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International Trade & Supply Chain Law: Download Our 2025 Year in Review & 2026 Outlook
Weekly Trade Update: November 17-21, 2025
Tariff Evasion Enforcement Continues To Be A Top Priority for DOJ and CBP
Recent developments highlight a coordinated, aggressive approach by the U.S. Government to crack down on schemes that undermine U.S. trade laws.
An Indonesian jewelry company, UBS Gold, its co-owner, and two employees were charged with conspiring to evade over $86 million in U.S. customs duties on jewelry imports. Two individuals were arrested and face up to 20 years in prison for wire fraud conspiracy, while UBS Gold faces fines up to $500,000 or twice the gain.
U.S. Modifies Tariffs on Brazilian Imports
On November 20, 2025, the White House issued an Executive Order marking a significant shift in U.S. trade policy toward Brazil. This action updates the measures originally imposed under Executive Order 14323 from July 30, 2025, which had established a 40% additional ad valorem duty on certain Brazilian goods under the International Emergency Economic Powers Act (IEEPA) due to concerns over Brazil’s policies and practices impacting U.S. national security and foreign policy.
BIS Suspends “Affiliates Rule” for One Year Following U.S. Agreement with China
The U.S. Commerce Department’s Bureau of Industry and Security (BIS) has issued a final rule which will suspend BIS’s recently enacted Affiliates Rule effective as of November 10, 2025 and continuing through November 9, 2026. The Trump Administration committed to make this change as part of its Deal on Economic and Trade Relations with China
Trump Reduces IEEPA Fentanyl Tariffs to 10% Effective November 10; Continues Suspension of Heightened Reciprocal Tariff Rate
Following the U.S. and China trade meetings last week, President Trump issued an Executive Order reducing the rate of fentanyl-related tariffs on China from 20% to 10%, effective November 10, 2025. These tariffs were originally imposed under the International Emergency Economic Powers Act (“IEEPA”) on February 1 and March 3, 2025 to address China’s failure to alleviate the influx of synthetic opioids into the U.S.
Commerce Integrates European Union Tariff Exemptions into the HTS; Auto Tariff Deal Retroactive to August 1, 2025
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
Update Regarding Tariffs on Steel and Aluminum Derivatives: BIS Opens Second Round of Product Inclusion Requests
On September 15, 2025, the Bureau of Industry and Security (“BIS”) announced via a Federal Register notice that it is now accepting requests to include new products under Section 232 tariffs on steel and aluminum derivatives.
Japanese Tariff Reductions to Begin September 16, 2025
On September 15, 2025, the U.S. Department of Commerce issued a Federal Register notice announcing that new tariff reductions on imports from Japan—including automobiles, auto parts, civil aircraft, and certain other goods—will take effect beginning September 16, 2025. These measures implement the U.S.-Japan trade agreement, which was finalized on July 22, 2025, and formalized by Executive Order 14345 signed on September 4, 2025. Please see our previous post here for more details on the U.S.-Japan deal.
BIS Makes 32 Additions to the Entity List
On September 12, 2025, the Bureau of Industry and Security (BIS) published a final rule announcing additions to the Entity List. 32 new entities across China, India, Iran, Singapore, Taiwan, Turkey, and the United Arab Emirates (UAE) have been added to the Entity List due to activities deemed contrary to U.S. national security or foreign
Presidential Executive Order Modifying Reciprocal Tariffs and Tariff Exceptions – Effective September 8, 2025
- Annex II as announced on April 2,