On March 3, 2025, the Department of Commerce (Commerce) released advanced Federal Register notices providing modifications to the Harmonized Tariff Schedule of the United States (HTSUS) in order to implement the steel and aluminum tariffs announced by the President on February 10, 2025. Our prior update on these tariffs and the products affected are
Customs Provides Guidance on New Tariff Subheadings Applicable to Canada and Mexico Tariffs, De Minimis Treatment Will Temporarily Remain Available
On March 3, 2025, U.S. Customs and Border Protection (Customs) issued two notices providing guidance on the implementation of the previously announced tariffs on imports from Canada and Mexico. The notices also provide the
On March 1, 2025, President Trump issued an Executive Order directing the U.S. Department of Commerce (“Commerce”) to initiate a Section 232 investigation into imports of timber, lumber, and their derivative products. This is the same law that was used to impose additional tariffs on imports of steel, aluminum, and their derivative products.
The full
This blog post covers trade developments occurring during the sixth week of the new Trump Administration. It covers events occurring through 12:00 pm Eastern time on Friday, February 28.
Import-Related Developments
Potential Retaliation for Global Digital Services Taxes
After we published our Week Five in Trade post last week concerning additional sector-specific import tariffs
On Friday, February 21, 2025, President Trump issued a National Security Presidential Memorandum (“NSPM”) titled “America First Investment Policy” which directed multiple federal agencies to take action to further restrict foreign adversaries’ ability to invest in sensitive United States businesses and to further restrict United States outbound investments into China. The Trump Administration also issued a Fact Sheet to accompany the NSPM.
This week, President Trump indicated that he was considering imposing additional import tariffs on goods from specific sectors. The trade press reported that President Trump has identified the auto, pharmaceuticals and semiconductor sector for import tariffs of as high as 25% and previewed that such tariffs may go into effect as early as April 2, 2025.
Tariff News
Aluminum and Steel Orders
Earlier, we discussed President Trump’s proclamations on aluminum and steel imports, which raised the tariff rate to 25 percent on imports of aluminum and steel (and certain derivatives thereof) under Section 232 of the Trade Expansion Act of 1962 (as amended, 19 U.S.C. 1862). Last week’s proclamations also removed
On February 14, 2025, the White House released Annex I of the February 10, 2025 Proclamations expanding the Section 232 duties to cover certain additional derivative products of steel and aluminum. The additional derivative products are identified by Harmonized Tariff Schedule of the United States (“HTSUS”) code in each annex.
As discussed in our
On Thursday, February 13, 2025, President Trump signed a memorandum entitled “Reciprocal Trade and Tariffs.” The memorandum stopped well short of immediately imposing a tariff regime and instead directs the Secretary of Commerce and the United States Trade Representative (USTR), in consultation with other Executive Branch departments and agencies, to take actions to investigate the
On Monday, February 10, 2025, President Trump signed Proclamations imposing 25 percent on all imports of steel and increasing the duty rate from 10 to 25 percent for all imports of aluminum into the United States pursuant to Section 232 of the Trade Expansion Act of 1962, as amended (19 U.S.C. 1862). Drawback will not