International Emergency Economic Powers Act

On February 6, 2026, President Trump signed an executive order, Addressing Threats to the United States by the Government of Iran, which authorizes the imposition of tariffs on goods imported from any country that “directly or indirectly purchases, imports, or otherwise acquires goods or services from Iran.” The order is effective at 12:01 a.m.

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

Husch Blackwell sent an update on this development on February 3. Read our legal update to discover the latest regarding President Trump’s tariffs on Canada, Mexico, and China.

In response to the tariffs imposed by President Trump on Canada, Mexico, and China on February 1, 2025 under the International Emergency Economic Powers Act (IEEPA), each