New Executive Order creates a national-emergency-based system to impose additional tariffs on U.S. imports from countries that supply oil to Cuba.

1. What changed

• The President signed an Executive Order (EO) on January 29, 2026, declaring a national emergency with respect to threats posed by the Government of Cuba.
• The EO establishes a new tariff system that authorizes the United States to impose additional tariffs on U.S. imports from any country that directly or indirectly sells or otherwise provides oil to Cuba.
• The EO authorizes the Secretary of State and the Secretary of Commerce to take all necessary actions, including issuing rules and guidance, to implement this tariff system and related measures.
• The President retains authority to modify the EO if Cuba or affected countries take significant steps to address the identified threat or align with U.S. national security and foreign policy objectives.

At this stage, the EO creates the legal framework for new tariffs but does not itself specify:

• Which countries are covered;
• Which HTS codes or product categories will be targeted; or
• The specific additional duty rates or effective dates for particular products.

2. Affected products and scope

Current status:

• The EO is country- and behavior-based (countries that provide oil to Cuba), not product-specific in the text provided.
• No explicit HTS subheadings, Chapter 99 provisions, or product lists are identified yet.

Likely structure once implemented (based on similar national-security tariff regimes such as Sections 232 and 301):

• Affected products will likely be defined by:
• Country of origin: countries determined by the U.S. Government to be directly or indirectly providing oil to Cuba; and
• HTS classification: specific tariff subheadings or broad chapters to which additional duties will apply.
• Implementation may use:
• Chapter 99 HTS provisions to apply additional duties on top of normal MFN or preferential rates; and/or
• Country-specific additional duty lines similar to Section 301 lists.

Industries potentially at risk (depending on which countries are designated):

• Any sector with significant sourcing from countries that export or transship oil to Cuba (e.g., energy-linked economies).
• This could include, for example, machinery, electronics, consumer goods, automotive parts, metals, textiles, or agricultural products, depending on the designated countries’ export profiles.

Because no specific countries or HTS codes are yet named, importers cannot map exact product exposure at this time, but should:

• Identify key supplier countries that are known or likely to export oil to Cuba; and
• Prepare for the possibility that imports from those countries may face additional duties via new Chapter 99 provisions.

3. Rate changes

• The EO authorizes “additional tariffs” on imports from countries that provide oil to Cuba but does not specify numerical duty rates.
• There is no explicit change yet to:
• Column 1 General MFN rates;
• Existing Section 232, 301, or 201 rates; or
• Existing ADD/CVD rates.

Expected future developments:

• Implementing regulations or Federal Register notices could:
• Establish specific additional ad valorem or specific duty rates (e.g., +10%, +25%); and
• Create new Chapter 99 HTS numbers to apply those rates.

Until those implementing measures are issued, there is no concrete old→new rate comparison available.

4. Dates and timelines

• EO signing date: January 29, 2026.
• National emergency: Declared as of the EO date; this provides the legal basis for trade measures.
• Effective date of tariffs: Not specified in the text provided. Actual tariff application will depend on:
• Subsequent determinations of which countries are covered; and
• Issuance of implementing rules, guidance, or Federal Register notices by State, Commerce, and likely USTR and CBP.
• Modification/termination: The President may modify the EO if Cuba or affected countries take “significant steps” to address the threat or align with U.S. objectives. No fixed sunset date is indicated.

Key implication: As of the information provided, the EO creates authority but does not yet impose specific, dated tariff lines. Importers must watch for follow-on regulatory publications that will set effective dates for particular products and countries.

5. Required actions for importers, brokers, and compliance teams

Immediate actions (strategic and monitoring):

1) Regulatory monitoring

• Closely monitor:
• Federal Register notices from the Departments of State and Commerce for implementing rules;
• Announcements from USTR and CBP regarding:
• New Chapter 99 provisions;
• Country lists; and
• Product/HTS coverage.
• Track White House and State Department press releases for identification of countries deemed to be providing oil to Cuba.

2) Supply chain risk assessment

• Identify current and planned sourcing from countries that:
• Are known exporters of crude oil or refined petroleum products; and
• Have political or commercial ties with Cuba’s energy sector.
• Map your import volumes, HTS codes, and duty spend by these countries to estimate potential exposure if additional tariffs are imposed.

3) Contract and pricing review

• Review purchase contracts and Incoterms for imports from potentially affected countries to determine:
• Who bears responsibility for increased duties;
• Whether price-adjustment or duty-sharing clauses exist; and
• Whether renegotiation or diversification is needed.

4) Scenario planning

• Model potential additional duty scenarios (e.g., +10%, +25% surcharges) on imports from high-risk countries.
• Prepare contingency sourcing options from alternative countries that are unlikely to be implicated in oil supply to Cuba.

Actions once implementing rules are issued:

1) HTS and Chapter 99 coding

• Update internal classification databases and broker instructions to:
• Add any new Chapter 99 numbers required to declare additional duties; and
• Ensure correct pairing of base HTS codes with new additional-duty provisions.

2) Entry and system updates

• Coordinate with customs brokers and IT/ERP teams to:
• Update tariff tables and landed-cost models with new rates;
• Ensure ACE/ABI filings capture any new country- and product-specific requirements; and
• Validate that entries from designated countries are correctly flagged and assessed.

3) Compliance documentation

• Maintain documentation demonstrating:
• Country of origin and production for imported goods;
• Supply chain structure (especially if transshipment or complex routing is involved), in case CBP scrutinizes imports from countries linked to Cuba’s oil supply.

4) Internal communication

• Brief procurement, finance, and sales teams on:
• The new authority to impose tariffs tied to oil supply to Cuba;
• Potential cost impacts; and
• The need to factor possible surcharges into pricing and budgeting.

6. Relationship to other trade measures

• The EO is framed as a national security and foreign policy measure, similar in legal posture to Section 232 actions, but it is a distinct mechanism focused on countries that provide oil to Cuba.
• It does not directly modify existing:
• Section 232 steel/aluminum tariffs;
• Section 301 tariffs on China or other countries;
• Section 201 safeguard measures; or
• ADD/CVD orders.
• However, implementation may follow similar patterns (e.g., use of Chapter 99, country- and product-specific lists, staged implementation, and possible exclusions or waivers).

7. References and where to find further details

Note: The exact EO number and implementing documents are not provided in the text. Importers should look for:

• White House Fact Sheet (source of this summary):
• Fact Sheet: “President Donald J. Trump Addresses Threats to the United States by the Government of Cuba” (January 29, 2026)
• White House website main page for statements and fact sheets: https://www.whitehouse.gov

• Executive Order text:
• Once published, the EO will typically be available as a PDF on:
• White House: https://www.whitehouse.gov/presidential-actions/
• Federal Register: https://www.federalregister.gov

• Implementing regulations and guidance:
• Department of State: https://www.state.gov
• Department of Commerce: https://www.commerce.gov
• U.S. Trade Representative (for any trade list coordination): https://ustr.gov
• U.S. Customs and Border Protection (for operational and HTS/Chapter 99 guidance): https://www.cbp.gov

Importers should obtain and review the full EO and any subsequent Federal Register notices to confirm:

• The list of countries determined to be providing oil to Cuba;
• The specific HTS codes and Chapter 99 provisions affected;
• The additional duty rates and effective dates; and
• Any exclusions, licensing, or waiver mechanisms that may be available.

8. Practical next steps checklist

• Monitor: Set alerts for “Cuba,” “oil,” “tariffs,” and “national emergency” on the Federal Register and White House sites.
• Map exposure: Identify imports by country that could be implicated based on known or likely oil trade with Cuba.
• Prepare systems: Ensure your classification and customs systems can quickly incorporate new Chapter 99 lines and additional duty rates.
• Engage brokers: Inform customs brokers of potential upcoming measures and agree on a process to rapidly implement new coding and duty calculations.
• Review contracts: Confirm who bears the cost of any new tariffs and whether renegotiation or diversification is needed.

This EO is immediately relevant for trade compliance because it creates a new legal basis for additional tariffs on U.S. imports, but concrete product- and rate-level impacts will only be known once implementing rules and lists are published.