On September 25, 2025, a three-judge panel at the U.S. Court of Appeals for the Federal Circuit (CAFC) upheld the decision of the Court of International Trade (CIT) sustaining the China Section 301 tariffs. This decision followed oral argument at the CAFC on January 8, 2025, in the test case for the China Section 301 tariff
2025
Department of Commerce Initiates Section 232 Investigation of Imports of Personal Protective Equipment, Medical Consumables, and Medical Equipment
On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of personal protective equipment (PPE), medical consumables, and medical equipment including devices. Interested parties may submit written comments, data, analyses, or…
Department of Commerce Initiates Section 232 Investigation of Imports of Robotics and Industrial Machinery
On September 2, 2025, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of robotics and industrial machinery. According to the notice, the term “robotics and industrial machinery” for this investigation includes, among other things…
OFAC Amends Remaining Syria-Related Sanctions Regulations
The Office of Foreign Assets Control (OFAC) issued a Final Rule effective September 25, 2025 amending the Syria-Related Sanctions Regulations at 31 C.F.R. Part 569. The heading of these regulations is being changed to the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.” These amended regulations further implement Syria-related Executive Order 14312 (June 30, 2025).
New Process Announced for Adding Automobile Parts to Section 232 Tariffs
In Proclamation 10908, “Adjusting Imports of Automobiles and Automobile Parts into The United States,” on March 26, 2025, President Trump ordered the Secretary of Commerce to create a process for including additional automobile parts for passenger vehicles and light trucks to Section 232 tariffs on imports. A new interim final rule published on September 17…
BIS Now Accepting Requests to Add Products to Section 232 Steel and Aluminum Tariffs
On September 17, 2025, the Bureau of Industry and Security (BIS) published a Federal Register notice that it will again accept requests for new derivative products to be subject to Section 232 tariffs on steel and aluminum articles. The request window is open from September 15 through September 29, 2025. Requests must provide detailed information…
USTR Initiates Public Consultation Process for USMCA Joint Review
Update: On November 7, 2025, the Office of the U.S. Trade Representative issued a notice rescheduling the public hearing on the operation of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA). Originally scheduled for November 17, the hearing will now take place from December 3 to 5…
USTR Seeks Comment on Possible Extension of Remaining China Section 301 Product Exclusions
On September 16, 2025, the Office of the U.S. Trade Representative (USTR) issued a notice and request for public comments on the possible extension of the remaining 178 product exclusions in the Section 301 investigation of China’s acts, policies, and practices related to technology transfer, intellectual property, and innovation. The USTR has extended these exclusions…
Annual Blocked Property Reports Due to OFAC by September 30
All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2025. This does applies to all relevant persons, not only financial institutions.
This report is pursuant to 31 C.F.R.
Trump Administration Announces Changes to Japan Tariffs
On September 16, 2025, the Department of Commerce’s International Trade Administration (ITA) released a Federal Register notice announcing changes to the Harmonized Tariff Schedule of the United States (HTSUS) as to general tariffs on imports of Japanese goods in order to implement the United States-Japan Agreement (see Executive Order 14345). Under the original framework…
