On 24 March 2025, President Trump issued an Executive Order imposing a 25 percent tariff on all goods imported into the United States from any country that imports Venezuelan oil, whether directly or indirectly. The 25 percent tariff will be implemented on or after 2 April 2025, and will be in addition to the duties already imposed pursuant to the International Emergency Economic Powers Act (“IEEPA”), section 232 of the Trade Expansion Act of 1962, section 301 of the Trade Act of 1974, or any other authority.
The list of countries subject to the Venezuelan oil tariff has not yet been released. The President has authorized the Secretary of State, in consultation with the Secretary of the Treasury, the Secretary of Commerce, the Secretary of Homeland Security, and the United States Trade Representative, to determine which are the “offending” countries. However, the Executive Order specifically indicated that, if the Secretary of State decides to impose the tariff on “China, that tariff shall also apply to both the Hong Kong Special Administrative Region and the Macau Special Administrative Region, as a measure to reduce the risk of transshipment and evasion”.
The Executive Order defines the following terms:
- “Venezuelan oil” means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.
- The term “indirectly” includes purchases of Venezuelan oil through intermediaries or third countries where the origin of the oil can reasonably be traced to Venezuela, as determined by the Secretary of Commerce.
Major Importers of Venezuelan Oil
According to the Country Analysis Brief issued by the US Energy Information Administration on 8 February 2024, APAC (69 percent) accounted for the greatest share of Venezuelan crude oil imports in 2023, with China having the lion’s share of 68 percent (Singapore import share was 0.5% while Malaysia’s was 0.3 percent).1 Spain/EU and Cuba each accounted for 4 percent.
It is important to recognize that in this ever-changing environment, the below is subject to the Department of State’s final decision:
- China, the total additional tariffs on China’s imports to the US will be 79 percent (54 percent plus 25 percent Venezuelan oil tariff);
- Malaysia, the total additional tariffs on Malaysian imports to the US will be 49 percent (24 percent plus 25 percent Venezuelan oil tariff);
- Singapore, the total additional tariffs on Singapore’s imports to the US will be 35 percent (10 percent plus 25 percent Venezuelan oil tariff).
The current additional tariff on the EU is 20 percent. If Spain is listed, the total additional tariffs on Spanish imports to the US will be 45 percent (20 percent plus 25 percent Venezuelan oil tariff). However, it is uncertain if the 25 percent Venezuelan oil tariff will be extended to all EU imports. This would mean that Malaysia and Spain/EU may potentially face additional duties close to top of the US reciprocal tariffs, in the company of Cambodia (49 percent), Lao DPR (48 percent), Vietnam (46 percent) and Sri Lanka and Myanmar (44 percent).
While the list of impacted countries has yet to be released, companies may want to monitor developments in this area closely.
We understand this is an evolving situation and we will continue to provide updates to help you navigate the complexities of global trade. If you have any questions regarding this Alert, please reach out to PSA BDP’s Global Trade Management team:
Angie Alleva - Global Head, angie.alleva@psabdp.com
Paul Leong - Head, APAC, paul.leong@psabdp.com
Lisa Quetsch - Director, Americas, lisa.quetsch@psabdp.com
Wong Chian Voen - Director, APAC & Export Controls, chianvoen.wong@psabdp.com
Brittany Ford - Regional Lead (EU/UK), brittany.ford@psabdp.com
PSA BDP is not providing legal advice and does not assume liability for detrimental reliance on the information provided herein as conditions are subject to rapid change. The calculations herein are based on current conditions and assumptions. Please consult with your counsel regarding specific tariffs.
