2025

CBP Issues Facility Requirements for Bonded Warehouses

In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do not include container freight stations, inspectional facilities, express consignment facilities, etc., and therefore are not authorized for acceptance of Type 21/22

On May 15, 2025, U.S. Customs and Border Protection (“CBP”) issued further guidance via the Cargo Systems Messaging Service (“CSMS”) for determining the order in which the various tariffs  will apply to an article when that article is subject to more than one of the tariff actions identified in Executive Order (“EO”) 14289 (90

On May 15, 2025, U.S. Customs and Border Protection (“CBP”) published an FAQ stating that the “in-transit” exception for the reciprocal tariff duty rate does not apply to goods loaded onto a “feeder” vessel prior to April 5 (the IEEPA cutoff date under HTSUS 9903.01.28) or April 9 (the IEEPA cutoff date under HTSUS 9903.01.43

On May 11, 2025, the U.S. announced that it had reached an agreement with China to mutually reduce tariffs against each country for 90 days. The reduced rates, discussed below, will take effect for goods entered on or after May 14, 2025. The reduced rates will not be retroactive and will only apply to entries effective May 14, 2025, and forward.

The U.S. Department of Commerce (“Commerce”) has initiated an investigation to determine the effects on the national security of imports of commercial aircraft and jet engines, and parts for commercial aircraft and jet engines. Comments are due by June 3. Commerce has specifically requested comments on the following:

(i) the current and projected demand for

CBP Clarifies Exemption from Reciprocal Tariffs for Steel and Aluminum Articles Subject to Section 232 Duties

In its FAQs, U.S. Custom and Border Protection (CBP) clarified the exemption from reciprocal tariffs for goods subject to steel/aluminum Section 232 duties under HTSUS 9903.01.33. CBP clarified that the exemption only applies if the Section 232 duties

On May 8, 2025, the United States and the United Kingdom announced a new “trade agreement”. The Fact Sheet issued by the White House, can be found here. The Office of the United States Trade Representative has released the Agreements in Principle, which indicate that the terms of trade agreement are still a