CBP

Relations between the countries of the United States of America USA and JAPAN represented by the concept of two flags waving against a cloudy sky.3d render.

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.

On August 11, 2025, the Trump Administration issued an executive order extending the 10% IEEPA reciprocal tariffs on goods from China for an additional 90 days until November 10, 2025. The higher country specific tariffs were originally paused on May 14, 2025, and were set to escalate to 34% on August 12, 2025. The pause…

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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…

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…

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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…

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…

roll of steel sheet in factory

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…

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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…

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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…

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…