On September 5, 2025, President Trump issued an Executive Order modifying the list of products subject to reciprocal tariffs. The modifications take effect today.
Several goods have been added to the exclusions in Annex II of Executive Order 14257 of April 2, 2025 (as amended by the September 5 Executive Order) and no longer subject to reciprocal tariffs. These goods include bullion-related articles, certain critical minerals, and pharmaceutical products subject to a pending Section 232 investigation. The September 5 Order also incorporates into its own Annex II the exclusions for smartphones and similar products identified in the Presidential Memorandum of April 11, 2025.
Other goods have been removed from Annex II and are now subject to reciprocal tariffs. These goods include certain aluminum hydroxide, resin, and silicone products. The revised list is set out in Annex II of the September 5 Order.
The new Executive Order also identifies products that the administration may subject to a 0 % tariff under the Potential Tariff Adjustments for Aligned Partners in Annex III of the September 5 Order. These products fall into the following categories:
aircraft and aircraft parts;
generic pharmaceuticals and their ingredients;
unavailable natural resources and closely related derivative products; and
agricultural products not grown or produced in sufficient quantity in the United States.
Annex III of the September 5 Order includes a “Scope Limitations” column, signaling that even if certain products qualify for exclusion under future trade agreements, those exclusions may be limited in scope, potentially based on end use.
Please do not hesitate to reach out if you have any questions or would like to discuss how these changes may impact your business.