February 2025

This blog post covers trade developments occurring during the sixth week of the new Trump Administration. It covers events occurring through 12:00 pm Eastern time on Friday, February 28. 

Import-Related Developments

Potential Retaliation for Global Digital Services Taxes

After we published our Week Five in Trade post last week concerning additional sector-specific import tariffs

On February 26, 2025, the U.S. Chassis Manufactures Coalition (“Coalition” or “Petitioner”), filed a petition for the imposition of antidumping and countervailing duties on U.S. imports of certain chassis and subassemblies thereof from Mexico, Thailand, and the Socialist Republic of Vietnam.  

SCOPE OF THE INVESTIGATION

The merchandise covered by these investigations consists of chassis

On Friday, February 21, 2025, President Trump issued a National Security Presidential Memorandum (“NSPM”) titled “America First Investment Policy” which directed multiple federal agencies to take action to further restrict foreign adversaries’ ability to invest in sensitive United States businesses and to further restrict United States outbound investments into China. The Trump Administration also issued a Fact Sheet to accompany the NSPM.

This week, President Trump indicated that he was considering imposing additional import tariffs on goods from specific sectors. The trade press reported that President Trump has identified the auto, pharmaceuticals and semiconductor sector for import tariffs of as high as 25% and previewed that such tariffs may go into effect as early as April 2, 2025.

Tariff News

Aluminum and Steel Orders

Earlier, we discussed President Trump’s proclamations on aluminum and steel imports, which raised the tariff rate to 25 percent on imports of aluminum and steel (and certain derivatives thereof) under Section 232 of the Trade Expansion Act of 1962 (as amended, 19 U.S.C. 1862). Last week’s proclamations also removed

On February 14, 2025, the White House released Annex I of the February 10, 2025 Proclamations expanding the Section 232 duties to cover certain additional derivative products of steel and aluminum.  The additional derivative products are identified by Harmonized Tariff Schedule of the United States (“HTSUS”) code in each annex. 

As discussed in our

On Thursday, February 13, 2025, President Trump signed a memorandum entitled “Reciprocal Trade and Tariffs.”  The memorandum stopped well short of immediately imposing a tariff regime and instead directs the Secretary of Commerce and the United States Trade Representative (USTR), in consultation with other Executive Branch departments and agencies, to take actions to investigate the

On February 12, 2025, the Ad Hoc MDI Fair Trade Coalition (“Coalition” or “Petitioner”), filed a petition for the imposition of antidumping duties on U.S. imports of Methylene Diphenyl Diisocyanate (“MDI”) from the People’s Republic of China (“China”).

SCOPE OF THE INVESTIGATION

The following language describes the imported merchandise from China:

The merchandise subject to

On Monday, February 10, 2025, President Trump signed Proclamations imposing 25 percent on all imports of steel and increasing the duty rate from 10 to 25 percent for all imports of aluminum into the United States pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862).  Drawback will not