Trump Administration

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 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

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 Issues Facility Requirements for Bonded Warehouses

In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do not include container freight stations, inspectional facilities, express consignment facilities, etc., and therefore are not authorized for acceptance of Type 21/22

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 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.

The Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective April 30, 2025 establishing the process for additional products to be added to the list of steel and aluminum derivatives subject to tariffs under Section 232 of the Trade Expansion Act (“Section 232”).

BIS stated it will accept inclusion requests