Supply Chain

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

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.

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

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.

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

On September 4, 2025, President Trump, using his authority under the International Emergency Economic Powers Act (“IEEPA”), issued an executive order (“EO”) titled, Implementing The United States–Japan Agreement, to implement the trade agreement with Japan on July 22, 2025. The EO establishes a15% tariff on the majority of Japanese imports, notably including automobiles and auto parts that have previously been central to U.S.–Japan trade tensions. Under the EO, all Japanese automobiles and auto components entering the United States will face a minimum 15% tariff, unless their current tariff rate is already at or above that level, in which case no additional duties will be imposed. The EO also provides for targeted exemptions for aerospace products, certain natural resources, and generic pharmaceuticals, which will be subject to zero tariffs. These tariffs are retroactively applied to goods imported for consumption from August 7, 2025, onward.

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.

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