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    Home » IEEPA Tariffs Are Down from April Threats
    Tax Planning

    IEEPA Tariffs Are Down from April Threats

    troyashbacherBy troyashbacherNovember 24, 2025No Comments6 Mins Read
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    IEEPA Tariffs Are Down from April Threats
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    On “Liberation Day” in April 2025, President Trump threatened to impose extreme tariffs on most US trading partners under the International Emergency Economic Powers Act (IEEPA). These so-called “reciprocal” tariffs included a baseline of 10 percent on most US trading partners and higher rates of up to 50 percent on 57 specific trading partners, along with the subsequently announced 125 percent tariffTariffs are taxes imposed by one country on goods imported from another country. Tariffs are trade barriers that raise prices, reduce available quantities of goods and services for US businesses and consumers, and create an economic burden on foreign exporters. on China. The “reciprocal” tariffs were in addition to the IEEPA “fentanyl” tariffs imposed on Canada, Mexico, and China under a separate emergency declaration. Since April, the tariffs that have been implemented in practice are mostly, but not exclusively, lower than what was originally threatened.

    In this analysis, we compare the tariff rates threatened in April to the tariffs implemented as of November 17 and explain why the difference matters for economic projections and outcomes. We exclude all Section 232 tariffs from our analysis to focus solely on the IEEPA tariffs.

    Liberation Day Tariffs Then and Now

    Since announcing the Liberation Day tariffs, President Trump has twice postponed, and several times modified, the country-specific “reciprocal” tariffs. He has also adjusted other IEEPA tariffs affecting China, Mexico, Canada, Brazil, and India under different emergency declarations. The table below shows the rates threatened in early April under IEEPA versus the currently applied rates under IEEPA for the top 10 US trading partners. A full table is available for download.

    The most notable decrease in threatened versus implemented tariffs is for China, falling from the announced 145 percent in April to 20 percent as of November 1. Some trading partners, including Canada, India, and Brazil, have higher tariffs implemented as of November 17 than threatened in April. In the case of India and Brazil, higher rates result from new IEEPA tariffs related to other perceived emergencies. However, most trading partners have seen rates decline from April threats. In addition to rate changes, several categories of goods have been exempted.

    Table 1. Threatened Tariffs Compared to Current Tariffs for Select US Trading Partners

    Note: Rates shown include statutory rates under IEEPA tariff announcements; no other tariff rates are included.
    Source: US International Trade Commission, “Imports for Consumption”; Federal Register; TaxA tax is a mandatory payment or charge collected by local, state, and national governments from individuals or businesses to cover the costs of general government services, goods, and activities. Foundation calculations.

    Comparing Applied Tariff Rates Over Time

    The weighted average applied tariff rate shows the statutory burden placed on imports, independent of how importers may respond. For instance, if a 200 percent tariff significantly slows imports, then revenue and effective rate measures would approach zero, but the applied rate of 200 percent would still illustrate the burden placed on affected imports. For this reason, focusing on the applied tariff rate allows us to compare how the statutory tax burden on imports has changed over time. We calculate the applied tariff rate by taking the statutory rate for each country’s affected imports based on 2024 levels as a share of total imports.

    According to our calculations, the weighted average applied IEEPA tariff rate under the Liberation Day announcements was 23.2 percent. This estimate includes the 10 percent baseline tariff, the country-specific tariffs threatened in early April, the subsequently announced 125 percent tariff on China, the initial exemptions list, and the border security and fentanyl tariffs on Canada, Mexico, and China.

    As of November 17, the weighted average applied IEEPA tariff rate has fallen by more than half to 10.8 percent. This includes the 10 percent baseline tariff; the actual implementation of country-specific rates; the border security and fentanyl tariffs on Canada, Mexico, and China; the subsequently announced exemptions; and the new IEEPA tariffs of 50 percent on Brazil and India.

    Both estimates isolate the IEEPA tariffs only. They do not include pre-existing tariff programs or changes in other tariffs over the same period.

    Taken together, our calculations show that the actual implementation of IEEPA tariffs as of November 2025 is less than half of what was threatened on and immediately after Liberation Day.

     

    Economic Projections of the IEEPA Tariffs

    Given the large gap in the IEEPA tariffs threatened and imposed, we should also expect a large gap between the estimated economic effects of the Liberation Day tariff announcements and the actual imposition of IEEPA tariffs.

    Using Tax Foundation’s General Equilibrium Model, we estimate that if the April version of the IEEPA tariffs had been imposed, long-run US economic output would have fallen by 0.7 percent. Under the current version of IEEPA tariffs, instead, we estimate long-run US GDP will fall by 0.4 percent. Neither estimate incorporates announced or imposed foreign retaliation, which would further reduce output.

    IEEPA Tariffs Moving Forward

    The IEEPA tariffs are under challenge at the Supreme Court in a case that will determine whether a president may use IEEPA to impose tariffs. The Court could rule to remove the IEEPA tariffs altogether. In that event, the worst of the economic effects from higher tariffs may be avoided, even though the administration could employ other, more narrow measures to levy tariffs without IEEPA.

    Ultimately, the economic damage realized from tariffs may be less than initially predicted by economists in April because the tariffs ultimately imposed are smaller than originally announced. At the same time, elevated policy uncertainty remains, and uncertainty itself will depress investment and output in the immediate term.

    How the tariffs are ultimately implemented will determine the actual economic effects. Because the implemented IEEPA tariffs are roughly half the size of the April threats, the realized economic harm will be correspondingly smaller than what was originally estimated based on the larger threats.

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