The Clean Tech Tariff Tracker
February -> March 2025
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Last month I said there would be time to dig into tariffs. Well the time is now! Over the past several weeks, the White House has announced and teased a slew of new tariffs with major ramifications for the energy sector. Between the acronym and number soup (IEEPA, 232, 301, AD/CVD, etc.) and what’s been threatened, withdrawn, enacted, and hit with retaliatory tariffs by our trading partners, it’s easy to get confused.
That’s why we’re publishing a tariff tracker that we’ll update regularly to make sure you have a one stop shop to make sense of how tariffs can impact the energy sector. Our hope is that this can be a living document that you can bookmark and keep coming back to as needed.
What we’re covering:
Tariffs announced and threatened by the Trump Administration that have a direct impact on energy markets. Steel and aluminum? You bet. Economy-wide tariffs on our trading partners? Absolutely.
Tariffs stack like building blocks, so we’re also including the trade actions taken by the Biden Administration that are still in place - particularly those that heavily impacted the energy sector, such as last year’s Section 301 actions that increased tariffs on a cross section of Chinese clean tech imports like solar, batteries and minerals.
Other trade restrictions like the Uyghur Forced Labor Prevention Act (UFLPA), which has been used to block imports of Chinese products - including critical minerals and polysilicon used in solar panels - that are at risk of being tainted by forced labor.
What we’re not covering:
Tariffs that don’t have a direct impact on energy markets ( 👋 Hi softwood lumber!).
Where you come in: Hit us up if we’re missing something! There’s a lot to cover here, so if you see a gap, let us know!
Government Financing Update: We’re taking a pause on the Financing Report this month as the Trump Administration is getting up to speed and has not announced major new investments or opportunities.
The DC CleanTech Tariff Tracker
Tariffs and Trade Restrictions in Effect
🇨🇦 Country: Canada
📜 Legal Authority: The White House announcement cited the International Emergency Economic Powers Act (IEEPA)
📆 Date of Entry into Force: March 4 - March 6
📈Tariff Rate: 25%, except for energy products and potash, which are tariffed at 10%
Analysis: From March 7 - April 2 the tariffs will only apply to goods that are not U.S.-Mexico-Canada (USMCA) Free Trade Agreement compliant. After April 2, the White House has threatened to broaden the tariffs to all imports.
USMCA only covers about 38% of goods from Canada. Notably, a significant portion of the automotive industry is not covered under USMCA and trades under the most favored nation import tariff of 2.5% because many of those goods do not satisfy the USMCA “rules of origin” - a standard requiring that goods made up of parts from several countries contain at least 75% North American content. Many imports likely could meet USMCA rules of origin, but companies haven’t subjected themselves to being qualified because there was no substantial penalty for not doing so. Under the March 6 actions, those imports would be assessed an additional 25% tariff.
According to a White House official, not all Canadian energy exports to the United States comply with USMCA and will therefore be hit with a 10% tariff. Canada is a major exporter of uranium to the United States. Canada also exports electricity to the Midwest and Northeast United States, and crude oil which is refined in the Midwest. This could cause energy costs to rise in those regions, adding to already higher prices sparked by increasing demand driven by an uptick in manufacturing and data center load.
Retaliation: The tariffs risk sparking a trade war with one of America’s biggest trading partners. Canada responded with retaliatory 25% tariffs on $21 billion of U.S. exports, including orange juice, peanut butter, coffee, appliances, footwear, cosmetics, motorcycles and certain pulp and paper products.
The province of Ontario threatened a 25% retaliatory tariff on the energy it exports to the United States, costing businesses and residents in Michigan, Minnesota, and New York up to $400,000 per day, but later backed down. Quebec is considering taking similar measures, which could raise power prices further across the northeast United States.
Canada has threatened a further $87 billion in tariffs in three weeks on American products like electric vehicles, fruits and vegetables, diary, beef, pork, electronics, steel and trucks.
🇲🇽 Country: Mexico
📜 Legal Authority: The White House announcement cited the International Emergency Economic Powers Act (IEEPA)
📆 Date of Entry into Force: March 7
📈Tariff Rate: 25%, except potash, which is tariffed at 10%
Analysis: The tariffs risk sparking a trade war with one of America’s biggest trading partners, which will likely have consequences across the broader economy.
From March 7 - April 2 the tariffs will only apply to goods that are not U.S.-Mexico-Canada (USMCA) Free Trade Agreement compliant. After April 2, the White House has threatened to broaden the tariffs to all imports.
USMCA only covers about 50% of goods from Mexico. According to a White House official, not all Mexican energy exports to the United States comply with USMCA and will therefore be hit with a 10% tariff. Mexico exports crude oil to the United States where it is processed at the Deer Park refinery in Texas. The import of that Mexican crude would be hit with a 25% tariff.
Retaliation: Mexico threatened to retaliate with major tariff actions prior to President Trump walked back his initial promise to tariff all Mexican imports instead of those not covered by USMCA.
🇨🇳 Country: China
📜 Legal Authority: The White House announcement cited the International Emergency Economic Powers Act (IEEPA)
📆 Date of Entry into Force: February 4
📈Tariff Rate: 20% (a 10% tariff was announced on February 4, 2025, and an additional 10% on March 4, 2025)
Analysis: The tariffs risk sparking a trade war with one of America’s biggest trading partners, which will likely have consequences across the broader economy.
China dominates the production of LFP batteries used for stationary and grid storage, as well as the markets for several critical mineral supply chains used in clean energy technologies. Prices for those technologies could increase as a result of the tariffs. Remember, these tariffs stack, so the 20% tariff will be added to the 301 Tariffs (covered below). For an EV battery that means a 70% tariff (50% under Section 301 + 20% under this IEEPA action). Domestic producers of critical minerals and solar products will likely celebrate the news, while the domestic deployment sector will be burdened by higher prices.
While China is a major solar producer, the United States imports most of its solar panels from Cambodia, Malaysia, Thailand, and Vietnam.
Retaliation: Following the February 4 announcement, China responded by leveling 15% tariffs on U.S. LNG and coal and a 10% tariff on crude oil, large cars, and pickup trucks. After the March 4 salvo, Beijing added 10- 15% tariffs against U.S. agricultural products and tightened trade restrictions on U.S. companies. China specifically listed tungsten, tellurium, bismuth, molybdenum, and indium, as well as the technologies and information related to processing and producing them. These minerals are considered critical in industrial and defense applications, solar cell manufacturing, and the semiconductor industry.
Additionally, global market participants from the EV and industrial sector report that China has weaponized its dominant position in critical mineral markets by halting global exports of graphite dating back to February, shortly after the first 10% tariff was announced. China instituted export controls on graphite in 2023, and tightend them in December 2024, but exports had continued to flow until February, 2025.
🌎 Country: Global tariffs on Steel and steel derivative products and aluminum and aluminum derivative products.
📜 Legal Authority: The Federal Register Notice (FRN) cited Section 232 of the Trade Expansion Act of 1962, as amended
📆 Date of Entry into Force: March 12
📈Tariff Rate: 25%
Analysis:
Steel: For certain derivative products the tariff does not apply if the steel is melted and poured in the United States. For certain derivative products, the tariff only applies to the value of the steel content in the article. For other derivative products (covered in 169 tariff lines listed in the Annex of the FRN) the entire 25% tariff will be applied. These include the following items used in the energy sector:
Electrical transmission towers
Windmill towers and monopiles
Steel doors for offshore wind turbines
Pressure containers used in the oil and gas sector
Parts of overhead cranes used in the oil and gas sector
This action will also raise the price of steel generally, as tariffed imports raise costs and demand increases for limited domestic steel supply.
Aluminum: For certain derivative products the tariff does not apply if the aluminum is smelted and casted in the United States. For other derivative products (covered in 124 tariff lines listed in the Annex of the FRN) the entire 25% tariff will be applied.
Aluminum foils used in lithium-ion battery manufacturing will be impacted, as will solar panel mounts, which are covered in the tariffs for derivative products. This action will raise the price of aluminum generally, as tariffed imports raise costs and demand increases for limited domestic products.
Retaliation:
🇨🇦 On March 12, 2025 Canada announced retaliatory tariffs of 25% on $20 billion of U.S. imports, including computers, sports equipment, and cast iron products, effective on March 13, 2025.
🇪🇺On March 12, 2025 the EU also announced retaliatory tariffs of 25% on $28 billion of U.S. goods. Tariffs on $8 billion of U.S. imports will enter into force on April 1st, and $20 billion of tariffs will take effect on April 13, 2025 following Member State approval. Tariffs would be assessed on steel and aluminum products, textiles, leather goods, home appliances, household tools, plastics, wood, and agricultural products.
🇨🇳 China has not announced specific actions yet, but has pledged to take “all necessary measures” to protect its interests.
🇨🇳 Country: China
📜 Legal Authority: Section 301 of the Trade Act of 1974, as amended per the Federal Register Notice
📆 Date of Entry into Force: September 27, 2024, with tariffs on semiconductors, lithium-ion non-electrical vehicle batteries, permanent magnets, tungsten, polysilicon, and wafers, and natural graphite increasing in 2025 and 2026.
📈Tariff Rate:
🚗 Electric Vehicles: 100%
🔋Lithium-ion EV batteries: 25%
🔋Lithium-ion batteries for grid and stationary storage, heavy duty transportation and other applications: 25% in 2026
🏭 Steel and aluminum: 25%: Note: These tariffs are assessed on top of the aforementioned 232 steel and aluminum tariffs.
🪨 Natural graphite: 25% in 2026
🪨 Other critical minerals: 25%
☀️Solar cells: 50%
☀️Solar wafers and polysilicon: 50% effective January 1, 2025
🪨 Tungsten: 25% effective January 1, 2025
📡 Semiconductors: 50% effective January 1, 2025
Analysis: In 2024, the Biden Administration added to the first Trump Administration’s 301 tariffs on China, with a major focus on clean tech imports, including for EVs, solar cells, lithium ion batteries, and critical minerals. The Biden Administration sought to balance supporting the domestic clean tech manufacturing sector, which it hoped would make use of Inflation Reduction Act tax credits, and the domestic clean energy deployment sector, which relies on cheap inputs from China. That explains the Administration’s decision to postpone tariffs on graphite and lithium-ion batteries used for grid and stationary storage after U.S. importers advocated for these delays arguing there were insufficient ex-China supplies available to meet demand.
EV imports from China are essentially non-existent, and the Biden Administration’s 100% tariff on Chinese EVs (which the Trump IEEPA 20% tariffs pile on top of) will ensure that remains to be the case. The biggest risk to the clean tech deployment sector is around lithium-ion batteries for stationary storage. The Biden 301 tariffs do not enter into force until 2026 for those products, but President Trump could move the implementation date forward. Despite (or perhaps because of the delay in tariffs) there is not yet sufficient ex-China supply to meet demand.
President Trump has ordered the USTR to review the Biden Administration’s 301 tariff actions and provide recommendations for any additional actions by April 1, 2025.
Retaliation: In 2024, China banned the exports of critical minerals gallium, germanium and antimony to the United States. In response to the first-term Trump 301 tariffs, China leveled tariffs against thousands of U.S. products ranging from 5-25% and including agricultural goods, coal, fuel, buses, medical equipment, machinery, textiles, and chemicals.
🇨🇳 Country: China
📜 Legal Authority: Section 201 of the Trade Act of 1974, per the Biden White House Fact Sheet
📆 Date of Entry into Force: May 2024
📈Tariff Rate: 15%
☀️ Bifacial solar panels are now tariffed at 15% under section 201. Note: This tariff stacks with the China 301 and IEEPA actions.
Analysis: The first Trump Administration imposed 201 tariffs on imported solar panels but the U.S. Court of International Trade later reinstated an exclusion of bifacial solar modules from those tariffs. The Biden Administration ended the bifacial exemption in May 2024, reinstating a 15% tariff on imported bifacial panels.
At the same time, the Biden Administration raised the tariff-rate quota (TRQ) on solar cells from China, increasing the availability of cells used by U.S. domestic panel producers, given the lack of domestically sourced alternatives.
🇨🇳 Country: China
📜 Legal Authority: Enforcement of Circumvention of Antidumping and Countervailing Duties (AD/CVD) on Solar Cells and Modules from China
📆 Date of Entry into Force: June 2024
📈AD/CVD Rates: Anywhere from 15.24%-238.95% depending on the company.
Analysis: The U.S. Department of Commerce and U.S. International Trade Commission (ITC) found that certain Chinese producers were shipping their solar products through Cambodia, Malaysia, Thailand, and/or Vietnam for minor processing in an attempt to avoid paying antidumping and countervailing duties (AD/CVD) that had been assessed on Chinese solar exports to the United States in 2015.
Given the high solar prices (due in part to covid supply chain issues) and the lack of sufficient domestic manufacturing, in June 2022 the Biden Administration announced a solar “bridge” where the anti-circumvention duties would not be enforced until June, 2024.
The ultimate impact of this action was relatively minor. Affected companies had been relocating their supply chains to produce non-circumventing solar products by the time enforcement took effect in 2024.
🇰🇭🇲🇾🇹🇭🇻🇳 Countries: Cambodia, Malaysia, Thailand and Vietnam
📜 Legal Authority: Petition by U.S. Companies for an AD/CVD investigation into Crystalline PV Cells, whether or not assembled into modules
📆 Date of Entry into Force: On October 21, 2024 Commerce announced its preliminary affirmative determination in the CVD investigation, and on November 29, 2024, Commerce announced a preliminary affirmative determination in the AD investigation.
📈AD/CVD Rates: Preliminary CVD rates range from de minimis to 292%, depending on the company and country. Preliminary AD rates range from 0% to 271% depending on the company and country.
Analysis: Unlike the anti-circumvention investigation against Chinese companies, these petitioners allege direct dumping and illegal subsidization of solar exports to the United States from the four Southeast Asian countries.
AD/CVD investigations follow a strict schedule to determine if U.S. industry is harmed by dumping (AD) or illegal subsidization (CVD) and are generally shielded from political interference. Duties are assessed against imports commensurate with the rate of illegal dumping or subsidization uncovered during the investigation. Duties can be assigned from the point of the issuance of the preliminary determination.
With the preliminary determination published, importers must issue cash deposits equal to the dumping rate for any covered goods. For example, Jinko Solar’s Vietnam subsidiary received a preliminary AD rate of 56%, so an importer would be subject to a cash deposit of $5.6 million on an order of $10 million of panels. This cash deposit is to be payable if the final determination is consistent with the preliminary determination.
Final Anti-dumping determinations are expected in April, 2025.
🇨🇳 Country: China
📜 Legal Authority: Uyghur Forced Labor Prevention Act (UFLPA)
📆 Key Dates: On June 21, 2022 the Department of Homeland Security (DHS) published the UFLPA Entity List, barring listed companies from China from exporting goods to the United States. Since then, the Entity List has been updated several times, adding dozens more companies.
Analysis: The UFLPA bars imports to the United States of goods made wholly or in part with supply chains tainted by forced labor. According to the law, any good made wholly or in part in the Xinjiang Uyghur Autonomous Region is subject to a rebuttable presumption of being tainted by forced labor due to the prevalence of forced labor against the Uyghur population there. Xinjiang is a major hub of Chinese solar, coal, mining, automotive supply chains. Many solar importers have adjusted to comply with the UFLPA, but new additions to the entity list and to the list of sectors for high priority enforcement could impact solar, critical mineral, and storage imports once again.
UFLPA entity list designations are determined by officials at the DHS, the U.S. Customs and Border Protection (CBP), and the State Department, among other departments and agencies, and may be subject to political pressure under the Trump Administration. While in the Senate, Trump Administration Secretary of State Marco Rubio called for stricter enforcement of the UFLPA to include adding battery companies CATL and Gotion, which could affect battery storage prices and attachment rates.
Tariffs Proposed and AD/CVD Investigations Initiated
🌎 Country: Global tariffs on automobiles and automobile parts
📜 Legal Authority: Section 232 of the Trade Expansion Act of 1962, per the White House Proclamation
📆 Date of Entry into Force: April 3, 2025 for automobiles, and no later than May 3, 2025 for auto parts, except for USMCA-compliant imports, which will face tariffs once Commerce establishes a process to apply tariffs to their non-U.S. content.
📈Tariff Rate: 25%
Analysis:
🚗 Will apply to imported passenger vehicles, light trucks and automobile parts (engines, transmissions, powertrain parts, and electrical components which will be defined in an Annex to the Presidential Proclamation when it is published in the Federal Register). The 2019 232 Report may provide clues though -the shortcut to its list of recommended tariff lines is available here
🇨🇦 🇲🇽 Importers under USMCA can certify their U.S. content so that the 25% tariff only applies to the value of their non-U.S. content. The White House will allow USMCA-compliant automobile parts to remain tariff-free until the Secretary of Commerce establishes a process to apply tariffs to their non-U.S. content.
💰Car prices could rise by thousands of dollars, particularly after existing inventories are exhausted. Roughly half of all vehicles sold in the United States are imported, as are nearly 60% of the parts in vehicles assembled in the United States.
🚗 For the EV sector, the move may ultimately benefit Tesla, which manufactures its vehicles for sale in the U.S. domestically, vis-a-vis its competitors like GM and Ford, which manufacture EVs in Mexico.
📅 By June 24, 2025 the Secretary of Commerce will establish a process for including additional auto parts for tariffs.
🇨🇳 Country: China
📜 Legal Authority: Petition by U.S. Companies for an AD/CVD investigation into graphite Active Anode Material from China
📆 Key Dates: On January 8, Commerce announced the initiation of the AD/CVD investigation of Active Anode Material from China. On January 31, 2025 the ITC voted to continue its investigation, ruling that the establishment of a domestic industry “is materially retarded by reason of imports of active anode material from China” that is sold in the United States at a less than fair value and subsidized by the government of China.
📈AD/CVD Rates: Commerce initiated the case with a prospective dumping margin of 823%-915%.
Analysis: Active anode material is a critical component in lithium-ion batteries. China dominates global production, controlling 100% of some processing supply chains. The CVD preliminary determination is expected on May 20, 2025, and the AD preliminary determination could come as early as May, but the deadline will likely be extended until July.
🌎 Country: Global “reciprocal tariffs”
📜 Legal Authority: Unclear
📆 Date of Entry into Force: Potentially as early as April 2
📈Tariff Rate: Unclear, but it could be anywhere from 10-25%
Analysis:
While these have been billed as “global” tariff’s, USTR appears to be targeting countries with which the United States has the largest trade deficits, including: Argentina, Australia, Brazil, Canada, China, the European Union, India, Indonesia, Japan, Korea, Malaysia, Mexico, Russia, Saudi Arabia, South Africa, Switzerland, Taiwan, Thailand, Türkiye, United Kingdom, and Vietnam.
Based on the Trump Administration Presidential Memorandum on Reciprocal Trade and Tariffs, the White House will likely apply a fixed-rate, across the board tariff on all imports from a given trading partner, aimed at rectifying trade imbalances and combatting unfair trade practices. It is likely too complicated for CBP to implement tariff changes to each HTS code for each trading partner that mirrors their tariffs on U.S. goods
President Trump threatened 10-20% universal tariffs during his campaign, so reciprocal tariffs could fall in that range. But the President also said that he would anounce a 25% tariff on EU goods “very soon”, so these rates could be higher.
USTR requested comments from the public which closed on March 11. If tariffs are announced in early April as expected, it is unlikely that USTR would have had the time to analyze and seriously address the 747 comments submitted for that decision making process.
Risks:
These tariffs could spark retaliation and a broader trade war, hurting American exporters and raising costs for U.S. consumers.
Clean tech imports including solar panels and components from Southeast Asia, battery components and materials from Japan, and EVs and batteries from South Korea could be affected.
Tariffs could also be levied on imported raw critical minerals from ally and partner countries, raising production costs for American refiners and processors.
When viewed as a single trading block, the EU is the largest exporter of goods to the United States. The 27-member region exported more than $600 billion of goods to the United States in 2024, more than China and Japan (the 3rd and 5th largest exporters to the United States) combined.
The EU has vowed to respond “firmly and immediately” by imposing retaliatory tariffs.
The EU is a major exporter of wind technology to the United States, particularly for the offshore wind, and a 25% tariff would be another blow to that sector.
🌎 Country: Global tariffs on copper imports
📜 Legal Authority: Section 232
📆 Date of Entry into Force: Unclear, but During his speech to Congress on March 5, 2025, President Trump signaled that he had already decided to level a 25% tariff on copper imports, though no official action has been announced. The deadline for Commerce to complete investigation is December 5 (could be completed prior to that date); if Commerce makes an affirmative finding, the President will determine whether he concurs and if so, take remedial action 90 days after the competition of the investigation.
📈Tariff Rate: Likely 25%
Analysis:
The tariffs would cover all forms of copper, including mined copper, copper concentrates, refined copper, copper alloys, scrap copper, and derivative product.
On February 25, 2025, President Trump signed an executive order directing Commerce to launch an investigation into how copper imports threaten America’s security and economy.
On March 13, Commerce published a request for comments from stakeholders related to the copper investigation. Responses are due April 1.
Copper is a critical mineral used in EVs, lithium-ion batteries, power generation technologies, electricity transmission and distribution, and in the oil and gas extraction sector. Tariffs on copper risk making the production of electricity and extraction of energy more expensive.
🇨🇳 Country and Sector: China Maritime Sector Tariffs
📜 Legal Authority: Section 301
📆 Key Dates: Deadline to submit comments is March 24; deadline for final action is April 17.
📈Tariff Rate: TBD
Analysis: Tariffs would cover the maritime, logistics, and shipbuilding sectors. In 2020 China controlled more than 40% of the global merchant shipbuilding market.
🇨🇳 Country and Sector: China Foundational Semiconductor Tariffs
📜 Legal Authority: Section 301
📆 Key Dates: Deadline for final action is around December 23 (action could be taken prior to that date).
📈Tariff Rate: TBD
Analysis: This investigation was launched in December 2024 at the tail end of the Biden Administration. According to a USTR statement: “Evidence indicates that China seeks to dominate domestic and global markets in the semiconductor industry and undertakes extensive anticompetitive and non-market means, including setting and pursuing market share targets, to achieve indigenization and self-sufficiency. China’s acts, policies, and practices appear to have and to threaten detrimental impacts on the United States and other economies, undermining the competitiveness of American industry and workers, critical U.S. supply chains, and U.S. economic security”.
