Last night, the president announced agricultural exceptions to Brazil-specific tariffs. This followed similar reciprocal tariff cuts last week for beef, coffee, and other goods in a nod to growing concerns about the affordability of everyday items. TPC estimates that these and other recently announced changes to US tariff policy bring the average tariff rate to 17.6 percent. 

Given the volatility of American tariff policy, we’ve also made some innovations to our modeling approach. TPC’s new “tariff engine” calculates the tariff rate on each product, from each country, by day. In a single year, that’s 120 million tariff rates for just one policy, or ten billion tariff rates for all policies across two years.

This allows us to account for each tariff policy’s exceptions—and to answer what might seem a simple question: “What is the tariff rate on this import?”

Why is this so difficult?

It might seem straightforward: a good’s tariff rate at any given moment. But consider, as one importer explained in June, how their product could still face a 55 percent total tariff rate even after a widely heralded trade deal with China. 

There are three overlapping complications: Stacking, exemptions, and timing. Take medical face masks from China.

Many tariff rates stack, or add on top of each other. Since Nov. 10, imports from China face a 10 percent minimum reciprocal tariff (applied to all countries without a country-specific reciprocal tariff), plus an additional International Emergency Economic Powers Act (IEEPA) tariff of 10 percent. 

If no other tariff policies applied, importers could conclude the total tariff rate has increased by 20 percentage points. 

But other policies do apply: Face masks from China are subject to both a 7.5 percent and a 25 percent tariff (that add on top of each other and other policies) under Section 301—a completely different statutory authority than IEEPA. 

Complications don’t end there. Because face masks and other personal protective equipment are under a 270-day-long Section 232 investigation, they may qualify for exemption from all reciprocal tariffs. 

And starting Jan. 1, 2026, the 25 percent Section 301 tariff grows to 50 percent with expanded coverage of N95 respirators. Then by November, the 34 percent reciprocal rate for China will replace the minimum reciprocal tariff, while that additional 10 percent IEEPA tariff will rise to 20 percent. 

That’s at least four changes in one year. 

How does TPC’s tariff rules engine work?

TPC’s tariff rules engine addresses all of those complexities. The engine precisely considers interactions between the coverage of policies like Section 232, Section 301, reciprocal tariffs, and other IEEPA tariffs. For example, since June, Section 232 tariffs, except for those on copper, have replaced IEEPA tariffs on Canada in instances where both can apply.

The rules engine accounts for nearly half a million interactions to determine all tariffs on a single day. TPC then validates results with over 70 tests, before estimating the revenue and burden of tariffs with rates on almost 20,000 goods from over 200 trading partners.

What can ten billion tariff rates tell us? 

Figure 1 shows the average tariff rate over time, using these fine-grained data. The US paused reciprocal tariffs for all countries except China on April 9, and it raised China’s country-specific rate high enough to leave the US average tariff rate unchanged. Tariff rates have been inching up again since June, almost returning to levels reached on April 2 that triggered a stock market rout.

FIGURE 1

Figure 2 shows how the composition of tariffs has changed. Compared to April 2, Section 232 tariffs have increased in rate and in their share of total tariffs. The bulk of these tariffs is imposed on steel and aluminum derivatives. Because Section 232 tariffs apply only to specific goods, they have a larger effect on distorting the relative prices of goods. These tariffs would remain even if the Supreme Court strikes down the Trump administration’s IEEPA tariffs.

FIGURE 2

The TPC tariff rules engine also reveals the effects of trade deals and exemptions on specific products. On Nov. 13, President Trump expanded exceptions to reciprocal tariffs to agricultural goods, reducing tariff rates on select goods by at least 10 percentage points each. This was compounded when the president announced similar exceptions to the 40 percent IEEPA tariff on Brazilian goods. Figure 3 illustrates these changes. The average tariff rates on beef, bananas, coffee, and tea are now between 2 to 6 percent.

FIGURE 3
 

As broad tariffs shrink in importance and industry-specific, or sectoral, tariffs take on a larger role, the effects of tariffs on the economy will become even more complicated. 

Taxing different goods will have distributional implications for households, since consumers buy different goods depending on their incomes. Businesses will feel these changes too, because sectoral tariffs increase the costs of investing in some types of equipment and materials but not others. 

The layered complexity of tariffs can increase uncertainty and production costs for any importing business. The business either risks facing a surprise tariff rate or must spend time and resources deciphering the Harmonized Tariff Schedule. 

TPC’s tariff rules engine enables more precise and relevant insights into an ever-changing economy. You can see it in action regularly at TPC’s tariff tracker.