On February 23, 2026, U.S. Customs and Border Protection (“CBP”) published a CSMS containing additional guidance on the 10% duties imposed by the President pursuant to Section 122 of the Trade Act of 1974 (“Section 122”) against all imports from all countries (see February 20, 2026 Executive Order “Imposing a Temporary Import Surcharge”).
President Trump Announces Higher Tariff Rates Effective August 1st
After announcing an extension of the reciprocal tariff rates from July 9, 2025, to August 1,2025, President Trump published letters which were sent to various countries indicating the tariff rate the United States will impose on that country’s imports if the country does not enter
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 April 9, 2025, President Trump issued an Executive Order titled “Modifying Reciprocal Tariff Rates to Reflect Trading Partner Retaliation and Alignment”, increasing the reciprocal tariff rates for China to 125%. Importantly, country-specific reciprocal rates for 83 countries that took effect on April 9, 2025, have been paused for a period of 90
On April 8, 2025, President Trump, acting under the authority of the International Emergency Economic Powers Act of 1977 (“IEEPA”), issued an Executive Order (“EO”) titled “Amendment to Reciprocal Tariffs and Updated Duties as Applied to Low-Value Imports from the People’s Republic of China.” The EO modifies the previous April 2, 2025 Executive Order by