The United States will drop the additional tariffs placed on China on April 8 and April 9, 2025, but will maintain all tariffs imposed on China prior to April 2, 2025, including Section 301 tariffs, Section 232 tariffs, tariffs imposed in response to the fentanyl national emergency invoked pursuant to the International Emergency Economic Powers Act (20%), and normal MFN HTSUS tariff rates. This represents a large yet modest de-escalation in trade tensions with China, considering there is a new 30% base level tariff imposed since pre-Trump 2025.
The US will suspend its 34% reciprocal tariff imposed on April 2, 2025, for 90 days, but retain a 10% tariff during the 90-day period. The executive order is available here, and a high-level summary is available in the White House fact sheet.
How We Got Here: The April Escalation
To understand the significance of this de-escalation, it helps to know how extreme things had gotten. After the April 2 Liberation Day reciprocal tariff announcement, both the U.S. and China engaged in a rapid series of retaliatory escalations. By April 9, U.S. tariffs on Chinese goods had reached 145% — a level that functioned as a near-total trade embargo. China’s retaliatory tariffs on U.S. goods climbed to 125%. At those rates, normal bilateral trade was effectively impossible. The Geneva talks in May brought both sides back from that brink, and this executive order implements the agreed de-escalation: U.S. tariffs on China drop to 30% (10% reciprocal + 20% fentanyl IEEPA tariff), and China’s tariffs on U.S. goods drop to 10%, both for 90 days while negotiations continue.
What the Current Tariff Stack on China Actually Looks Like
The phrase “maintaining all tariffs imposed prior to April 2” deserves unpacking, because the cumulative rate is significant even after the de-escalation. For most Chinese-origin goods, the effective tariff rate as of this agreement includes the Section 301 tariffs (ranging from 7.5% to 25% depending on the product list), the 20% IEEPA fentanyl tariff, the 10% reciprocal tariff retained during the 90-day suspension period, and the normal MFN column 1 duty. For goods subject to the highest Section 301 rate of 25%, the effective combined rate is therefore approximately 55-60% before accounting for any applicable Section 232 duties on steel, aluminum, or autos. This is still a historically high tariff regime — the de-escalation removed the most extreme escalation layers but left a substantial base in place.
Update: First 90-Day Extension — August 11, 2025
The original 90-day truce was set to expire August 12. Hours before the midnight deadline, President Trump signed an executive order extending the pause for another 90 days through November 10, 2025. The terms remained the same: U.S. tariffs on Chinese goods at 30%, China’s tariffs on U.S. goods at 10%. The extension followed a third round of talks between U.S. and Chinese negotiators in Stockholm in late July, where Chinese officials had signaled a deal was imminent — a claim U.S. officials disputed, saying nothing was final until Trump approved it. The extension was signed right at the wire, in characteristic fashion.
Update: Trump-Xi Summit and One-Year Deal — October 30 / November 1, 2025
On October 30, 2025, President Trump and President Xi Jinping met bilaterally in Busan, South Korea, on the sidelines of the APEC summit. The meeting produced a broader trade and economic agreement announced by the White House on November 1. Key elements of the deal as it affects tariffs:
- Reciprocal tariff suspension extended one year through November 10, 2026. The 10% reciprocal tariff remains in place during this period.
- Fentanyl tariff reduced from 20% to 10% effective November 10, 2025, in exchange for Chinese commitments to halt shipments of fentanyl precursor chemicals to North America.
- China suspends retaliatory tariffs imposed since March 4, 2025, on a broad range of U.S. agricultural products including soybeans, wheat, corn, cotton, pork, beef, and dairy. China’s general tariff rate on U.S. goods drops to 21.9%.
- China suspends rare earth export controls announced in October 2025, issuing general licenses for exports of rare earths, gallium, germanium, antimony, and graphite to U.S. end users.
- Section 301 exclusions extended through November 10, 2026 — the 178 product exclusions that were set to expire November 29, 2025 are extended as part of the deal.
- Agricultural purchase commitments — China commits to purchase at least 12 million metric tons of U.S. soybeans in the last two months of 2025 and 25 million metric tons annually in 2026, 2027, and 2028.
The combined effective tariff rate on most Chinese goods after November 10, 2025 is therefore approximately 45-50% for goods subject to 25% Section 301 tariffs — lower than the pre-deal level but still historically elevated.
Update: Supreme Court Strikes Down IEEPA Tariffs — February 20, 2026
On February 20, 2026, the Supreme Court ruled 6-3 in the consolidated cases of Learning Resources, Inc. v. Trump and V.O.S. Selections v. United States that IEEPA does not authorize the President to impose tariffs. This ruling directly affects the IEEPA-based components of the China tariff stack — both the reciprocal tariff and the fentanyl IEEPA tariff — which were imposed under the emergency powers the Court found to be unauthorized. The Section 301 tariffs and Section 232 tariffs on China are unaffected and remain fully in force.
The practical implications for importers of Chinese goods are still being worked out through the courts. The case has been remanded to the Court of International Trade to address refunds of IEEPA duties collected. If you have been paying IEEPA tariff components on Chinese imports and want to understand your options for refunds, contact us.
China Tariff Questions?
Do you have questions about the China tariffs and how they apply to your imports? Great Lakes Customs Law has been advising importers for more than 15 years. Call us at (734) 855-4999, send a text message, or reach us on WhatsApp.