On March 12, 2026, the U.S. Trade Representative (USTR) announced that it was launching Section 301 investigations into 60 trade partners to determine whether they have been engaged in forced labor practices. The investigations, to be conducted pursuant to Section 301of the Trade Act of 1974, include China, the European Union, India, and Mexico. A
Aaron C. Mandelbaum
Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.
OFAC Issues Russia General License Allowing Delivery and Sale of Russian Crude Oil and Petroleum
On March 12, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 134, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026.” The general license authorizes transactions “that are ordinarily incident and necessary…
CBP Reports Progress on IEEPA Tariff Refund Process
On March 12, 2026, Judge Richard Eaton of the U.S. Court of International Trade (CIT) held a second conference with the parties in the Atmus Filtration, Inc. vs. United States, et al. litigation matter regarding the progress of Customs and Border Protection (CBP) in establishing a process and procedures to allow for automated refund of…
Two Steps Importers Should Take Now to Prepare for IEEPA Tariff Refunds
On March 6, 2026, Brandon Lord, a U.S. Customs and Border Protection (CBP) official who, inter alia, leads CBP’s strategic efforts to enforce and protect tariff revenue, submitted a declaration to the U.S. Court of International Trade outlining a proposed process for issuing refunds for importers who have paid tariffs under the International Emergency Economic…
CIT Suspends Earlier Order Directing IEEPA Tariff Refunds
On March 6, 2026, Judge Richard Eaton of the U.S. Court of International Trade (CIT or Court) held a closed conference in Atmus Filtration, Inc. vs. United States, to continue the Court’s process in determining how the International Economic Emergency Powers Act (IEEPA) tariffs can be refunded to importers of record. At the conclusion of…
CIT Orders Refund of IEEPA Tariffs
On March 4, 2026, in Atmus Filtration, Inc. vs. United States, Judge Richard Eaton of the U.S. Court of International Trade (CIT) issued an order, referencing the U.S. Supreme Court’s February 20, 2026 ruling in Learning Resources, Inc. v. Trump declaring International Emergency Economic Powers Act (IEEPA) tariffs unlawful, that: (1) “[a]ll importers…
Federal Circuit Clears Path for CIT to Oversee IEEPA Tariff Refund Process
On March 2, 2026, the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) issued a per curiam order granting the plaintiffs’ February 24, 2026 motion in V.O.S. Selections v. Donald J. Trump, et al. to immediately issue the Federal Circuit’s mandate, remanding the case to the U.S. Court of International Trade (“CIT”) for…
After U.S. Supreme Court Invalidates IEEPA Tariffs, Trump Administration Turns to Other Options – What Importers Need to Know
In a 6-3 ruling, the Supreme Court of the United States ruled that the International Emergency Economic Powers Act (IEEPA) does not grant the president power to impose tariffs. In response, President Donald Trump issued a temporary 10% tariff on all imports pursuant to Section 122 of the Trade Act of 1974. Importers of record…
Plaintiffs in China Section 301 Tariff Litigation File Petition with U.S. Supreme Court Seeking Review of Federal Circuit Decision
On February 20, 2026, lead counsel for the plaintiff group in the test case for the China Section 301 tariff refund litigation (HMTX Industries LLC, et al. v. United States et al.), filed a Petition for a Writ of Certiorari with the U.S. Supreme Court seeking review of the U.S. Court of Appeals…
In Response to U.S. Supreme Court IEEPA Tariff Ruling, USTR Plans to Initiate Section 301 Investigations
On February 20, 2026, in response to the U.S. Supreme Court’s ruling that tariffs under the International Economic Emergency Powers Act (IEEPA) are illegal (see Thompson Hine Update of February 20, 2026), Ambassador Jamieson Greer, the U.S. Trade Representative, issued a statement that the decision “affects [only] one element of the Administration’s” trade…
