First 100 Days of Trade

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 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 U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule that automatically applies Entity List and Military End User (“MEU”) List restrictions to any entity that is 50% or more owned by one or more listed entities, MEUs, or other sanctioned parties. This IFR will be known as the

President Trump has issued a proclamation under Section 232 of the Trade Expansion Act of 1962 (“Section 232”) that sets October 14, 2025 as the effective date for Section 232 tariffs on softwood timber and lumber, upholstered wooden furniture, kitchen cabinets and vanities.  

Imports of softwood timber and lumber will face a 10% ad

On September 25, 2025, the U.S. Court of Appeals for the Federal Circuit (“CAFC”) issued its decision upholding tariffs imposed during President Trump’s first administration pursuant to Section 301 on goods imported from China. Specifically, the CAFC held that Section 301 Lists 3 and 4A tariffs were appropriate and a valid use of the government’s

On September 25, 2025, the U.S. Department of Commerce and the Office of the U.S. Trade Representative issued a notice implementing various changes pursuant to the recent US-European Union trade deal. Retroactive to August 1, 2025, automobiles and automobile parts with a most-favored nation (MFN) rate of 15% or higher, will still be subject to

The U.S. Court of Appeals for the Federal Circuit issued its decision in VOS Selections Inc. v. United States where the plaintiffs challenged the validity and legality of the Trump administration’s tariffs instituted under the International Emergency Powers Act (IEEPA). The full panel of circuit judges who heard oral argument on July 31, 2025, affirmed the Court of International Trade’s earlier decision that while IEEPA grants the executive “authority to ‘regulate’ imports” it “does not authorize the tariffs imposed by the Executive Orders. The majority opinion was issued by Judge Lourie who was joined by six other Circuit Judges, with additional views provided by four judges, and a dissent led by the remaining four judges on the panel.