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Jonathan Wang is an associate in the Governmental Practice in the firm's Washington D.C. office.

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The CIT held that the imposition of the tariffs exceeded the authority granted to the President by Congress under IEEPA. The Court issued a permanent injunction blocking the administration from enforcing the IEEPA tariffs, and ordered the administration to issue the necessary administrative orders within 10 days to end them. In response, the government appealed the case to the U.S. Court of Appeals for the Federal Circuit.Continue Reading Federal Court Strikes Down IEEPA Tariffs

This week, underscoring a commitment to national security, the White House and the Food and Drug Administration (FDA) issued separate communications that aim to bolster domestic drug manufacturing while tightening oversight of foreign facilities. But they also raise questions about implementation, industry impact, and long-term effects. This is another step from the Department of Commerce Bureau of Industry and Security’s (BIS) Section 232 investigation into pharmaceuticals initiated on April 1, 2025. These developments, while unsurprising, should be viewed within the constellation of broader administration policy, and could make real progress on furthering the manufacturing onshoring agenda for the critical life sciences industry.Continue Reading Onshoring Pharma Ops: Reading Recent EO and Policy Tea Leaves

The implementation of new 25% Section 232 duties on steel, aluminum, and certain derivatives, effective March 12, 2025, which are in addition to any special rate of duty otherwise applicable, are affecting importers globally. Here is a breakdown of what these new tariffs entail:Continue Reading Overview of Section 232 Tariffs on Steel and Aluminum: What Importers Need to Know

On April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment (SME), and related products to evaluate how those imports may impact national security.Continue Reading Who is Stacking the Chips: U.S. Commerce Department Launches Section 232 Investigation into Semiconductor Imports

On April 2, President Trump issued an Executive Order (EO) imposing global reciprocal tariffs (White House Fact Sheet). The EO drew enough parallels to the Smoot-Hawley Tariff Act that Trump mentioned it in his Rose Garden announcement. The EO imposes a 10% baseline tariff on all imports to the United States beginning April 3, 2025.Continue Reading Blockading the Ports: U.S. Imposes 10% Global Tariff; Higher Reciprocal Tariff Rates by Country

UPDATE: On February 5, 2025, the Trump administration issued an executive order delaying the cancellation of de minimis until “adequate systems are in place to fully and expediently process and collect tariff revenue applicable”. Imports from China below the value of $800 will generally not be subject to the 10% tariff or Section 301 duties.Continue Reading The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)

You have always dreamed of going to space. All of us have at some point or another. And the only thing standing between you and that dream were overly-restrictive commodity and technology export licensing requirements on certain space items to specified countries! (well, that, and gravity, and the fact that you are not a billionaire[1], and maybe a few other things).Continue Reading Ticket to Ride – The Commercial Space Activity Exception and Space Tourism: Reduced Export Controls Ease Cross-Border Collaborations (Part IV of IV)

In a land before time (technologically speaking . . . so, like, the mid-nineties), the most basic software encryption functions were controlled under the U.S. International Traffic in Arms Regulations. The then-current version of Netscape or Lotus Notes (the hot tech of the era) were controlled under the same regulatory regime as missiles and fighter jets. Then, in 1996, an executive order moved encryption to commercial export controls and freed up the software industry to flourish into its current, omnipresent state.Continue Reading The Commercial Industry Gets More Space: Reduced Export Controls Ease Cross-Border Collaborations (Part II of IV)