The 2025 framework
In October 2025, the Office of the Uniteed States Trade Representative announced that it had concluded a framework for ART. Under the framework, Thailand will remove tariffs on 99 percent of goods, and the US will keep a 19 percent reciprocal tariff on Thai imports while identifying certain products eligible for a zero rate. Thailand committed to easing non-tariff barriers. These commitments include accepting vehicles built to US safety and emissions standards and recognising US FDA approvals for medical devices and pharmaceuticals. The framework also covers digital trade, intellectual property, labour and environmental standards.
A changed tariff landscape in 2026
The legal basis for US tariffs has shifted during the year. On 20 February 2026, the US Supreme Court ruled against the reciprocal tariffs that had been imposed under the International Emergency Economic Powers Act (IEEPA), which meant the 19% rate stopped applying. A temporary 10% tariff under Section 122 of the Trade Act followed.
On 24 July 2026, that temporary tariff was replaced by a 12.5% Section 301 tariff on most Thai imports. USTR imposed it on grounds that Thailand had not imposed and effectively enforced a ban on imports of goods made with forced labour. Countries that already ban such imports, or that have reciprocal trade agreements with the US, pay a lower rate of 10%. Neighbouring countries with signed trade agreements with the US, such as Cambodia and Malaysia, are in that 10% group. Separately, the US is also looking into Thailand’s “excess capacity” in export sectors including electronics, rubber and machinery.
Deal signing expected soon
On 7 October 2026, Prime Minister Anutin Charnvirakul said Thailand is about to conclude the agreement. The Prime Minister said that Thailand expects to sign an agreement during President Trump’s next trip to Asia, probably in November around the ASEAN meetings.
What this means for businesses
- Exporters to the US: Look at your actual duty exposure product by product. The 12.5% applies on top of the MFN rate for each product’s tariff classification, and certain goods are exempt. Once the final agreement is published, check whether it changes Thailand’s rate.
- Supply chains and origin: US authorities are enforcing rules against transshipment more strictly. Manufacturers must keep tract of developments in product rules of origin with respect to products exported to the US and assess whether their goods substantially originate in Thailand.
- Importers of US goods: Lower Thai tariffs and fewer regulatory barriers may create opportunities for Thai importers, particularly in agriculture, energy, automotive, healthcare and digital services.
- Compliance: Expected reforms in labour law, intellectual property and digital trade may affect how businesses operating in Thailand comply with regulations.
The final text of the agreement will determine the details. Grant Thornton Thailand is following developments closely and can help businesses assess tariff exposure, origin compliance and the related tax and regulatory implications.
