IEEPA

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 May 11, 2025, the U.S. announced that it had reached an agreement with China to mutually reduce tariffs against each country for 90 days. The reduced rates, discussed below, will take effect for goods entered on or after May 14, 2025. The reduced rates will not be retroactive and will only apply to entries effective May 14, 2025, and forward.

On April 29, 2025, President Trump issued an Executive Order clarifying the calculation methods that should be used for certain imports subject to the various tariffs implemented since February 2025. The EO sets out a procedure for determining which of the multiple tariffs should apply to an article and when multiple tariffs currently apply. Importantly

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

U.S.-China Trade War Intensifies

On April 8, 2025, President Trump issued an Executive Order raising the reciprocal tariff rate on Chinese imports from 34% to 84%. This move followed his earlier warning that the U.S. would impose a 50% increase unless China withdrew its 34% retaliatory tariffs on American goods.

China swiftly responded by matching

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

President Trump Issues Universal Reciprocal Tariff and Higher Individualized Rates for Certain Countries

On April 2, 2025, President Trump issued an Executive Order (“EO”) imposing a 10% universal tariff on imports from all countries (with certain exceptions) pursuant to the International Emergency Economic Powers Act of 1977 (“IEEPA”).  These tariffs will take effect at 12:01

As reported in our prior update on April 2, President Trump issued an Executive Order (“EO”) imposing sweeping tariffs on a broad range of imports from virtually all trading partners. 

The text of the EO references two annexes.  According to Sections 2 and 3(a) of the EO, Annex I sets forth the country-specific reciprocal tariff