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EO 14326Executive OrderTrump 47 · R

Executive Order 14326

Further Modifying the Reciprocal Tariff Rates

Executive Order 14326 modifies reciprocal tariff rates imposed under EO 14257, replacing country-specific additional ad valorem duties with new rates in Annex I effective August 7, 2025. The order creates a 15% combined duty floor for EU goods, maintains a 10% default rate for unlisted partners, imposes a 40% transshipment penalty, and requires biannual publication of circumvention facility lists.

Federal Register Open PDF 90 FR 37963

Impact dates

  1. 20d ago

    Subsequent biannual circumvention list publications

  2. First biannual publication of circumvention countries and facilities list

  3. Deadline for in-transit goods (loaded before August 7, 2025) to be entered for consumption under prior EO 14257 rates

  4. Tariff modifications effective; new Annex I rates apply to goods entered for consumption or withdrawn from warehouse

Market exposure

Policy exposure mapping — not investment advice. Illustrative public companies are incomplete and not recommendations.

Sectors

Steel & aluminumAutosAgriculturePharmaTechnology & softwareSemiconductors

Mechanisms

TariffBan / prohibitionProcurement

Role pressure

  • AdverseImporter — Higher or restructured ad valorem duties on covered goods; 40% transshipment penalty creates compliance risk; EU floor at 15% raises costs for EU-sourced goods
  • ProtectiveDomestic producer — Tariff walls against imports from non-compliant partners and EU goods below 15% baseline; emergency declared to protect domestic manufacturing base and defense industrial base
  • MixedDownstream manufacturer — Protected from import competition but faces higher input costs for EU goods subject to new floor and other partner goods with elevated Annex I rates
  • MixedTrading-partner exporter — Adverse for non-compliant partners and those with insufficient offers; protective/uncertain for partners 'on verge of concluding' agreements whose rates may be memorialized in subsequent orders
  • AdverseProject developer — Supply chain uncertainty from biannual circumvention lists affecting procurement and due diligence; potential exclusion from public procurement if facilities listed

Geographies

USEUCNJPKRTWMXCAUKINVNMY

Exposure dates

  • — Tariff modifications effective; new Annex I rates apply to goods entered for consumption or withdrawn from warehouse
  • — Deadline for in-transit goods (loaded before August 7, 2025) to be entered for consumption under prior EO 14257 rates

Illustrative public companies

Curated watchlist matches by sector/role — incomplete; not a recommendation.

AAAlcoaGOOGLAlphabetAAPLAppleADMArcher Daniels MidlandAVGOBroadcomBGBungeCATCaterpillarCENXCentury AluminumCLFCleveland-CliffsCTVACortevaLLYEli LillyFFordGMGeneral MotorsHYMTFHyundai MotorINTCIntelQQQInvesco QQQ TrustJNJJohnson & JohnsonMRKMerckMETAMeta PlatformsMUMicron TechnologyMSFTMicrosoftNVSNovartisNUENucorNVDANVIDIA

Confidence: high · Policy alerts

Key directives

  • Modify HTSUS per Annex II effective 12:01 a.m. EDT August 7, 2025
  • Impose new country-specific ad valorem duties per Annex I in lieu of EO 14257 rates
  • Apply 15% combined duty floor for EU goods (Column 1 Duty Rate less than 15% gets supplemental rate to reach 15%; at/above 15% gets zero additional)
  • Maintain 10% default additional duty for unlisted trading partners
  • Impose 40% ad valorem penalty on transshipped goods evading duties
  • Publish biannual list of circumvention countries and facilities (every 6 months)
  • Terminate existing HTSUS headings 9903.01.43-9903.01.62 and 9903.01.64-9903.01.76 and subdivisions upon Annex II effective date
  • Commerce/USTR determine additional HTSUS modifications via Federal Register notice
  • Commerce/USTR monitor emergency and recommend further action

Who is ordered

Timeline

Immediate

  • EO takes effect upon signing July 31, 2025
  • tariff modifications effective August 7, 2025 at 12:01 a.m. EDT (7 days after signing)
  • in-transit goods loaded before August 7, 2025 exempt from new rates if entered before October 5, 2025
  • HTSUS heading suspensions continue until Annex II effective date

Near term (90d)

  • first biannual circumvention facility list due within 6 months (by January 31, 2026)
  • Commerce/USTR monitoring and recommendations to President on partner compliance
  • potential subsequent orders memorializing trade agreements with partners near conclusion

Long term

  • ongoing tariff regime subject to further modification based on trade negotiation outcomes
  • potential additional action if emergency not resolved or partners retaliate
  • permanent remedy of trade barriers dependent on bilateral agreement conclusions

Risks & tensions

  • EU 15% floor creates asymmetric treatment that may provoke retaliation from Brussels
  • Biannual circumvention list weaponizes reputational risk for supply-chain due diligence but criteria undefined
  • 'On the verge of concluding' agreements with certain partners creates uncertainty for rates that may change with subsequent orders
  • Transshipment 40% penalty plus non-mitigable fines risks severe supply disruption if CBP enforcement aggressive
  • EO 14298 China carve-out preserved, maintaining separate bilateral tension track
Executive Order 14326: Further Modifying the Reciprocal Tariff Rates · Executive Orders