On April 3, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) released its quarterly update to the Boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business. This resource
Scott E. Diamond**
Scott is a senior policy advisor with more than 25 years' experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.
**Not licensed to practice law.
Trump Signs EO Prohibiting Duty-Free De Minimis Treatment for Goods from China
On April 2, 2025, President Donald Trump signed an Executive Order (EO) that excludes goods from China (including products of Hong Kong) from entering the United States duty-free under the de minimis exception beginning May 2, 2025. Section 321 of the Tariff Act of 1930, commonly referred to as the “de minimis” rule…
Trump Announces Reciprocal Tariffs on Over 60 Countries
UPDATED: This blog post has been updated with additional information and links upon the release of the Annexes to the Executive Order. Readers should note that the breadth and depth of this Executive Order and the implementation of these tariffs is unprecedented, thus the situation regarding interpretation and their implementation remains fluid. It is expected…
Annex Identifying Scope of Automobiles and Automobile Parts Subject to Section 232 Tariffs Is Released
On April 2, 2025, the Annex to the Presidential Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts was released along with U.S. Customs and Border Protection (US-CBP) guidance regarding the fully assembled automobile provisions. As previously reported, see Thompson Hine Update…
President Trump Announces Section 232 Tariffs of 25% on Imports of Automobiles and Certain Auto Parts
On March 26, 2025, President Donald Trump issued a Proclamation imposing 25% tariffs under Section 232 of the Trade Expansion Act of 1962 on imports of automobiles and certain automobile parts, citing “a critical threat to U.S. national security.” The tariffs will apply to final assembled automobiles, entered for consumption or withdrawn from warehouse for…
BIS Adds Over 80 Companies to Entity List, with Heavy Focus on China
On March 25, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) added over 80 companies to its Entity List through two Final Rules. These are the first listings by BIS under President Donald Trump’s second term and the listings heavily focus on China. According to BIS, these entities “have been determined by…
Trump Signs EO Imposing an Additional 25% Tariff on Countries That Buy Venezuelan Oil
On March 24, 2025, President Donald Trump signed an Executive Order (EO) declaring that any country purchasing oil from Venezuela, “whether directly from Venezuela or indirectly through third parties,” will pay a 25% tariff on their exports to the United States. The EO tasks the Secretary of Commerce with determining whether a country buys Venezuelan…
CBP Issues Guidance on Energy, Energy Resources and Critical Minerals from Canada Subject to 10% IEEPA Tariffs; President Trump Issues Executive Order Addressing Mineral Production
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…
BIS Seeks Public Comments on Section 232 Investigations of Imports of Copper and Lumber
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…
Trump Administration Imposes Section 232 Steel and Aluminum 25% Tariffs March 12, 2025; EU and Canada Retaliate
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.
