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

Tariffs remain the focus of the incoming Trump Administration. Over the past several months, the announcements from president-elect Trump and his transition team have been dynamic. We expect the Trump trade policy team to use creative methods to deliver aggressive new tariff policies this year.Continue Reading Trump Tariffs Survival Guide: 10 Strategies for U.S. Importers

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

If your company is like many, your board of directors may be demanding that you put more effort into environmental, social, and governance issues, which have become known by the now-ubiquitous acronym “ESG.” Those demands don’t come from nowhere: consumers are demanding transparency and social responsibility. In particular, if your company does business internationally, regulators are focused on international social justice issues (such as the use of forced labor) more than ever.
Continue Reading Does Your Trade Policy Support Your Company’s Values?

Today, the United States Trade Representative issued a notice informing the importing community about a new Section 301 exclusion process and seeking comments from affected importers. The comment period begins on October 12, 2021, and ends on December 1, 2021.
Continue Reading Exclusions 2.0. The USTR Announces a New Section 301 Exclusion Process for Chinese Products

Companies are putting forth more effort, thought, commitment, and resources into environmental, social, and corporate governance (ESG) considerations across their business lines. The focus of ESG has primarily centered around climate change and sustainability, but the “S” in ESG is becoming increasingly important to consumers and other stakeholders. As global corporate citizens become more vocal about asserting their identity and values, it is critical to think about how their global trade and compliance policies and supply chains reflect those values. Issues like forced labor in the supply chain, third party diligence, and how to build an ethical culture are part and parcel of a strong compliance program. But these issues also present opportunities for companies to reflect their values in a fundamental way and speak to what consumers are demanding with their dollars.
Continue Reading ESG, Global Trade, and Forced Labor: Aligning Compliance with Company Values

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)

One point all can likely agree on in these divisive times is that the Trump Administration’s international trade policy has been aggressive. Over the past four years, we have been clinging to our seats on the rollercoaster ride with some pretty challenging peaks and valleys:

  • Section 301 tariffs on over $370 billion worth of imports from China, under which over $68 billion in total duties have been assessed;[1]
  • Replacement of NAFTA with the United States-Mexico-Canada Agreement (USMCA);
  • Withdrawal from the Trans Pacific Partnership (TPP); and
  • Imposition of Section 232 steel and aluminum tariffs, under which over $9 billion in total duties have been assessed.[2]

Continue Reading Four Ways the Biden Presidency Could Impact Imports, Tariffs, and Trade Agreements