In the last week, President Trump has threatened "secondary" tariffs in three distinct scenarios. While this is the first time that the Administration has used the term "secondary" tariffs, the terminology is likely intended to mirror that used in the sanctions context and, as with "secondary" sanctions, appears designed to be another mechanism by which the U.S. Administration could impose economic costs against third countries based on their alleged dealings with targets of U.S. sanctions.
Concrete Action Against Venezuela: On March 24, 2025, President Trump issued an Executive Order, authorizing the imposition of a 25% tariff on all goods imported into the United States from any country determined to be importing Venezuela crude oil or petroleum products extracted, refined, or exported from Venezuela on or after April 2, 2025.
The U.S. Department of Commerce, in coordination with the U.S. Departments of State and Justice will determine which country has imported Venezuelan oil (which includes indirect imports through third parties, as can be reasonably traced back to Venezuela). Commerce will be responsible for issuing regulations, guidance, and determinations to implement the order.
However, it will be the U.S. Department of State, in consultation with the U.S. Departments of the Treasury, Commerce, and Homeland Security, and the Office of the U.S. Trade Representative ("USTR") that will decide whether or not to impose the 25% tariff on a particular country. Once the tariff is imposed, it will expire one year after the country last imported Venezuelan oil, or at an earlier date, if determined by Commerce in consultation with the U.S. Departments of State, Treasury, Homeland Security, and the USTR. This tariff would be in addition to any other tariffs already imposed on the specific country or product, such as existing duties imposed under IEEPA and Sections 232 and 301.
Based on publicly available information in a 2024 brief published by the U.S. Energy Information Administration ("EIA"), two of the largest importers of Venezuelan oil are China and India, making them potential targets of further tariffs.
As of the date of this blog post, none of the U.S. Department's of Commerce, State, and Justice have publicly identified any countries that import Venezuelan oil.
Russia: On March 30, President Trump threatened to impose secondary tariffs on Russian oil, specifically noting that it would be a 25-50% tariff on goods from countries that buy oil from Russia. President Trump explained that he would impose such a tariff within a month, if (a) Russia is unable to agree to a ceasefire in Ukraine and (b) the White House believes that failure is attributable to Russian action (or inaction). No further details were shared.
A 2024 brief published by EIA explains that the largest importers of Russian oil are China, India, Turkey, and a handful of Eastern EU members (i.e., Hungary, Slovakia, and Czech Republic). Importers of petroleum products from Russia are much more diversified to include locations such as Singapore, Brazil, and the United Arab Emirates.
Iran: Also on March 30, President Trump threatened to impose secondary tariffs on Iranian oil, by imposing tariffs on goods from countries that buy oil from Iran. He provided even fewer details on these potential tariffs, other than the decision to impose them would depend on whether the Iranian government would negotiate a nuclear agreement with the United States.
The 2024 EIA brief on Iran explains that China is the largest importer of Iranian oil by significant margins (89% of all sales), with the remaining purchases from Syria, the UAE, and Venezuela.
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