On October 7, 2025, BIS posted a second tranche of requests made by the public for inclusion on the list of derivative products subject to Section 232 tariffs on steel and aluminum derivative products. BIS received 95 inclusion requests in the second submission period that opened on September 15 and closed on September 29. The
Status of Trade-Related Agency Operations During Government Shutdown
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.
Department
BIS Expands Entity List End-User Controls to Cover Affiliates of Listed Entities
On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule that expands the export control restrictions of its Entity List to cover any affiliates that are at least 50% owned by one (or more) entities on the Entity List or the Military End-User (MEU) List. Previously
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
OFAC Again Extends Russia General License 13 Authorizing Transactions Ordinarily Incident and Necessary for Operations in Russia
On September 29, 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 13O, “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
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:
CBP Issues WRO on Bicycles Manufactured in Taiwan
On September 24, 2025, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against bicycles, bicycle parts, and bicycle accessories produced by Giant Manufacturing Co. Ltd. in Taiwan. The WRO follows an investigation into the company where CBP discovered several International Labour Organization (ILO) forced labor indicators, including abusive working and living
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