A Federal Reserve analysis finds that the gap between U.S. tariffs announced in 2025 and the rates actually paid by importers is almost twice the size of the gap seen during the 2018‑2019 tariff rise. The study, published in the FEDS Notes, compares the effective tariff rate (ETR) with the realized effective tariff rate (RETR) across the two episodes. By December 2025 the ETR had climbed 12.37 percentage points, while the gap to the RETR was 5.43 points – about 44 % of the increase, versus 0.44 points (22 %) in 2018‑2019. Both composition changes and rate‑discrepancy factors, such as front‑loading and shipment timing, explain the larger gap. The 2025 tariffs were also more evenly distributed across partners, reflected in a lower concentration index (HHI 0.06 versus 0.29).
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