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Department of Energy Seeks Input for the 2026 Energy Critical Materials Assessment

The Department of Energy’s Request for Information seeks input for the 2026 Energy Critical Materials Assessment (CMA), which will identify materials critical for energy based on two primary factors: importance to energy and...more

U.S. Tariffs on Non-USMCA-Compliant Products Take Effect; Increased Tariff Rate on China Imposed

Between March 4, 2025, and March 6, 2025, U.S. trade policy in North America changed course multiple times as the Trump administration initially implemented previously paused tariffs on imports from Canada and Mexico, and two...more

The Trump Administration Reinstates and Expands Section 232 Tariffs on Steel and Aluminum

On February 10, 2025, President Trump issued two Presidential Proclamations reimposing and expanding tariffs on all steel and aluminum imports into the United States pursuant to Section 232 of the Trade Adjustment Act of...more

CBP’s Region-Wide WRO Escalates Pressure in China’s Xinjiang Region

On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more

U.S. Expands WROs in Xinjiang, Targeting Major Cotton Producer with Implications for Global Supply Chains

On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more

World Trade Organization Panel Finds Section 301 Tariffs on Chinese Products Violate WTO Rules, but Decision Unlikely to Have...

On September 15, 2020, a World Trade Organization (“WTO”) panel found that the Trump Administration’s unilateral tariffs imposed on Chinese products violated WTO rules regarding nondiscrimination and import tariff rates...more

U.S. Government Moves to Block Imports from Xinjiang, Triggering Due Diligence Challenges for Companies

On September 14, 2020, U.S. Customs and Border Protection (CBP) issued five Withhold Release Orders (WROs) for a range of goods produced in the Xinjiang region of China.  Under 19 U.S.C. § 1307, CBP can initiate enforcement...more

The United States No Longer Considers Hong Kong Autonomous from China, Setting the Stage for Rule Changes that Could Disrupt Trade...

Since the handover of Hong Kong by the United Kingdom to China in 1997, Hong Kong has enjoyed separate treatment from the mainland by the United States, other countries and international organizations pursuant to the “one...more

6/1/2020  /  China , Export Controls , Hong Kong , Imports

Treasury and CBP Temporary Rule on 90-Day Deferment for Payment of Certain Duties

On April 19, 2020, the Treasury Department in conjunction with Customs and Border Protection (CBP) released a temporary interim final rule (“Rule”) to provide importers that meet the qualifying criteria with the option of a...more

USTR Launches New Exclusion Request Procedure to Address COVID-19

On Friday, March 20, 2020, in an effort to fight against the coronavirus pandemic, the U.S. Trade Representative (USTR) announced that it is accepting exclusions requests to remove tariffs imposed on Chinese origin...more

Department of Commerce Publishes Regulations Allowing it to Impose Punitive Duties on Products from Countries with Undervalued...

On February 3, 2020, the Department of Commerce published a final rule that amends the regulations for countervailing duty investigations to allow the imposition of duties on countries that undervalue their currencies....more

DHS’s New Criminal Enforcement Initiative to Prosecute Corporations for Forced Labor

Criminal investigations will target businesses profiting from the importation into the United States of goods made using forced labor. The new criminal enforcement initiative seeks to leverage data about corporate supply...more

Trump Administration To Impose Tariffs on List 4 Products

On September 1, a new round of Section 301 duties will be imposed on “List 4” products.  President Trump previously announced plans for these duties, but had delayed implementation in June citing progress on the negotiations...more

Slavery in Supply Chains: CBP Petitions Raise New Forced Labor Compliance Risks

Third-party petitions seeking to ban the importation of goods made with forced labor may affect global supply chains. Petitions are being filed with U.S. Custom and Border Protection seeking to ban the importation into the...more

The Trump Administration Initiates a Tariff Exclusion Process for Chinese Imports Provided in List 3

On May 21, the Office of the United States Trade Representative (USTR) established a process through which U.S. stakeholders may exclude products included in List 3 from a 25% tariff imposed pursuant to the investigation of...more

USTR Issues Proposed Tariff List on Nearly $300 Billion of Chinese Goods

Further to our prior blog post, on May 13, 2019, at the direction of President Trump, the Office of U.S. Trade Representative (“USTR”) published a proposed tariff list covering approximately $300 billion worth of Chinese...more

Further Escalation of Trade War: Trump Administration Raises Tariffs on Chinese Products

On May 9, 2019, the Office of the United States Trade Representative (USTR) issued a Federal Notice indicating that tariffs on $200 billion worth of Chinese imports would be increased from 10% to 25%. ...more

U.S. Customs and Border Protection Takes Action Against Fishing Vessel Under Forced Labor Import Ban

On February 4, 2019, U.S. Customs and Border Protection (“CBP”) issued a withhold release order (“WRO”) against tuna and tuna products from the Tunango No. 61, a Taiwanese vessel, based on information obtained by CBP that...more

The Trump Administration Further Escalates Tariffs on Chinese Products

June 15, 2018 – U.S. proposes an additional 25 percent ad valorem duty on products from China (818 tariff categories) with an annual trade value of approximately $34 billion. The $34 billion action became effective on July 6,...more

Tariff Wars Escalate: USTR Announces Tariff Increases on a Wide Range of Chinese Products and China Responds with Tariffs on US...

Following President Trump’s direction in connection with the Section 301 investigation into China’s acts, policies and practices related to intellectual property, on June 15, 2018, the Office of U.S. Trade Representative...more

Car Wars: Trump Administration Opens Section 232 Investigation into Imports of Autos and Auto Parts

On May 23, 2018, as directed by President Trump, the Secretary of Commerce initiated a Section 232 investigation into whether imports of automobiles, including SUVs, vans, light trucks and automotive parts, threaten to impair...more

Trump Administration Takes Action Following Section 301 Investigation

President Trump issued a memorandum (“Memorandum”) directing his Administration to take several actions related to the investigation by the Office of U.S. Trade Representative (“USTR”) into China’s acts, policies, and...more

Department of Commerce Outlines Process for Product-Exclusions from Steel and Aluminum Tariffs

Pursuant to President’s Trump’s March 8, 2018 proclamations issued under authority of Section 232 of the Trade Expansion Act of 1962, added customs tariffs on imports of a wide variety of steel and aluminum imports from all...more

Trump Administration Imposes Steep Tariffs on Steel and Aluminum Imports

On March 8, 2018, President Trump signed proclamations authorizing the imposition of a 25 percent customs duty on certain steel products and a 10 percent customs duty on certain aluminum products. The duties were imposed...more

CBP Takes Measures to Enforce Ban on Imports Made With Forced Labor and Sanctions for Forced North Korean Labor in Supply Chains

On November 22, 2017, Apple, Inc. (“Apple”) released a statement confirming reports that its major supplier in China, Foxconn Technology Group (“Foxconn”) has used illegal student labor to assemble the latest version of the...more

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