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
On October 8, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule adding 29 total entries to the Entity List, including 26 entities and three addresses. The entities and addresses are located in China (19 entries), Turkey (9 entries), and the United Arab Emirates (“UAE”) (1 entry) and
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule that automatically applies Entity List and Military End User (“MEU”) List restrictions to any entity that is 50% or more owned by one or more listed entities, MEUs, or other sanctioned parties. This IFR will be known as the
On September 17, 2025, the Bureau of Industry and Security (“BIS”) announced via an interim final rule that it is now accepting requests to include additional auto parts under Section 232 tariffs. According to the notice, the initial submission window for the requests will open on October 1, 2025, and will remain open for 14 days. Following this period, BIS will conduct a 60-day review to evaluate all inclusion requests.
On September 15, 2025, the Bureau of Industry and Security (“BIS”) announced via a Federal Register notice that it is now accepting requests to include new products under Section 232 tariffs on steel and aluminum derivatives.
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
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
On May 22, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released a diverse list of 58 requests for new products to be added to the list of derivatives subject to the Section 232 tariffs on steel and aluminum products. Details about the process for requesting inclusion of Section 232 derivatives were
CBP Issues Facility Requirements for Bonded Warehouses
In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do not include container freight stations, inspectional facilities, express consignment facilities, etc., and therefore are not authorized for acceptance of Type 21/22
The Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective April 30, 2025 establishing the process for additional products to be added to the list of steel and aluminum derivatives subject to tariffs under Section 232 of the Trade Expansion Act (“Section 232”).
BIS stated it will accept inclusion requests