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
The U.S. photovoltaic (PV) industry, solar module suppliers, manufacturers, and renewable energy developers are facing new regulatory challenges with the implementation of new legislation which has a significant impact on such imports. Among the most significant is the Uyghur Forced Labor Prevention Act, Pub. L. No. 117-78, 135 Stat. 1525 (2021) (“UFLPA”), whose provisions became fully effective on June 21, 2022.Continue Reading Is the U.S. solar industry ready to prove its panels aren’t made with Uyghur forced labor?
On Monday, President Biden issued an Executive Order suspending the collection of anti-dumping and countervailing duties (AD/CVD) of certain solar cells and modules exported from Cambodia, Malaysia, Thailand, and Vietnam. The Executive Order comes on the heels of a Commerce Department investigation initiated back in March 2022 into whether solar cell and modules from the aforementioned countries were circumventing AD/CVD duties on solar cells and modules made in China. The anticircumvention investigation, however, will continue to run its normal course, and if circumvention is found, AD/CVD duties will not be imposed until the end of the 24 month period (or until the emergency is declared terminated) (see here). Continue Reading President Biden Suspends AD/CVD Duties on Solar Cells and Modules from Cambodia, Malaysia, Thailand, and Vietnam
In recent years, a wide array of trade actions pursued by the United States, foreign and domestic policies of the United States and China, reputational risks, and supply chain breakdowns are driving a trend of more and more manufacturing moving from Asia to Mexico. The Biden Administration has made no secret of its desire to encourage U.S. manufacturers and their component suppliers to move production from China to Mexico.[i]
Continue Reading The Trend of Production Moving from China to Mexico – Regulatory and Practical Considerations: Zai Jian Zhongguo, Bienvenidos a México
This is the second of three articles on the Solar Industry and Forced Labor. Here we focus on interactions with solar module suppliers. Our first article in the series focused on regulations in this area, and our next will focus on investors and their requirements.
Continue Reading Clean Energy’s Messy Problem II: The Solar Industry, I͟t͟s͟ S͟u͟p͟p͟l͟i͟e͟r͟s, and the Complex Task of Combatting Forced Labor
This is the first of three articles on the Solar Industry and Forced Labor. Here we focus on regulation. Articles in the coming weeks will focus on issues facing importers and their suppliers, and on investors and their requirements.
Continue Reading Clean Energy’s Messy Problem: The Solar Industry, the U.S. Government, and the Complex Task of Combatting Forced Labor
Continue Reading Anti-Forced Labor Measures Turn Up the Heat on Chinese Solar Equipment Suppliers
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) on cotton and tomato products produced by entities operating in Xinjiang, China. The order is based on information that indicates the use of forced labor in the production of the goods. If you are sourcing these products from the Xinjiang region, you may want to consider proactive compliance steps to mitigate your risk and prevent disruption in your supply chain.
Continue Reading CBP Stops More Imports Under Forced Labor Rules (Cotton a Jam, Part II)
Key Takeaways:
In the last few weeks of former President Trump’s term in office, the United States Trade Representative (USTR) suspended its previous plans to impose tariffs on certain French luxury goods, as we discussed here and here.
Continue Reading USTR Suspends Tariffs on Certain French Luxury Goods: A Potential Shift in Trade Talks