On August 7, 2025, the United States implemented its updated set of reciprocal tariff rates, leaving all countries except Canada and Mexico facing at least a 10 percent tariff. Non-USMCA conforming imports (goods not substantially transformed in North America) from Canada are subject to a 35 percent tariff with Mexico remaining at 25 percent through October.
The final rates caught several countries off guard including Switzerland, which received among the highest rates at 39 percent. Japan and South Korea received 15 percent tariffs.
The European Union negotiated an all-in rate of 15 percent to include any General Duty rates with the reciprocal action. As of this writing, this is the only instance where the country-specific tariffs are incorporated into the General Duty rates and not in addition. Currently, the duty rates, which typically range from 2-5 percent, are added to the reciprocal tariffs now in effect.
Absent from any of the agreements is a definitive path forward on the Section 232 50 percent tariffs on steel, aluminum, and copper which apply to all countries. The U.S.-EU announcement included key commitments, stating that the two are “joining forces to protect the steel, aluminum and copper sectors from unfair and distortive competition. Global overcapacity threatens EU and US industry alike. Together, the EU and the US will establish tariff rate quotas for EU exports at historic levels, cutting the current 50% tariffs, while jointly ensuring fair global competition.”
The reference to tariff rate quotas (TRQs) is significant and appears to differ from the Biden administration approach of zero tariffs until the quota is reached. Officials are discussing a two-tiered tariff system with a lower rate, possibly at 25 percent for steel, aluminum, and copper imports until the quota limit, followed by a return to the 50 percent rate.
U.S. Implements 50% Tariffs on Semi-Finished Copper Products
Effective 12:01AM on August 1, 2025, the Trump administration began imposing a 50 percent tariff on global imports of semi-finished copper and on “intensive copper derivatives.” While this broad action temporarily excludes refined copper, and copper inputs such as ores, concentrates, mattes, cathodes, and anodes, it covers copper alloys. Earlier this year, One Voice filed comments raising concerns over too broad of a scope of tariffs on copper and copper alloys.
U.S. Customs is expected in the coming weeks to issue a FAQ potentially clarifying how to calculate the copper content in imports, such as brass, bronze, and nickel. The administration announced that by October 28, it will create a process for the public to request that the Commerce Department add more products made of copper, known as derivatives, to the 50 percent tariff list. Any goods already subject to the Section 232 auto tariffs are not also subject to this 232 copper action.
The 50 percent tariff applies only to the copper content of covered products; non-copper portions will be assessed under reciprocal specific to that country of origin or other applicable duties.
U.S. Customs and Border Protection (CBP) will require strict copper content declarations, with underreporting potentially triggering monetary penalties, loss of import privileges, and criminal liability. Imports entering U.S. foreign trade zones must be classified as “privileged foreign” and pay the 50 percent duty upon entry into domestic commerce.
The scope deliberately excludes certain raw and primary forms of copper, including ores, concentrates, mattes, cathodes, and anodes, as well as copper scrap. However, the proclamation directs the Department of Commerce to review cathode and anode market conditions by June 30, 2026. Should supply chain vulnerabilities persist, phased tariffs of 15 percent in 2027 and 30 percent in 2028 may be imposed on refined copper. Scrap copper remains exempt from duties, but a new domestic sales requirement mandates that at least 25 percent of high-quality scrap be sold in the U.S., with a possible export licensing system to ensure compliance.
Additional supply-chain measures require that, starting in 2027, 25 percent of U.S.-produced copper ores, concentrates, cathodes, and anodes be sold domestically, rising to 30 percent in 2028 and 40 percent in 2029. Duties paid under this proclamation are not eligible for drawback. The non-copper content of any covered item remains outside the copper Section 232 scope and will continue to be assessed under existing tariff regimes, including reciprocal tariffs.
EPA Proposes to Revoke GHG Endangerment Finding
The Environmental Protection Agency (EPA) has taken a historic step toward rolling back federal climate regulations by proposing to rescind the 2009 Endangerment Finding, the legal and scientific determination that greenhouse gases (GHGs) pose a threat to public health and welfare. Announced by Administrator Lee Zeldin on July 30, 2025, and formally published in the Federal Register on August 1, the proposed rule would also dismantle associated vehicle emissions standards that stemmed from that finding. The agency describes this as “the largest deregulatory action in U.S. history,” projecting $54 billion in annual consumer savings and $170 billion in regulatory relief for small businesses.
The EPA’s legal reasoning centers on a revised interpretation of Section 202(a) of the Clean Air Act, which it now argues does not authorize regulation of pollutants based on global climate change impacts—only those with localized and direct effects. The proposal also challenges the scientific underpinnings of the original finding, suggesting that its methodology is no longer valid. Alongside its primary rationale, the agency presents an alternative argument questioning the original climate risk assessments and invites public comment on both legal and scientific grounds. The comment period will run through September 15, 2025.
Reaction has been swift and polarized. Environmental groups and many state officials, particularly in California, have condemned the move, warning that it undermines decades of climate policy and jeopardizes public health. Several states have pledged to pursue their own emissions rules, while advocates forecast legal challenges that could eventually reach the Supreme Court. Industry groups, small business advocates, and conservative policymakers have praised the action as long-overdue regulatory relief, contending that climate policy should be set by Congress rather than unelected agencies. Whether the rule survives the rulemaking process and anticipated litigation could shape the trajectory of U.S. climate regulation for years to come.
EPA Submits Proposed TSCA Risk-Evaluation Framework Overhaul to OMB
The U.S. Environmental Protection Agency (EPA) has formally submitted to the Office of Management and Budget (OMB) a revised proposed rule titled “Further Reconsideration of Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA)”, marking the next major step in reshaping how chemical risk assessments are conducted under TSCA.
Originally finalized in May 2024 during the Biden administration, the TSCA risk evaluation framework rule established how EPA evaluates whether chemicals pose unreasonable risks. Key elements included a single-risk determination per chemical, comprehensive inclusion of all exposure pathways and conditions of use, and excluding personal protective equipment (PPE) from risk assessments.
On March 10, 2025, the EPA announced its intent to reconsider the 2024 rule—prompted by Executive Order 14219, which directed agencies to reassess regulations for compliance with administration policy and statutory authority. Among the issues EPA planned to reevaluate were:
• Whether a single risk determination per chemical is TSCA-compliant;
• The statutory timeline for evaluating all conditions of use;
• Incorporation of PPE and industrial controls in occupational risk evaluations;
• The breadth of regulatory definitions expanded in the 2024 rule.
The submission triggers OMB’s interagency review process, typically lasting around 90 days, though in some cases it may take longer.