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Dan focuses his practice on providing end-to-end counsel across clients’ Canada-United States, North American and global supply chains. This trade counsel includes customs classification and compliance, utilization of preferential trade agreements such as the USMCA, tariff mitigation and exclusions, procurement issues such as Buy America/Buy American, and anti-dumping/countervailing duty issues. He also advises clients on negotiating transportation agreements, managing trusted trader and related security programs, and addressing issues at ports-of-entry.

On May 16, 2025, Customs and Border Protection (CBP) issued a Notice to implement President Donald Trump’s earlier Executive Order (EO) 14289 that eliminated the “stacking” (or accumulation) of certain overlapping tariffs. These overlapping tariffs included the IEEPA tariffs on Canada and Mexico, the Section 232 automobile and automotive part tariffs, and the Section 232

On April 29, 2025, President Trump signed a Proclamation amending the previously announced tariffs on automobile parts used in passenger vehicles and light trucks. This amendment follows Proclamation 10908, which announced 25% section 232 tariffs on imports of certain final, assembled passenger vehicles and light trucks (“automobiles”), effective April 3, 2025, and imports of

On April 29, 2025, President Donald Trump issued an Executive Order (EO) clarifying that each of the tariffs he has imposed pursuant to the International Emergency Economic Powers Act (IEEPA) and Section 232 of the Trade Expansion Act of 1962, serve separate and distinct policy purposes, but should “not all have a cumulative effect (or ‘stack’

On April 17, 2025, the Office of the U.S. Trade Representative (USTR) announced targeted actions “to restore American shipbuilding” after its determination that China was implementing “unreasonable acts, policies, and practices to dominate the maritime, logistics, and shipbuilding sectors.” Although the specific details of the targeted actions differ from USTR’s proposed actions (see Update

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

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

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

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