On April 29, 2025, President Trump signed a new Executive Order that limits the cumulative application or “tariff stacking” of certain U.S. tariffs, reducing duty exposure on targeted imports from Canada and Mexico—including autos, auto parts, aluminum, and steel. The order applies retroactively to all entries made on or after March 4, 2025.
PRODUCTS EXCLUDED FROM TARIFF STACKING
The non-stacking policy applies only to tariffs imposed under the following authorities and related actions:
- Section 232 duties on automobiles and auto parts (Proclamation 10908, March 26, 2025)
- IEEPA-based duties on imports from Canada and Mexico imposed to disrupt illicit drug flows (Executive Orders 14193, 14194, and amendments)
- Section 232 aluminum duties (Proclamation 9704 and amendments)
- Section 232 steel duties (Proclamation 9705 and amendments)
Under the new order, these tariff actions remain independently valid, but when a single article qualifies under more than one of them, the Executive Order restricts how those tariffs may be combined.
KEY TARIFF EXEMPTIONS CLARIFIED
The executive order clarified key tariff exemptions for the following commodities, Section 232 tariffs, and IEEPA related duties:
- Auto and Auto Parts Imports: Shipments subject to Section 232 auto tariffs are now exempt from additional duties under both Canada and Mexico IEEPA border actions and the Section 232 aluminum and steel programs.
- Aluminum and Steel Duties: Tariffs on aluminum and steel may still apply together if a product meets the eligibility criteria for both. In other words, stacking is permitted between these two material-based programs where applicable.
RETROACTIVE TARIFF IMPACT AND OVERPAYMENT REFUNDS
The order applies retroactively to all entries made on or after March 4, 2025. U.S. Customs and Border Protection has been directed to issue refunds under standard procedures for shipments that qualify under the revised duty treatment.
All changes to the Harmonized Tariff Schedule of the United States (HTSUS) are expected by 12:01 a.m. EDT on May 16, 2025.
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