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
On April 29, 2025, President Trump issued a Proclamation (the “Proclamation”) amending the tariffs applicable to imports of automobiles and automobile parts. For a complete discussion on the tariffs imposed on automobiles and automobile parts, see our separate blog posts here and here.
The Proclamation issued on April 29th, amends Proclamation 10908 which first
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