Section 232

This blog post summarizes trade regulatory developments which occurred during the week of April 19-25, 2025.  It is current up to 3:00 pm PT on Friday, April 25, 2025.  Any developments occurring after that time will be covered in next week’s update.  Please continue to check Husch Blackwell’s First 100 Days of Trade series for

On April 23, 2025, the Trump Administration issued a pre-publication federal register notice scheduled to be published on April 25, 2025. The notice seeks public comments following the April 22, 2025, initiation of an investigation targeting imports of medium-duty trucks, heavy-duty trucks, and medium- and heavy-duty truck parts, and their derivative products (collectively, “trucks and

On April 15, 2025, President Trump directed the Secretary of Commerce to initiate an investigation under Section 232 of the Trade Expansion Act of 1962 examining the threats to national security from imports of processed critical minerals and derivative products.  

The latest Section 232 investigation follows the Trump Administration’s April 1, 2025 initiation of

On April 14, 2025, the Trump Administration issued two federal register notices scheduled to be published on April 16, 2025. The notices seek public comments following the April 1, 2025 initiation of investigations targeting imports of pharmaceuticals and semiconductors pursuant to Section 232 of the Trade Expansion Act of 1962. The Trump administration claims that imports of semiconductors and pharmaceuticals are a threat to national security.

On April 8, 2025 U.S. Customs and Border Protection (“CBP”) issued a Cargo Systems Messaging Service (“CSMS”) Message # 64680374which sets forthadditional guidance on the reporting of reciprocal tariffs set to take effect on April 9, 2025. This guidance is an update to CSMS # 64649265 previously issued on April 4, 2025.

The President 

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

On April 2, 2025, President Trump published the Annex of automobiles and automobile parts subject to tariffs pursuant to Section 232 of the Trade Expansion Act of 1962.  This follows the President’s March 26, 2025 Proclamation announcing the forthcoming 25% tariffs on certain vehicles and related parts, which we previously reviewed here.  This Annex

On March 26, 2025, President Trump, pursuant to Section 301 of the Trade Act of 1974 (19 U.S.C. § 2411), as amended, and Section 232 of the Trade Expansion Act of 1962 (19 U.S.C. § 1862) issued a Proclamation titled Adjusting Imports of Automobiles and Automobile Parts Into The United States. The Proclamation is being issued under Section 232 to protect U.S. national security interests and under Section 301, which allows for the United States Trade Representative (USTR) to investigate and respond to unfair trade practices of foreign countries, including allowing for the imposition of tariffs.

On March 24, 2025, President Trump, pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) (“IEEPA”), the National Emergencies Act ((50 U.S.C. 1601 et seq.), and section 301 of title 3, United States Code, issued an Executive Order (the “EO”) titled Imposing Tariffs on Countries Importing Venezuelan Oil.

As previously reported, on February 10, 2025, President Trump issued Proclamations 10895 and 10896, making significant changes to the existing measures imposed on imports of aluminum and steel on national security grounds pursuant to Section 232 of the Trade Expansion Act of 1962.  Among other changes, the Proclamations added to the list of so-called “derivative”