Executive Order Issued to Prevent Tariff Stacking on U.S. Imports

Trade Update • April 29, 2025

New policy aims to eliminate “stacking” of tariffs on the same goods under multiple trade actions.

resident Donald Trump has signed a sweeping new Executive Order to eliminate the compounding effect of multiple U.S. tariffs on the same imported products. The order, issued under his authority as President and pursuant to laws including the International Emergency Economic Powers Act and Section 232 of the Trade Expansion Act, aims to streamline tariff enforcement while maintaining the protective goals of each individual trade measure.

Addressing Certain Tariffs on Imported Articles

Ending Tariff “Stacking”

The Executive Order sets a clear policy: when an imported article is subject to more than one U.S. trade action, the applicable tariffs will not cumulatively increase unless specifically allowed. The goal is to prevent tariff rates from unintentionally compounding beyond what’s necessary to achieve U.S. national security, foreign policy, or economic objectives.

If Autos 232 applies:
→ Excludes: Canada IEEPA (Border), Mexico IEEPA (Border), Aluminum 232, Steel 232

If Canada IEEPA applies:
→ Excludes: Aluminum 232, Steel 232
→ Presumed Exceptions: Autos 232 does not apply (if it does, CA IEEPA would not apply)
→ Presumed Exceptions: Mexico IEEPA (Border) does not apply (for Canadian-origin goods, subject to CA IEEPA)

If Mexico IEEPA applies:
→ Excludes: Aluminum 232, Steel 232
→ Presumed Exceptions: Autos 232 does not apply (if it does, MX IEEPA would not apply)
→ Presumed Exceptions: Canada IEEPA does not apply (for Mexican-origin goods)

If Steel 232 applies:
→ Aluminum 232 will stack (if product is subject to Aluminum 232 tariffs)
→ Presumed Exceptions: Autos 232, CA IEEPA, and MX IEEPA do not apply (as the other tariffs apply)

If Aluminum 232 applies:
→ Steel 232 will stack (if product is subject to Steel 232 tariffs)
→ Presumed Exceptions: Autos 232, CA IEEPA, and MX IEEPA do not apply (as the other tariffs apply)

Affected Tariff Programs

The Executive Order covers the following recent and legacy trade actions:

• Auto Tariffs (Proclamation 10908) — Section 232 tariffs on imported automobiles and parts
• Northern Border Duties (EOs 14193, 14197, 14226, 14231) — Tariffs targeting narcotics trafficking from Canada
• Southern Border Duties (EOs 14194, 14198, 14227, 14232) — Tariffs addressing border threats from Mexico
• Steel and Aluminum Tariffs (Proclamations 9704, 9705, 9980, 10895, 10896) — Trump-era Section 232 duties still in effect and recently updated

Articles falling under one of these categories will now be evaluated to ensure tariffs are not “stacked” unless explicitly permitted. For instance, steel imports may still face tariffs under both steel-specific and aluminum-related proclamations if statutory conditions are met.

Refunds and Implementation

The order is retroactive to March 4, 2025, and any excess tariffs collected due to overlapping duties will be eligible for refunds. U.S. Customs and Border Protection (CBP), in coordination with the Departments of Treasury, Commerce, and Homeland Security, is tasked with updating enforcement systems and issuing guidance by May 16, 2025.

CBP will publish refund procedures and any necessary updates to the Harmonized Tariff Schedule of the United States (HTSUS) in a Federal Register Notice no later than May 16, 2025. Until the process has been published, filers should refrain from submitting refund requests.

CSMS # 64916414 – Executive Order Addressing Certain Tariffs on Imported Articles

The Secretary of Homeland Security may also recommend changes to the Harmonized Tariff Schedule of the United States (HTSUS) to reflect the new non-stacking policy.

What’s Not Affected

This order does not alter:

• Duties from Section 301 of the Trade Act (e.g., China-related tariffs)
• Duties under EO 14195 on the synthetic opioid supply chain
• Antidumping or countervailing duties
• Any other fees or exactions listed in column 1 of the HTSUS

Such measures can still apply in addition to the trade actions covered under the new Executive Order.

The information presented is general in nature, and is not intended to constitute legal advice with respect to any event or occurrence, and may not be considered as such.​​ Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.​ Due to the complexity of Customs Regulations, valuations are based on information currently available and should not be considered binding, we recommend obtaining National Customs Rulings in areas of uncertainty.​

How GHY Can Help

GHY helps importers ensure every customs invoice is accurate, complete, and audit-ready. Our Global Trade Services team specializes in navigating complex compliance requirements—whether you’re managing changes to de minimis thresholds, Section 232 tariffs, or updated documentation standards enforced by CBP.

We offer targeted compliance audits, HTS classification reviews, and valuation consulting to uncover gaps and prevent costly errors. GHY also supports clients with origin determination, PGA reporting, and recordkeeping strategies aligned with the latest regulatory shifts.

With GHY as your compliance partner, you can reduce risk, avoid penalties, and maintain seamless customs clearance across all your shipments.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.