As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.
President Trump Issues Proclamation Adjusting Tariffs on Imports of Timber, Lumber and their Derivative Products
On September 29, 2025, President Donald Trump issued a proclamation announcing that the Department of Commerce had concluded its investigation into the effects of imports of timber, lumber, and their derivative products (collectively, wood products) pursuant to Section 232 of the Trade Expansion Act of 1962 and found certain wood products are being imported into
President Trump Announces Section 232 Tariffs on Heavy-Duty Trucks, Cabinetry, Upholstered Furniture, and Branded/Patented Pharmaceuticals Starting October 1, 2025
On September 25, 2025, President Donald Trump announced on social media that the United States will impose a 25% tariff on heavy-duty trucks beginning October 1, 2025. The social media post did not specify the legal basis for the tariff but indicated it was necessary “for many reasons, but above all else, for national security
President Trump Signs Executive Order on China’s Divestment of TikTok
On September 25, 2025, President Donald Trump issued an Executive Order (EO), “Saving TikTok While Protecting National Security”, stating that “a plan has been presented to me to undergo a qualified divestiture of TikTok’s United States operations, as outlined in a framework agreement.” While the agreement has not been made public, the EO indicates that:
Department of Commerce Lists EU Tariff Exemptions
On September 24, 2025, the U.S. Department of Commerce announced tariff exemptions for certain goods imported from the EU. The notice modified additional duty rates applicable to certain imported products of EU member countries.
On August 21, 2025, the United States and the EU announced an agreement that adjusted tariffs on certain EU products, including
Federal Circuit Upholds CIT Decision Supporting China Section 301 Lists 3 and 4A Tariffs
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
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
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