Tariffs & Trade

Updated CSMS Guidance on Steel and Derivatives

One June 24, 2025 CBP published updated guidance via a CSMS Message on Section 232 tariffs, correcting the number for preexisting HTSUS subheading 9903.81.98. The change effects steel or iron derivative items imported from the United Kingdom.

Additionally, the CSMS Message added certain steel imports in Chapters 84

The Ninth Circuit Court of Appeals in Island Industries v. Sigma Corp., upheld a lower court jury determination that an importer of welded pipe fittings is liable for $8 million in unpaid antidumping duties under the False Claims Act (“FCA”). The penalty under the FCA is trebled totaling the liability to over $32 million for importer Sigma Corp. 

CBP Deploys Portal for Forced Labor Allegations

On June 20, 2025, U.S. Customs and Border Protection (“CBP”) announced it is deploying the Forced Labor Allegation Portal, which allows users to submit forced labor allegations. Submissions may be made anonymously and may include Allegations may be submitted supporting documents related to their submissions.

U.S. Steel and

On June 17, 2025, the two importers who filed a lawsuit in U.S. District Court challenging President Trump’s authority to issue tariffs under the International Emergency Economic Powers Act (“IEEPA”) petitioned the Supreme Court to hear their case instead of waiting for a ruling from the Court of Appeals.

The two companies, Hand2Mind and Learning

On June 16, 2025, President Trump issued an Executive Order setting a 7.5% Section 232 tariff on U.K.-origin cars which are imported under the 100,000 quota, per the announced trade deal with the U.K. Combined with the current most-favored nation status duty, the total duties and tariffs on U.K.-origin vehicles imported under the quota will

Effective June 28, 2025, importers of derivative downstream products incorporating aluminum known should report “unknown” in lieu of the International Organization for Standardization (ISO) code when the country of smelt and cast is not known, per CSMS guidance published by U.S. Customs and Border Protection (“CBP”).

CBP’s CSMS states that, when reporting “unknown” for the

On June 10, 2025, the United States Court of Appeals for the Federal Circuit (“Federal Circuit”) stayed the Court of International Trade’s (“CIT”) permanent injunction on the Trump Administration’s executive orders instituting tariffs pursuant to the International Emergency Economic Powers Act (“IEEPA”) pending the appeal of the case. The Federal Circuit judges stated in the

On June 3, 2025, President Trump issued a Proclamation (“the Proclamation”) increasing the Section 232 duties on imports of aluminum and steel from 25% to 50%. The Proclamation states that the previously imposed steel and aluminum tariffs “have not yet enabled these industries to develop and maintain the rates of capacity production utilization that are

Week Seventeen

CIT Unequivocally Strikes Down IEEPA Tariffs as Invalid

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT), in a unanimous decision, held tariffs imposed by the Trump Administration pursuant to the International Emergency Economic Powers Act of 1977 (IEEPA) to be unlawful and invalid. The CIT’s order