Taxes, Tariffs & Trade

NAFEM informs and represents its members on the complex issues of U.S. taxes, tariffs, and trade, advocating for open and fair policies and rules that maximize market opportunities and cost-effective supply chain sourcing. 

Tariff resources 

While NAFEM regularly updates this resource page, we strongly recommend consulting your customs broker for real-time information specific to your products.  

Understanding the U.S. Tariff Landscape

Updated November 5, 2026 

Trump eases tariffs on Canadian refrigeration equipment  

President Trump modified tariffs on certain Canadian imports under Section 338 of the Tariff Act of 1930, removing some refrigeration equipment and machinery from the list of products subject to additional duties, effective Oct. 30. This follows the additional 50% tariffs imposed on certain Canadian goods Aug. 22 Canada announced counter tariffs of 15, 25 and 50% Sept. 8, with the rate for each product matching the corresponding U.S. rate.  

Russia tariffs delayed under new sanctions law 

President Trump issued an executive order Oct. 16 implementing the Lindsey O. Graham Sanctioning Russia and Iran Act but waived its new tariffs and several sanctions provisions, citing U.S. national interests. The order establishes tariffs of 500% on Russian imports and 100% on imports from certain countries that purchase Russian energy or facilitate sanctions evasion, but the waivers prevent these duties from taking effect. The administration will monitor Russian energy purchases and sanctions evasion to determine whether further action is warranted.  

Court ruling could expand IEEPA refund eligibility; refund status update 

The U.S. Court of International Trade certified a class of importers seeking IEEPA tariff refunds Oct. 8, potentially expanding eligibility to businesses that have not filed individual lawsuits. The ruling does not immediately authorize additional refunds but U.S. Customs and Border Protection (CBP) continues to notify additional qualifying importers of their eligibility to file Phase 3 claims.  

As of Oct. 2, CBP reported sending approximately $126 billion in refunds and interest to the Department of the Treasury for disbursement, although not all funds have reached importers. Missing banking information continues to delay some payments. 

NAFEM members should preserve import records, verify electronic payment information, and consult trade counsel about potential refund claims as litigation continues. Filing guidance is available on the CBP IEEPA Duty Refunds page.  

USMCA negotiations underway

The U.S. Trade Representative (USTR) is seeking public input ahead of the 2027 joint review of the United States – Canada – Mexico Agreement (USMCA). USTR is accepting public comments and requests to testify through Jan. 12, 2027. A majority of NAFEM members responding to the 2026 business challenges survey identified trade with Canada and Mexico under the agreement as important to their businesses. Members interested in helping shape potential comments should email advocacy@nafem.org by Nov. 30. 

In July, the U.S. declined to renew the USMCA in its current form. The agreement remains in effect as negotiations continue, including its preferential tariff rules, but the three countries will enter annual joint reviews until an agreement on renewal is reached or the agreement reaches its final expiration date on July 1, 2036.  

Section 338 tariffs   
Annexes I and II  
Presidential Proclamations  
Fact Sheet 
Canada 50% Exceptions include energy, potash, products already subject to Section 232 tariffs and certain other goods, including some fish and critical minerals. 
Section 301 tariffs banning imports produced with forced labor  

Fact Sheet 
Canada, Ecuador, Indonesia, Mexico, Pakistan and the EU  Algeria, Angola, Argentina, Australia, the Bahamas, Bahrain, Bangladesh, Brazil, Cambodia, Chile, People’s Republic of China, Colombia, Costa Rica, Dominican Republic, Egypt, El Salvador, Guatemala, Guyana, Honduras, Hong Kong, India, Iraq, Israel, Japan, Jordan, Kazakhstan, Kuwait, Libya, Malaysia, Morocco, New Zealand, Nicaragua, Nigeria, Norway, Oman, Peru, the Philippines, Qatar, Russia, Saudi Arabia, Singapore, South Africa, South Korea, Sri Lanka, Switzerland, Taiwan, Thailand, Trinidad and Tobago, Türkiye, United Arab Emirates, United Kingdom, Uruguay, Venezuela, Vietnam 10% for failing to effectively enforce a prohibition on the importation of goods produced with forced labor    12.5% for failing to impose and effectively enforce a prohibition on the importation of goods produced with forced labor   All articles and parts or articles covered by Section 232 tariffs are not impacted. The full list of exempted products is included in the Federal Register Notice. 
Section 301 tariffs on imports from Brazil  
Notice of Action 
Imports subject to an additional 25% tariffs. Products already subject to Section 232 tariffs are excused. These include covered steel, aluminum, copper, vehicles, vehicle parts, certain wood products, heavy vehicles and semiconductors, are excluded. 
Section 301 tariffs on imports from China Every product subject to the Section 301 actions is identified by an 8-digit or 10-digit HTS Subheading. The USTR website provides a search engine for more information.  
Section 232  

Presidential Proclamation


Fact Sheet 
All countries except Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union, where trade agreements exist, plus Russia 50% on articles made entirely or almost entirely of steel, aluminum or copper pay a flat 50% on the full value. 25% on derivative articles that are “predominantly composed” of steel, aluminum or copper 15% on certain metal-intensive fixed industrial equipment, power equipment, agricultural equipment, and certain HVAC systems and components through 2027 10% on products made abroad but 85% with American steel, aluminum, and copper 0% on products made of 15% or less steel, aluminum, or copper Steel, Aluminum & Copper  Products in Annex I-C are 25%, except Products from Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or a member nation of the European Union are 15%, unless bi-lateral agreements state otherwise. 
EU Per the U.S. – EU Framework  Speak with suppliers and customs brokers for specifics 
Japan Per the United States – Japan Agreement (see below) Speak with suppliers and customs brokers for specifics 
South Korea Per the U.S. – Korea Strategic Trade and Investment Deal (see below) Speak with suppliers and customs brokers for specifics 
Russia 200% For aluminum imports 
U.K. Per the U.S.- U.K. Economic Prosperity Deal Speak with suppliers and customs brokers for specifics 
Upholstered wood furniture from all countries  Presidential Proclamation Effective Oct. 14, 2025 10% U.K. 15% EU 15% Japan 25% all other countries   Planned 30% increase delayed to Jan. 1, 2027  
Semiconductors, semiconductor manufacturing equipment and derivative products  Presidential Proclamation 25% – effective Jan. 15, 2026   Tariffs do not apply when the chips are imported to support the buildout of the U.S.’ technology supply chain during ongoing trade negotiations with foreign jurisdictions that have the potential to strengthen the U.S. semiconductor industry.  
De Minimis No longer apply for any countries – effective Aug. 29, 2025, and reconfirmed Feb. 20, 2026; this decision is under appeal 

  • The May 8, 2025 Agreement addresses steel and aluminum tariffs and numerous other trade-related topics.
  • The USTR opened a Section 301 investigation into Vietnam’s inadequate intellectual property protection and enforcement. USTR sought input by July 2 regarding acts, policies and practices related to a lack of adequate and effective protection of IP rights and the denial of fair and equitable market access to persons that rely on IP protection. 
  • The U.S. International Trade Commission (ITC) released its report estimating that revoking China’s permanent normal trade relations (PNTR) status would increase U.S. consumer prices 1% and reduce imports from China 30.8% by the sixth year. The ITC also evaluated phasing in higher tariffs on selected national security-related products over five years. Congress has not enacted PNTR revocation.
  • On Oct. 28, the U.S. Secretary of Commerce concluded an investigation under the Trade Expansion Act to assess whether imports of robotics and industrial machinery, and parts/components, pose a risk to national security. On that date, President Donald Trump signed an official proclamation that declares: these imports threaten national security, avoids immediate tariffs or HTS changes, keeping existing duties in place and continues negotiations. 

Global Market Access and Conformity Guide

NAFEM’s regularly updated resource to assist in the identification of international certifications, the Global Market Access and Conformity Guide provides certification contact information for fuel type, region and other data points to reduce research time. While this tool is updated periodically, we encourage companies to take all steps necessary to confirm and verify information for your specific products and market needs.

Additional Resources

Questions?

Contact advocacy@nafem.org