal Authority: Section 232
📆 Key Dates: Deadline to submit comments is May 16
📈Tariff Rate: TBD
Analysis: On April 22, 2025, the Department of Commerce initiated an investigation under Section 232 to determine the effects on the national security of the imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts.
The scope of the investigation covers “medium-duty trucks” (with a gross vehicle weight of more than 10,000 and under 26,001 pounds), “heavy-duty trucks” (with a gross vehicle weight rating of 26,001 pounds or more), and truck parts, including engines and engine parts, transmissions and powertrain parts, and electrical components.
Battery electric, hybrid, and hydrogen fuel cell vehicles and components could be impacted by the outcome of this investigation. Given that lithium ion batteries used in passenger EVs are subject to tariffs resulting from the 232 investigation into automobiles and auto parts, lithium ion batteries for larger commercial and heavy duty vehicles and battery components could be included in the scope of this investigation as well.
According to Global Market Insights, the global electric commercial vehicle market was valued at $72.3 billion in 2024 and is projected to grow to $235.7 billion by 2034, registering a 12.7% CAGR over that time. North America dominates the global electric commercial vehicle market with a share of around 36% and the United States leads the market in the region generating revenue of $26.2 billion in 2024. The last-mile delivery segment, which is largely comprised of medium-duty trucks, is projected to grow fastest at a CAGR of 15% over the next decade.
🇨🇳 Country and Sector: China Foundational Semiconductor Tariffs
📜 Legal Authority: Section 301
📆 Key Dates: Deadline for final action is around December 23 (action could be taken prior to that date).
📈Tariff Rate: TBD
Analysis: This investigation was launched in December 2024 at the tail end of the Biden Administration. According to a USTR statement: “Evidence indicates that China seeks to dominate domestic and global markets in the semiconductor industry and undertakes extensive anticompetitive and non-market means, including setting and pursuing market share targets, to achieve indigenization and self-sufficiency. China’s acts, policies, and practices appear to have and to threaten detrimental impacts on the United States and other economies, undermining the competitiveness of American industry and workers, critical U.S. supply chains, and U.S. economic security”.
