On December 23, 2025, the U.S. Trade Representative (USTR) announced new tariffs on Chinese semiconductors under Section 301 of the Trade Act of 1974. Notably, the USTR set the initial rate of these tariffs at 0%. This will increase on June 23, 2027 to a rate that will be announced in the future.Continue Reading Blank Slate or Bargaining Chip?: Additional Section 301 Tariffs on Chinese Semiconductors Set for June 2027
Capping off a highly eventful week in Asia at the end of October, President Donald J. Trump has further reshaped the landscape of U.S. trade with the Asia-Pacific region through a series of new agreements. This latest round of negotiations includes new reciprocal trade deals and market access commitments across Cambodia, Thailand, Malaysia, Vietnam, China, South Korea, and Japan. Some of these agreements build upon the foundation laid by Executive Order 14346 (Sept. 5, 2025). That order provided for zero percent tariffs on products listed in Annex III, once a qualifying trade deal was announced.[1] With some agreements now in place, Annex III of the EO is being actively implemented.Continue Reading Shifts in U.S. Trade in Asia: Key Agreements from President Trump’s October 2025 Asia Trip – Part II: East Asia
Capping off a highly eventful week in Asia, President Donald J. Trump has further reshaped the landscape of U.S. trade with the Asia-Pacific region through a series of new agreements. This latest round of negotiations includes new reciprocal trade deals and market access commitments across Cambodia, Thailand, Malaysia, Vietnam, China, South Korea, and Japan. Some of these agreements build upon the foundation laid by Executive Order 14346 (Sept. 5, 2025). That order provided for zero percent tariffs on products listed in Annex III, once a qualifying trade deal was announced.[1] With some agreements now in place, Annex III of the EO is being actively implemented.Continue Reading Shifts in U.S. Trade in Asia: Key Agreements from President Trump’s October 2025 Asia Trip – Part I: Southeast Asia
On October 17, 2025, the Trump Administration released a significant proclamation imposing new Section 232 duties on medium- and heavy-duty vehicles (MHDVs) (such as trucks); MHDV parts; and buses. These changes further expand tariff coverage over sectors critical to U.S. industrial capacity and national security, and bring a few new complexities to both importers and domestic manufacturers.Continue Reading Not Only Tariffs on Trucks: Trump Administration’s Proclamation Amends the Tariff Landscape on Automobiles, Steel, and Aluminum
Update (November 2025): BIS suspended implementation of the Affiliates Rule for one year, temporarily reversing the extension of Entity List and MEU-related controls to foreign affiliates that are 50% or more owned by listed entities. In a final rule effective November 10, 2025, BIS stayed the interim rule’s amendments to the EAR until November 9, 2026, absent further extension. During the suspension period, the EAR reverts to the prior “legally distinct” test, meaning foreign affiliates are not automatically covered solely by virtue of 50% ownership. The suspension comes as result of trade negotiations with China, which we discuss our recent blog series on U.S. Trade in Asia.Continue Reading Not Your Usual Monday: BIS Adopts 50 Percent Rule for Entity List, MEU List & Related EAR Controls
If the White House wants tariffs, but the courts strike down the Reciprocal Tariffs, what other options are out there?Continue Reading A Time Machine and a Bag of Hammers: U.S. Tariffs are not Over
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
Some importers are finding, to their surprise, that the Trump Administration’s 25% tariffs on aluminum and steel create an exemption from the 125% tariffs on Chinese goods.Continue Reading Not What You Think: Some Trump Tariffs Exempt Your Goods from Other Trump Tariffs
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II
The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I