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With the conclusion of President Trump’s 90-day tariff extension—in which the promised 90 trade deals were not completed—the administration has issued a new executive order modifying the original “reciprocal” tariff EO of April 2.

Country-specific IEEPA tariffs: Country rates in Annex I of the April 2 EO included those that “have agreed to, or are on the verge of concluding, meaningful trade and security agreements with the United States.”

• Annex I tariffs will apply until deals are concluded and memorialized in a U.S. presidential EO.
• Some countries have concluded deals (e.g., Japan, South Korea, the EU and Vietnam), and those rates are reflected in Annex I.
• However, it’s unclear if there’s room for improvement for those trading partners as well as for those that have not reached deals.

Notable details: Here are a few details from the new EO that stand out:

• The EU rate has a 15% ceiling inclusive of the base MFN rate, so the additional International Emergency Economic Powers Act tariff is the difference between 15% and MFN.
• Brazil has a tariff of 10% in Annex I, which will stack on the 40% in a separate EO issued July 30.
• Notable new rates in the new EO include India at 25%, Switzerland at 39% and Taiwan at 20%.
• A full updated chart maintained by the NAM shows the difference between April 2 rates and July 31 rates. The chart can be accessed here. 

Exceptions: Annex I of the new EO replaces Annex I of EO 14257 of April 2. However, the exceptions set forth in EO 14257 (as amended) still apply.

Everyone else at 10%: Any trading partner not listed in Annex I is subject to an additional 10% IEEPA tariff, unless otherwise expressly provided.

• China: The status quo is under a 90-day “pause” until Aug. 12 unless new terms are struck.
• Mexico: The president concluded a call with Mexican President Claudia Sheinbaum on Thursday and determined to extend the terms of Mexico’s 25% IEEPA fentanyl tariff, along with the same Section 232 terms and exception for USMCA-qualifying goods, for another 90 days “or longer” with a goal of signing a deal.
• Canada: In a fact sheet (citing an EO not yet published), the president increased the IEEPA fentanyl tariff on Canada from 25% to 35% “in response to Canada’s “continued inaction and retaliation.” USMCA-qualifying goods remain exempt. Goods transshipped will be subject to 40%.

Timing: The new tariff rates go into effect for goods entered for consumption on or after 12:01 a.m. EDT seven days after the date of this EO.  

• There is an “on the water” exception for goods in final mode of transit before this time, so long as they are entered for consumption before Oct. 5, 2025.

What’s next: Expect negotiations to continue, at the president’s determination and discretion.