On April 29, 2025, President Trump issued an Executive Order to prevent the “stacking” or cumulative application of certain tariffs on imported goods. While each tariff action serves distinct policy goals, the administration has determined that overlapping duties on the same article may exceed what is necessary to achieve those objectives. The Executive Order outlines a procedure to determine which tariff shall apply when an article is subject to multiple listed actions.
This order only applies to the following actions:
Proclamation 10908 – Section 232 tariffs on imports of automobiles and parts
Executive Orders 14193, 14226, 14231 – IEEPA-based fentanyl tariffs on Canada
Executive Orders 14194, 14198, 14227 – IEEPA-based fentanyl tariffs on Mexico
Proclamations 9704, 9980, 10895 – Section 232 tariffs on aluminum and derivative articles
Proclamations 9705, 9980, 10896 – Section 232 tariffs on steel and derivative articles
Under this order, any articles subject to tariffs under Proclamation 10908 (Action 1) will not be subject to additional tariffs under Actions 2, 3, 4, or 5. Any articles subject to tariffs under the Canadian or Mexican IEEPA fentanyl tariffs (Actions 2 or 3) will not be subject to additional tariffs under the aluminum or steel actions (Actions 4 or 5). Articles subject to tariffs under the aluminum proclamations (Action 4) may also be subject to tariffs under the steel proclamations (Action 5), and vice versa.
Each action listed in the order remains independently valid and enforceable. However, when multiple listed actions apply to the same article, duty rates will not be cumulative if the conditions set forth in the order are met. If an imported article is subject to a tariff covered by this Executive Order and also subject to one or more tariffs imposed under actions not listed in the order, the duties will be cumulative.
Accordingly, an article that is subject to duties pursuant to an action listed in this order, may still be subject to other applicable duties, taxes, fees, or charges. These may include, but are not limited to, those in column 1 of the Harmonized Tariff Schedule of the United States; duties imposed under section 301 of the Trade Act of 1974, as amended; duties imposed under Executive Order 14195 (Imposing Duties To Address the Synthetic Opioid Supply Chain in the People’s Republic of China), as amended; and any applicable antidumping or countervailing duties.
The Executive Order applies retroactively to all entries of merchandise subject to the applicable tariffs identified above and entered for consumption on or after March 4, 2025. Refunds, where applicable, will be processed in accordance with applicable laws and CBP’s standard refund procedures.
CBP will publish specific refund procedures and any necessary updates to the HTSUS in a Federal Register Notice no later than May 16, 2025. Importers and filers have been instructed to refrain from requesting refunds until the procedures are formally announced in that notice.
An updated bulletin will be posted once CBP provides the refund procedures.
To view the full Executive Order, visit: