On April 15, 2025, President Donald Trump issued an Executive Order (EO) directing the Department of Commerce (Commerce) to initiate an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on national security of imports of processed critical minerals and their derivative products. Because “processed critical minerals and their
Commerce Initiates Section 232 National Security Investigation of Imports of Semiconductor Manufacturing Equipment
On April 1, 2025, it was announced that the Department of Commerce had initiated an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on the national security of imports of semiconductors and semiconductor manufacturing equipment (SME), and their derivative products. This includes, among other things, semiconductor substrates and
Commerce Initiates Section 232 National Security Investigation of Imports of Pharmaceuticals & Pharmaceutical Ingredients
On April 1, 2025, it was announced that the Department of Commerce had initiated an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on the national security of pharmaceuticals and pharmaceutical ingredients and their derivative products. This includes both finished generic and non-generic drug products, medical countermeasures, critical
White House Releases List of Products Not Subject to Reciprocal Tariffs
On April 11, 2025, President Donald Trump issued a Presidential Memorandum providing clarification of allowable exceptions under Executive Order 14257 of April 2, 2025 (i.e., implementation of reciprocal tariffs). The memorandum clarifies that one excepted product is the importation into the United States of “semiconductors.” The memo proceeds to define this term as including products
President Trump Pauses Country-Specific Reciprocal Tariffs for 90 Days but Increases Tariffs on China
On April 9, 2025, President Donald Trump issued an Executive Order (EO) announcing that he was pausing the country-specific reciprocal tariffs and, instead, leaving in place for 90 days the baseline 10% tariffs on all countries that was implemented on April 5, 2025. The President, however, noted that this pause would not apply to imports
President Trump Increases Reciprocal Tariff and De Minimis Rates on China Due to Retaliation
On April 8, 2025, President Donald Trump issued a new Executive Order (EO) to address China’s retaliatory 34 percent tariff it is scheduled to impose on all goods imported into China originating from the United States beginning on April 10, 2025. The President has stated that effective with respect to goods entered for consumption, or
CBP Clarifies Savings Clause for Entry of Goods Subject to Reciprocal Tariffs
On April 8, 2025, U.S. Customs and Border Protection (CBP) issued further clarification on the “savings clause” issued under President Donald Trump’s Executive Order (EO) implementing reciprocal tariffs on over 60 countries (see Thompson Hine Update of April 3, 2025). The reciprocal tariff EO states that goods loaded onto a vessel at the
President Trump Orders De Novo CFIUS Review of U.S. Steel Acquisition
On April 7, 2025, President Donald Trump issued a Presidential Memorandum directing the Secretary of the Treasury and others in his administration to conduct a new review of the acquisition of U.S. Steel Corporation by Nippon Steel Corporation “to assist me in determining whether further action in this matter may be appropriate.” Citing former President
OFAC Again Continues to Extend Authorizations Under Russia General License 13
On April 7, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13M, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import
CBP Issues WRO on Taepyung Salt Farm
On April 2, 2025, the U.S. Customs and Border Protection (CBP) issued a press release announcing that it had issued a Withhold Release Order (WRO) for imports of sea salt products from Taepyung Salt Farm, a South Korean company, “based on information that reasonably indicates the use of forced labor.” The WRO is effective immediately