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
Week Twenty-Two in 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
Week Twenty in Trade
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
Amendment to Imports of Aluminum and Steel Increases 232 Tariffs to 50%
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 Sixteen and Seventeen in Trade
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
Week Seventeen in Trade
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
CBP Issues Guidance on Prioritization of Articles “Subject to” More Than One Tariff Under EO 14289
On May 15, 2025, U.S. Customs and Border Protection (“CBP”) issued further guidance via the Cargo Systems Messaging Service (“CSMS”) for determining the order in which the various tariffs will apply to an article when that article is subject to more than one of the tariff actions identified in Executive Order (“EO”) 14289 (90
CBP Confirms Goods on “Feeder” Vessels Not Eligible for “In-Transit” Reciprocal Tariff Exception
On May 15, 2025, U.S. Customs and Border Protection (“CBP”) published an FAQ stating that the “in-transit” exception for the reciprocal tariff duty rate does not apply to goods loaded onto a “feeder” vessel prior to April 5 (the IEEPA cutoff date under HTSUS 9903.01.28) or April 9 (the IEEPA cutoff date under HTSUS 9903.01.43
Week Fifteen in Trade
- The Executive Order applies retroactively to merchandise effected by the Section 232 Automobile and Auto Parts Tariffs,
Customs Clarifies That “In Transit” Exemption Only Applies to Ocean Vessels
On April 30th, U.S. Customs and Border Protection (“Customs”) clarified in its International Emergency Economic Powers Act Frequently Asked Questions that the “in transit” exemption from reciprocal tariffs provided for in the Executive Order for goods in transit as of April 5th or April 9th applies only to ocean vessels. Customs stated the following:
The