The Trump administration has made a rolling set of announcements on the application of tariffs on imports into the United States of America. Ai Group will update this page as we gain more understanding of the quantum and application of these tariffs.

As with all major disruptions, the most important thing that companies can do is focus on communication and relationships. We recommend that you are communicating regularly with your customers, suppliers, service providers and peers.

In some applications of the tariffs on imports from some countries, the percentage of US content is excluded from the new tariff upon application to the US Commerce Department. It is essential that you understand your supply chain and have robust material data processes so that you can support your US-based customer in any application that they may make.

 

Known Knowns as of 4 June 2025

Please note the effective dates. On 10 April there was an announcement that rolled back some tariffs. The steel, automotive and base line tariffs remain in place.

On 29 May the United States Court of International Trade declared the announced Reciprocal Tariffs illegal. The Presidential Office immediately lodged an appeal, during which time the Court has confirmed that the tariffs remain; this includes the 10% tariff applied to general goods from Australia.

On 3 June, the White House issued a statement announcing an increase in the tariff rate for imports of steel articles and derivative steel articles, and aluminium articles and derivative aluminium articles, from 25 percent ad valorem to 50 percent ad valorem effective as of 12:01 a.m. eastern daylight time on June 4, 2025.

There are two separate announcements on the same day (3 June):

• Adjusting Imports of Aluminum and Steel into the United States
• Fact Sheet: President Donald J. Trump Increases Section 232 Tariffs on Steel and Aluminum

Rules of Origin

This update provides clarity of the rules of origin that will apply to products manufactured in Australia, and would traditionally be using the United States Australia Free Trade Agreement.

The document can be found here.

The introductory text explains the treatment of packaging diminis products and the calculation of Regional Value Content if it applies.

To identify your Product Specific Rule, go to the relevant chapter, for example, Chapter 76, Aluminium and articles thereof.

Then find your specific code:

7603 Aluminium powders and flakes.

Then the relevant rule: A change to heading 7603 from any other chapter.

This rule means that any input not originating from either Australia or the United States must be imported under any code that does not start with 76. For example, Items of Zinc, from Chapter 79 is fine. It is important to understand that purchasing from an Australian company does not make the product Australian.

Rules for other Free Trade Agreements to the US can be found at this link.

Cumulative tariffs/Staking of tariffs

The lack of tariff cumulation has been confirmed by the White House in this announcement. This is consistent with our previous advice.

25% tariff on all steel and aluminium and their derivatives (products with significant % of metal) was effective 12:01 a.m. USA Eastern Daylight Time on March 12, 2025.

• Import guidance for Steel and derivatives
• Import guidance for Aluminium and their derivatives

25 % tariff on automotive; passenger vehicles (sedans, SUVs, crossovers, minivans, cargo vans) and light trucks and their parts (engines, transmissions, powertrain parts, and electrical components) from all countries was effective 12:01 USA Eastern Daylight Time on April 3, 2025.

• Import guidance for automotive products

10% baseline tariff on most other Australian products

• Some goods will not be subject to the 10% Tariff. These include: (1) articles subject to 50 USC 1702(b); (2) steel/aluminum articles and autos/auto parts already subject to Section 232 tariffs; (3) copper, pharmaceuticals, semiconductors, and lumber articles; (4) all articles that may become subject to future Section 232 tariffs; (5) bullion; and (6) energy and other certain minerals that are not available in the United States.
• This took effect April 9, 2025 at 12:01 a.m. EDT.
• Import guidance for all new tariff lines.
  • This document outlines the rules for the baseline 10% tariffs that apply to all countries, as well as listing the additional tariffs for countries other than Australia.  
  • The so-called reciprocal tariffs that are additional to the baseline, have been paused for 90 days.  
  • Annex Two of this document lists the impacted products.  

Chinese goods to the United States are now subject to up to 245% in accumulative tariffs (although the majority of goods are only subject to an accumulative 145% in tariffs). These comprise:

• the 125% 'reciprocal tariff' on all goods from China, Hong Kong and Macau;
• a 20% tariff on all goods, which is linked to perceived inaction from China to curb the transit of fentanyl into the US; and
• goods-specific tariffs ranging from 7.5% to 100% linked to sector-specific Chinese trade practices the US regards as hostile. Examples of products affected by these tariffs include electric vehicles and medical supplies.

This White House announcement outlines increased charges for packages from China subject to di minimis conditions, increasing the tariff from 90% to 120% and adds a USD100 charge per package, up from $75. 

Australian di minimis packages are not subject to these additional charges.  

Australian goods are not subject to cumulative tariffs (steel + auto part + Australia).

Which tariff is for me? The hierarchy of tariffs appears to be Steel, then automotive, then baseline.

The White House has stated that around 75 nations are seeking to negotiate new trade agreements to end the tariffs. Australia is one of those countries. The Australian Industry Group continues to closely monitor the status of these negotiations and is in regular contact with relevant Australian officials.

Who pays?

The tariff is applied by product, not company. An Australian company sending Chinese-made product to the US, could be hit by a 125% tariff, not 10%. It is important to understand your supply chain and country of origin of your products.

It is unclear what, if any, Australian products might intersect with the additional goods-specific tariffs (ranging from 7.5% to 100%) the US has levelled against some Chinese products, such as electric vehicles.

Exporters paying under the following International Commercial Terms (Incoterms) will be responsible for paying the tariffs.

DDP (Delivered Duty Paid): The seller (exporter) takes on the maximum responsibility, covering all costs, including import duties and taxes, and delivering the goods to the named place, cleared for import.

All other Incoterms: the importer is responsible for paying all import charges.

How are they calculated?

They will be calculated on the FOB (Freight on board) value of the product.

 

Known unknowns

When they will end?

Will there be more tariffs and/or more temporary exemptions?

Will the current figures change?

Will current exemptions be included later on?

What is the full scope of Australian products impacted?

 

Unknown unknowns

The impact on individual economies, especially our major trading partners.

How individual economies or companies will react, or what the consequences of that rection might be.

Impact on the Australian economy, positive or negative.

Currency exchange impacts.

 

What can you do?

Email industry.policy@aigroup.com.au with questions and stories we can use for advocacy on your behalf.

Evidence of Australian Origin will grow in importance. Ai Group offers this service to members. Email tradedocs@aigroup.com.au

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