Reciprocal Tariffs Update – Q3 Exceptions, Trade Deal Frameworks, And Increased Enforcement Risk

The White House modified its reciprocal tariff policy effective this week in ways that may benefit some domestic US importers. On September 5, 2025, one month after releasing new reciprocal tariff rates for most countries to replace previous universal 10% duties, the Trump Administration (the "Administration") published a new Executive Order that further modifies reciprocal tariff rates for specific goods (the "E.O."). Key changes were effective on September 8, 2025. When reciprocal tariffs were first announced on "Liberation Day" in April 2025 the program applied to nearly all imports from most countries and excepted only certain classes of goods. The Administration now has added and removed certain goods from lists of exceptions, which could have a material impact on the cost of landed goods in some supply chains.