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 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
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
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
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
On April 29, 2025, President Trump issued a Proclamation (the “Proclamation”) amending the tariffs applicable to imports of automobiles and automobile parts. For a complete discussion on the tariffs imposed on automobiles and automobile parts, see our separate blog posts here and here.
The Proclamation issued on April 29th, amends Proclamation 10908 which first
On April 24, 2025, the U.S. Department of Homeland Security issued a notice regarding changes to the Harmonized Tariff Schedule of the United States (HTSUS) eliminating the Section 321 de minimis exemption for goods from China, which had previously permitted shipments valued at under $800 to be entered into the U.S. informally and duty-free.
The notice
On April 16, 2025, the State of California filed a complaint against President Trump, the Secretary of Homeland Security and US Customs and Border Protection (CBP) challenging the legality of tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The complaint was filed in the District Court for the Northern District of California rather