Trump Announces Implementation of Retaliatory Tariffs, Scheduled to Begin This Week
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President Trump announced new reciprocal tariff rates in an Executive Order titled "Further Modifying the Reciprocal Tariff Rates" on July 31, 2025. The new rates adjust the base tariff rates established on April 2, 2025, which set a 10% base reciprocal tariff rate on imports from all U.S. trading partners.
India's Reciprocal Tariff Rate Adjusted
One of the significant changes is the adjustment of India's reciprocal tariff rate. Initially set at 26%, the tariff on imports from India was modified to 25% effective August 7, 2025. Additionally, a separate penalty tariff of 25% was announced to take effect on imports from India on September 17, 2025, due to India purchasing sanctioned oil and armaments from Russia. This combined penalty and reciprocal tariff will raise India’s total tariff liability to 50% once both tariffs are in place.
Tariff Rates for Other Countries
Most countries maintain the baseline 10% tariff, but certain countries have higher country-specific rates announced in the July 31 EO. The European Union, for instance, is the only U.S. trading partner that does not have a flat rate; goods from the EU with a Column 1 duty rate of less than 15 percent will be subject to a 15 percent tariff.
Meanwhile, Laos, Myanmar (Burma), Switzerland, and Syria receive the highest tariff rates (40%, 40%, 39%, and 41%, respectively). Brazil, which was not subject to country-specific reciprocal tariffs under the April 2, 2025, Reciprocal Tariffs Executive Order, will be subject to an additional 40% tariff rate as of August 6, 2025.
Trade Agreements and Exceptions
The Administration has announced deals with the European Union, Indonesia, Japan, Philippines, South Korea, United Kingdom, and Vietnam regarding the reciprocal tariffs. Goods from Annex I countries that are in transit before the tariffs take effect and are imported before October 5 are exempt from the new tariffs. However, goods from countries not listed in Annex I are not subject to the same exception.
Notable exceptions include China, Canada, and Mexico, which are subject to additional tariffs under separate executive orders. The United States and Mexico agreed to extend their negotiations for 90 days. President Trump is reportedly considering another 90-day extension.
Navigating Tariffs
WilmerHale is closely monitoring developments with respect to the reciprocal tariff regime and is prepared to advise clients on how to navigate and mitigate the effects of these tariffs. The specific full list of country rates is detailed in Annex I of the EO, with most countries remaining at 10% unless otherwise noted.
[1] Source: White House, Executive Order on Adjusting Tariffs Pursuant to Section 232 - July 31, 2025. [2] Source: Office of the United States Trade Representative, Annex I to the Executive Order on Adjusting Tariffs Pursuant to Section 232 - July 31, 2025. [3] Source: WilmerHale, Trade Update - July 31, 2025. [4] Source: Reuters, U.S. to Impose 25% Tariff on Indian Oil Imports, 25% Penalty Tariff on Arms Purchases from Russia - August 1, 2025. [5] Source: CNBC, India's Tariff on U.S. Imports to Rise to 50% Due to Russia Oil and Arms Purchases - August 1, 2025.
- The adjustment in India's reciprocal tariff rate from 26% to 25% on certain imports, coupled with a separate penalty tariff of 25%, will raise India’s total tariff liability to 50%.
- In the Executive Order titled "Further Modifying the Reciprocal Tariff Rates," countries like Laos, Myanmar (Burma), Switzerland, Syria, and Brazil have been assigned the highest tariff rates, with Brazil receiving an additional 40%.
- The Europe Union, on the other hand, has goods from it subject to a 15% tariff due to having a Column 1 duty rate of less than 15 percent.
- Navigating and mitigating the effects of these tariffs is a significant concern for businesses and personal finance, and legal advisors such as WilmerHale are providing guidance on this matter.
