- Annex II as announced on April 2,
Presidential Executive Order Modifying Reciprocal Tariffs and Tariff Exceptions – Effective September 8, 2025
Trump Finalizes Japan Trade Deal With 15% Tariffs
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.
Federal Circuit Finds IEEPA Fentanyl and Reciprocal Tariffs Illegal But Continue to Be Required at Time of Entry
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.
Updates for the Week of August 25, 2025 Related To Tariffs
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
The US and EU Reach A Trade Deal—EU Goods Subject to 15% Tariff
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
Week Twenty-Six in Trade
EU Prepares Retaliation List If Trade Deal is Not Reached
On July 24, 2025 the European Commission voted to impose retaliatory tariffs of €93 billion on U.S. goods if a trade deal is not reached between the United States and European Union. The tariffs will be effective August 7, 2025. The tariffs include €21billion on
Petition Summary: Certain Freight Rail Couplers and Parts Thereof from the Czech Republic and the Republic of India
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.
SCOPE OF THE INVESTIGATION
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Week Twenty-Five in Trade
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
Petition Summary: Crystalline Silicon Photovoltaic Cells, Whether or Not Assembled Into Modules, from the Republic of India, the Republic of Indonesia, and the Lao People’s Democratic Republic
On July 17, 2025, the Alliance for American Solar Manufacturing and Trade (“the Alliance”), filed a petition for the imposition of antidumping and countervailing duties on U.S. imports of crystalline silicon photovoltaic cells whether or not assembled into modules (“c-Si PV cells and modules”) from the Republic of India (“India”), the Republic of Indonesia (“Indonesia”)
Special Provisions Go Into Effect for UK Autos, Auto Parts and Civil Aircraft Products Under the United States – U.K. Economic Prosperity Deal
On June 30, 2025, the U.S. Department of Commerce published in the Federal Register a notice to modify the Harmonized Tariff Schedule of the United States (HTSUS) to conform with General Terms of the United States of America-United Kingdom Economic Prosperity Deal (Executive Order 14309) with respect to automobiles, automobile parts, civil aircraft