- Annex II as announced on April 2,
Presidential Executive Order Modifying Reciprocal Tariffs and Tariff Exceptions – Effective September 8, 2025
Week Twenty-Three in Trade
De Minimis Exemption to End
The House and Senate passed the tax bill, which includes a provision to end the de minimis exemption for all e-commerce effective July 1, 2027. The bill now goes to the President for his signature. The de minimis exemption currently allows imports at or under $800 in value to enter
Amendment to Imports of Aluminum and Steel Increases 232 Tariffs to 50%
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 Sixteen and Seventeen in Trade
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
Court of International Trade Unequivocally Declares IEEPA Tariffs to be Unlawful
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 covers IEEPA tariffs imposed against Canada, Mexico and China related
CBP Confirms Goods on “Feeder” Vessels Not Eligible for “In-Transit” Reciprocal Tariff Exception
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
Summary of Tariff Requirements Updated: May 14, 2025
- Goods with Country of
Week Fifteen in Trade
- The Executive Order applies retroactively to merchandise effected by the Section 232 Automobile and Auto Parts Tariffs,
Week Twelve in Trade – First 100 Days of the New Administration
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