On July 16, 2025, the U.S. Department of Commerce published a Federal Register notice soliciting public comments on an investigation into the national security impacts of imported unmanned aircraft systems (UAS or drones) and...more
On July 16, 2026, the U.S. Department of Commerce launched new Section 232 investigations on imports of Chinese drones and polysilicon. Drones and polysilicon are both currently subject to additional tariffs of 55% and 80%,...more
The Department of Commerce (Commerce) has launched two additional Section 232 investigations covering unmanned aircraft systems (UAS), their parts and components, and of polysilicon and its derivatives. President Trump is...more
On July 14, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) announced the initiation of investigations into the effects on US national security of (i) imports of polysilicon and its derivatives, and...more
On July 9, President Trump told a group of reporters that a 50% tariff on all copper imports was imminent....more
On July 14, 2025, the Commerce Department announced new investigations initiated by the Secretary of Commerce on July 1, 2025, pursuant to Section 232 of the Trade Expansion Act of 1962. The pre-publication Federal Register...more
Section 232 tariffs on steel and aluminum have been in effect since 2018, during the first Trump administration. Until recently, importers had been able to file exclusion requests at the U.S. Department of Commerce’s Bureau...more
Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more
Section 232 Investigation Ends with 50% Duties on Copper - On Tuesday, July 8, President Trump told reporters that he would soon announce a 50% tariff on copper—the result of a Section 232 Investigation into U.S. copper...more
President Trump Announces Higher Tariff Rates Effective August 1st- After announcing an extension of the reciprocal tariff rates from July 9, 2025, to August 1,2025, President Trump published letters which were sent to...more
Uncertainty around the reciprocal tariffs continues to abound as President Trump has extended the deadline for the imposition of the country-specific reciprocal tariffs while at the same time notifying certain countries of...more
The Trump Administration recently took two major steps as to tariffs on steel and aluminum and their derivative products. First, on May 1, 2025, the Commerce Department announced the issuance of an interim final rule (“IFR”)...more
On July 7, President Trump began sending letters to select U.S. trading partners informing them of new “reciprocal” tariff rates that will be effective Aug. 1. These letters update the rates that the recipient country was...more
The evolving U.S. tariff regime under President Donald Trump has had and likely will continue to have profoundly impacts on commercial contracts. Commercial actors are evaluating their contractual commitments to determine the...more
In the final days of May, decisions in two significant court actions — V.O.S. Selections Inc. v. U.S. and Learning Resources Inc. v. Donald Trump — affected the tariff and trade landscape. If the courts' rulings are not...more
What Are Section 232 Investigations? Section 232 investigations are a tool the U.S. government uses to determine the effect of certain imports on national security. These investigations are conducted under the Trade Expansion...more
One June 24, 2025 CBP published updated guidance via a CSMS Message on Section 232 tariffs, correcting the number for preexisting HTSUS subheading 9903.81.98. The change effects steel or iron derivative items imported from...more
As of June 19, 2025, U.S. import tariffs vary widely depending on the product and country of origin. Goods from China face layered duties, including Section 301 tariffs ranging from 7.5% to 100% (with electric vehicles hit...more
Businesses engaged in international trade are struggling with a wave of uncertainty arising from recent shifts in U.S. tariff policy. Each day’s news cycle is peppered with stories about the Trump administration’s aggressive...more
On June 16, 2025, President Trump issued an Executive Order setting a 7.5% Section 232 tariff on U.K.-origin cars which are imported under the 100,000 quota, per the announced trade deal with the U.K. Combined with the...more
Effective June 28, 2025, importers of derivative downstream products incorporating aluminum known should report “unknown” in lieu of the International Organization for Standardization (ISO) code when the country of smelt and...more
On February 10, 2025, President Trump issued two Proclamations announcing the reinstatement of the 25% tariff on all steel imports and the reinstatement and increase of tariffs on aluminum imports to 25% pursuant to Section...more
In a notice dated June 12, 2025, the Department of Commerce, Bureau of Industry and Security announced that it is adding 11 new HTS subheadings to the list of derivative products subject to the 50% Section 232 steel tariffs...more
With the rising importance of trade compliance programs, it is important to start with the law. (Spoken like a true lawyer). The U.S. relies on two powerful tariff tools — Section 301 and Section 232 tariffs. Relying on...more
The White House issued a Fact Sheet and Proclamation addressing Section 232 tariff actions on February 10, 2025. These steps strengthen President Trump’s 2018 tariff actions on steel and aluminum imported into the United...more