Addressing Threats to the United States by the Government of Iran
The order establishes a process to impose additional tariffs — cited at up to 25% as an example — on imports from any foreign country that purchases goods or services from Iran, invoking the national emergency first declared in 1995.
It uses IEEPA authority to create a secondary economic pressure mechanism: countries that continue trading with Iran can be targeted with U.S. tariffs, expanding the Iran sanctions regime to reach third-country trade partners.
What this order does
What it orders
The order directs the Secretary of Commerce to monitor and determine whether any foreign country directly or indirectly purchases, imports, or acquires goods or services from Iran. When Commerce makes an affirmative finding, it notifies the Secretary of State, who — in consultation with Treasury, Homeland Security, and the U.S. Trade Representative — assesses whether an additional tariff should be recommended and at what rate. The Secretary of State then submits that recommendation to the President, who makes the final decision on whether and to what extent to impose the tariff. Commerce and State are each authorized to issue implementing rules, regulations, and guidance.
The order does not itself impose any tariff; the actual duty requires completing this multi-step review chain and a subsequent presidential determination. It also reserves broad presidential modification authority — including if a targeted country retaliates, cooperates with U.S. national security goals, or if circumstances otherwise change. A severability clause ensures that if any provision is invalidated, the broader existing Iran sanctions framework remains intact.
Who it affects
Foreign governments and businesses in countries that trade with Iran, U.S. importers and businesses that source goods from those countries, and the governments and economies of any nation placed under review by the Commerce Secretary for Iranian trade ties.
Why it matters
U.S. importers sourcing goods from countries found to trade with Iran could face tariff surcharges on those goods once the review process concludes and the President acts. Foreign trading partners must weigh continued commerce with Iran against the risk of U.S. tariff exposure on all their exports to America.
What must happen and when
How the order is supposed to work
The order works through a two-stage bureaucratic trigger. Commerce first monitors and identifies countries buying Iranian goods or services; an affirmative finding is passed to State. State then consults Treasury, DHS, and USTR to formulate a tariff recommendation, which goes to the President for a final decision. No tariff attaches until that presidential determination. Commerce and State each hold independent rulemaking authority to operationalize the process. The President retains discretion to modify or suspend tariffs based on retaliation, cooperation, or changed circumstances, and a severability clause insulates the broader Iran sanctions regime from any judicial challenge to this order.
Actions and deadlines
- Monitor whether foreign countries directly or indirectly purchase goods or services from Iran
- Determine whether a foreign country purchases Iranian goods or services and notify the Secretary of State
- Issue rules, regulations, and guidance necessary to implement the order
- Determine whether and to what extent an additional tariff should be recommended on a found country's goods
- Submit tariff recommendation and supporting Commerce findings to the President
- Monitor circumstances related to the Iran national emergency and report any situation warranting further Presidential action