EO 14326 country-specific reciprocal tariffs take effect

At 12:01 a.m. eastern daylight time on 7 August 2025, the country-specific reciprocal tariff rates set by Executive Order 14326 of 31 July 2025 took effect for the trading partners enumerated in Annex I, supplanting the 10 per cent reciprocal baseline established by EO 14257 of 2 April 2025 (as amended by EO 14266 of 9 April, EO 14316 of 7 July and EO 14326 of 31 July).¹² Among the Annex I rates: the European Union, Japan and the Republic of Korea at 15 per cent (each tied to a July 2025 framework Joint Statement); the United Kingdom at 10 per cent (under the US-UK Economic Prosperity Deal of 8 May 2025); India at 25 per cent; Switzerland at 39 per cent; Canada at 35 per cent (under the separate IEEPA fentanyl track, not the reciprocal regime).³ Brazil at 50 per cent flows from the separate EO 14323 of 30 July 2025, an IEEPA action not part of EO 14326 Annex I.⁴ The People’s Republic of China is handled separately under a parallel IEEPA stack (EO 14195 fentanyl 20%

• reciprocal 125% from EO 14266 § 2) at a cumulative rate of approximately 145 per cent for covered articles.⁵ EO 14326 invokes IEEPA (50 U.S.C. § 1702(a)(1)(B)), the National Emergencies Act (50 U.S.C. § 1601 et seq.), § 604 of the Trade Act of 1974 (19 U.S.C. § 2483) and 3 U.S.C. § 301.⁶⁷⁸ The 10 per cent baseline under EO 14257 § 2(a), effective since 12:01 a.m. EDT on 5 April 2025, continues for partners not in Annex I; goods listed in EO 14257 Annex II remain outside both schedules.⁹

1. CBP collects the additional duty under HTSUS Chapter 99 subchapter III subheadings activated by Annex III of EO 14326.¹⁰ In-transit cargo loaded onto a vessel at the port of loading and on the final mode of transit before 12:01 a.m. EDT on 7 August 2025, and entered for consumption before a separately specified date, clears at the prior 10 per cent baseline rather than the country-specific rate.¹¹

2. The IEEPA “regulate … importation” authority at 50 U.S.C. § 1702(a)(1)(B) is the contested merits question in V.O.S. Selections, Inc. v. United States, No. 25-1812 (Fed. Cir.), on which the Federal Circuit, sitting en banc, heard oral argument on 31 July 2025; the opinion is pending.¹² The Court of International Trade had ruled on 28 May 2025 (Slip Op. 25-66) that IEEPA does not authorise these tariffs; the Federal Circuit granted an administrative stay on 29 May 2025.¹³¹⁴ If the Federal Circuit affirms, importer refund procedures would proceed under 19 U.S.C. § 1514 (protests) and 19 U.S.C. § 1520 (refunds and errors), conditioned on the scope of any equitable remedy ultimately granted and on the universal-injunction constraints of Trump v. CASA, Inc., 145 S. Ct. 2540 (2025).¹⁵¹⁶

3. The reciprocal duties cumulate with other tariff regimes not covered by EO 14289’s anti-stacking precedence — § 301 China duties under USTR action, EO 14195 China IEEPA fentanyl duties, and MFN column-1 rates all apply on covered Chinese-origin goods alongside the reciprocal component. EO 14289 establishes precedence only among Section 232 auto/parts, EO 14193, EO 14194, and Section 232 steel and aluminum.¹⁷