Addressing Certain Tariffs on Imported Articles
The order establishes a non-stacking rule for five overlapping sets of U.S. import tariffs — covering automobiles, aluminum, steel, and goods from Canada and Mexico — so importers pay the applicable highest single rate rather than having multiple tariff regimes add together on the same article.
It takes effect immediately and applies retroactively to merchandise entering on or after March 4, 2025, requiring refunds of duties that were collected at stacked rates, making it a self-executing change with direct financial consequences across a wide range of trade.
What this order does
What it orders
The order directs that when an imported article is covered by more than one of five specified tariff actions — the automobile tariff proclamation, the Northern Border drug tariffs, the Southern Border drug tariffs, the aluminum tariffs, and the steel tariffs — the rates from those actions shall not stack cumulatively. The priority rule works in tiers: automobile tariffs take precedence over all others; Northern and Southern Border tariffs take precedence over aluminum and steel tariffs; aluminum and steel tariffs may still stack with each other. The order is retroactive to March 4, 2025, and requires CBP to issue refunds for excess duties already collected under stacking.
The order explicitly preserves all other tariffs outside the five listed actions, including Section 301 China tariffs, antidumping and countervailing duties, and standard Harmonized Tariff Schedule rates, which remain fully cumulative with any tariff from the five listed actions. The underlying authority for each of the five tariff regimes remains independently valid — only the stacking of their duty rates is limited.
Who it affects
Importers of automobiles, automobile parts, aluminum, steel, and goods from Canada and Mexico who were or are subject to multiple overlapping tariffs simultaneously. Companies that overpaid under stacked rates since March 4, 2025, are eligible for refunds through U.S. Customs and Border Protection.
Why it matters
Businesses importing covered goods could receive retroactive refunds for tariffs paid at stacked rates since March 4, 2025, and will face lower duty costs going forward when multiple listed tariffs would otherwise apply to the same shipment. Importers of automobiles and steel or aluminum products are the most directly affected.
What must happen and when
How the order is supposed to work
The non-stacking rule is self-executing from signing and retroactive to March 4, 2025. CBP — guided by Treasury and Commerce — must update its systems, guidance, and enforcement mechanisms to apply the new priority tiers. Any needed changes to the Harmonized Tariff Schedule must be completed by 12:01 a.m. EDT on May 16, 2025, with the Secretary of Homeland Security coordinating with the International Trade Commission Chair to make those amendments. Refunds for prior stacked-rate overpayments flow through CBP's standard refund procedures under applicable law.
Actions and deadlines
- Update CBP guidance, systems, and enforcement mechanisms to reflect the non-stacking policy
- Make all necessary changes to the Harmonized Tariff Schedule to execute this order
- Apply the non-stacking rule retroactively to all qualifying merchandise entries
- Process refunds for duties collected at stacked rates on retroactive entries