October 2025

On October 26, 2025, President Trump announced trade deals with Cambodia and Malaysia. Under both deals, the US will maintain a 19% ad valorem rate on goods originating from Cambodia and Malaysia. However, certain products originating from Cambodia and Malaysia will be exempt from the 19% ad valorem rate as provided for in Schedule 2 to the Cambodia agreement and Schedule 2 to the Malaysia agreement.

U.S. Launches Section 301 Investigation into China’s Phase One Trade Agreement Compliance

On October 24, 2025, U.S. Trade Representative Jamieson Greer announced the launch of a Section 301 investigation into China’s implementation of its commitments under the phase one trade agreement, which was singed on January 15, 2020, in response to the U.S. imposing up to 25% in Section 301 duties.

On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the immediate imposition of full blocking sanctions pursuant to Executive Order (“E.O.”) 14024 against Russian oil companies PJSC Lukoil Oil Company (“Lukoil”) and PJSC Rosneft Oil Company (“Rosneft”), along with over two dozen of their subsidiaries, for operating

USTR Imposes 100% Tariffs on Ship-to-Shore Cranes Under Section 301

Effective November 9, 2025, the United States will impose additional duties of 100% on certain ship-to-shore (“STS”) cranes and certain cargo handling equipment from China under Section 301 of the Trade Act of 1974. These tariffs follow the Office of the U.S. Trade Representative (“USTR”)’s original proposal in April 2025.

On October 8, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule adding 29 total entries to the Entity List, including 26 entities and three addresses. The entities and addresses are located in China (19 entries), Turkey (9 entries), and the United Arab Emirates (“UAE”) (1 entry) and

The Commerce Department’s Bureau of Industry and Security (“BIS”) published over 90 requests for the inclusion of additional HTSUS subheadings to the list of steel and aluminum derivative products subject to Section 232 tariffs of 50%.

On September 17, 2025, BIS announced a two-week window where parties could submit requests to include additional products to

As of October 1, 2025, the U.S. Government has shut down as a result of the budget impasse in Congress. While essential services such as law enforcement remain operational, many departments have had to furlough staff and suspend non-critical functions.

For international trade-related operations, the impact varies by agency. Critical functions tied to national security—such