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David is the leader of Thompson Hine's International Trade practice group and a member of the firm's International Committee. He advises clients on the risks and opportunities presented by U.S. international trade laws and regulations and international trade agreements. He focuses on antidumping (AD), countervailing duty (CVD) and safeguard litigation, international trade policy, and cross-border compliance issues affecting goods, services, technology and investments that involve transportation, customs, export controls, economic sanctions, anti-boycott and anti-bribery laws and regulations.

On March 24, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License (GL) 41B extending the expiration date of Venezuela GL 41, which authorized certain transactions related to Chevron Corporation’s joint ventures in Venezuela.  Previously, under GL 41A issued earlier this month, all transactions “ordinarily incident and

UPDATE: On March 24, 2025, Customs and Border Protection (CBP) issued a message noting the release of an updated list of impacted HTSUS codes covering “energy” and “energy resources” from Canada that are now subject to 10% tariffs since March 4, 2025. The list now specifically includes all crude and crude mixtures along with

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued Federal Register notices announcing that interested parties may submit written comments, data or other information pertinent to these investigations. Comments are due no later than April 1, 2025.

Section 232 National Security Investigation of Imports of Copper

This investigation was initiated on February

As previously announced by President Donald Trump, the Section 232 steel and aluminum 25% ad valorem tariffs went into effect 12:01 a.m., March 12, 2025, against all steel and aluminum articles and all listed derivatives, including many automotive, construction and consumer products. Aluminum articles and their derivative products from Russia are subject to 200% tariffs.

On March 3, 2025, the Office of the U.S. Trade Representative (USTR) delivered President Donald Trump’s 2025 Trade Policy Agenda, 2024 Annual Report, and World Trade Organization at Thirty report to Congress. This year’s trade agenda seeks to strengthen the middle class and national defense and to address trade deficits by focusing on a “Production

President Donald Trump issued two executive orders (“EOs”) on March 6, 2025 delaying the 25% tariffs imposed against imports of products of Canada and Mexico (10% tariffs for imports of energy products of Canada) pursuant to the International Emergency Economic Powers Act (“IEEPA”) until April 2, 2025.  The EOs specifically provide that goods qualifying and entered

  • The USTR issued a determination and report in January 2025 finding that China’s acts, policies, and practices of in the maritime, logistics, and shipbuilding sectors burden or restrict U.S. commerce and are actionable under Section 301 of the Trade Act of 1974.
  • The USTR is proposing actions that could include significant port service

The Trump administration implemented tariffs against Canada and Mexico effective March 4, 2025, arising from declared national emergencies at both the northern and southern U.S. borders pursuant to the International Economic Emergency Powers Act (IEEPA).

Implementation of Tariffs

On March 3, 2025, U.S. Customs and Border Protection (CBP) issued draft Federal Register notices (to be

On March 3, 2025, the White House issued an Executive Order to further address the synthetic opioid supply chain in China by increasing the current tariffs on all products of China (and Hong Kong) from 10% to 20%. China immediately responded by announcing that it will implement additional tariffs of up to 15% on key

On March 1, 2025, President Donald Trump signed an Executive Order (EO) initiating an investigation under Section 232 of the Trade Expansion Act of 1962 to determine the effects on national security of imports of timber, lumber and their derivative products (including paper products, furniture and cabinetry) dumped into the U.S. market. The EO states