First 100 Days of Trade

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.

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Canada to Exempt CUSMA-Origin U.S. Goods from 25% Retaliatory Tariffs Starting September 2025—Steel, Aluminum, and Autos Still Excluded

On August 27, Canada announced that, effective September 1, 2025, U.S. goods certified as CUSMA (USMCA) qualifying will be exempt from the country’s 25% retaliatory tariffs. This decision follows a similar exemption implemented by the United States…

On August 11, 2025, the Trump Administration issued an executive order extending the 10% IEEPA reciprocal tariffs on goods from China for an additional 90 days until November 10, 2025. The higher country specific tariffs were originally paused on May 14, 2025, and were set to escalate to 34% on August 12, 2025. The pause…

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The Trump Administration announced in an executive order that it will institute and impose an additional 25% on imports of goods with a country of origin India effective August 27, 2025 to address India’s imports of Russian oil. The administration instituted these additional tariffs as India purchased Russian oil and the executive order states that the Commerce Secretary, Treasury Secretary and Secretary of State “shall determine whether any other country is directly or indirectly importing Russian Federation oil,” and “shall recommend whether and to what extent I should take action as to that country, including whether I should impose an additional ad valorem rate of duty of 25 percent on imports.”

On July 30, 2025, President Trump issued a Presidential Proclamation announcing the imposition of a fifty percent (50%) tariff on “all imports of semi-finished copper products and intensive copper derivative products” as set forth in the Annex to the Proclamation. The tariff is effective “with respect to goods entered for consumption, or withdrawn from warehouse…

On July 30, 2025, President Trump issued an Executive Order, suspending the duty-free de minimis treatment for imports from all countries to address national emergencies related to illicit drug trafficking and trade deficits. The suspension will take effect starting August 29, 2025. President Trump had previously suspended the duty-free de minimis treatment for Mexico…

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On July 30, 2025, President Trump issued an Executive Order pursuant to the International Emergency Economic Powers Act (“IEEPA”) imposing an additional forty percent (40%) ad valorem rate on certain products from Brazil. This rate shall be in addition to the existing ten percent (10%) tariff rate currently imposed on goods from Brazil.

The Executive…

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On July 27, 2025, President Trump announced that the U.S. and European Union (“EU”) have reached a trade deal. Pursuant to the Fact Sheet released by the White House on July 28th, the U.S. will impose a 15% tariff on all EU goods, including auto parts, pharmaceuticals, and semiconductors. The Fact Sheet further stated that…