Supply Chain

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

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

On July 23, 2025, the Coalition of Freight Coupler Producers (“Petitioners”), filed a petition for the imposition of antidumping duties on U.S. imports of Certain Freight Rail Couplers and Parts Thereof from the Czech Republic and the Republic of India and countervailing duties on the Republic of India.

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Commerce Initiates Section 232 Investigation On Drones and Polysilicon from China

On July 16, 2026, the U.S. Department of Commerce launched new Section 232 investigations on imports of Chinese drones and polysilicon. Drones and polysilicon are both currently subject to additional tariffs of 55% and 80%, respectively. The new investigations aim to assess whether