tariffs

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 12, 2025, President Trump issued an Executive Order (“EO”) Clarification of Exceptions Under Executive Order 14257 of April 2, 2025, as Amended, which expanded the list of Harmonized Tariff Schedule of the United States (“HTSUS”) codes exempted from the reciprocal tariffs that were announced on April 2, 2025. The exemptions apply retroactively to goods

On April 2, 2025 we reported that imports from China valued at $800 or less would no longer qualify for de minimis treatment starting May 2, 2025. On April 9, 2025 we reported the increase in tariffs and fees for imports of small value packages from China following issuance of Executive Order Amendment to Reciprocal

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 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 

On April 5, 2025, U.S. Customs and Border Protection (“CBP”) issued guidance through the Cargo Systems Messaging Service (“CSMS”) that duty drawback is available for the 10% universal baseline tariffs that take effect on April 5, 2025.

The CSMS stated CBP will issue separate guidance for the country-specific tariffs that take effect April 9, 2025.

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

Commerce Department Establishes Standard Policy for Questionnaire Extensions in AD/CVD Proceedings

The Department of Commerce issued a new policy to create uniform filing deadline extensions in antidumping duty and countervailing duty proceedings. Overall, the policy will decrease the amount of time received in extension requests for initial and supplemental questionnaires. The specific policy updates include

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.