On June 24, 2025, in a press release, the Department of Commerce’s International Trade Administration (ITA) announced new procedures for U.S. producers of auto parts to request that additional auto parts be included in the list of auto parts that are subject to 25% tariffs under the Section 232 review of automobiles and auto
Section 232 Investigations
Commerce Publishes Federal Register Notice Modifying HTSUS for Implementing General Terms of U.S. and UK Trade Deal
The U.S. Department of Commerce’s International Trade Administration (ITA) has published a Federal Register notice indicating that effective June 30, 2025, in consultation with U.S. Customs and Border Protection and the U.S. International Trade Commission, it has revised relevant provisions of the Harmonized Tariff Schedule of the United State (HTSUS) to conform with changes specified…
US and UK Implement General Terms of Trade Deal
On June 16, 2025, the United States and the United Kingdom formally implemented the General Terms for the United States of America and the United Kingdom of Great Britain and Northern Ireland Economic Prosperity Deal (the “General Terms”). In a related Executive Order (EO), President Donald Trump set forth agreements reached with the UK regarding…
Section 232 Aluminum and Steel Tariffs Increased to 50% Except for UK; Significant Changes Made to Calculating and “Stacking” of Tariffs
President Donald Trump issued a Proclamation on June 3, 2025 increasing the previously imposed Section 232 tariffs on aluminum and steel products and their derivatives from 25% to 50%. These increased tariffs were effective June 4, 2025. The proclamation excluded products of the United Kingdom which stay at 25% until July 9, 2025.
U.S. Customs…
CBP Issues Notice Addressing Refunds to Address Tariff “Stacking” Updates
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…
Department of Commerce Initiates Section 232 Investigation of Imports of Commercial Aircraft and Jet Engines
On May 1, 2025, the Department of Commerce (Commerce) announced that, pursuant to Section 232 of the Trade Expansion Act of 1962, it was initiating an investigation to determine the effects on the national security of imports of commercial aircraft, jet engines, and parts for commercial aircraft and jet engines. Interested parties may submit written…
President Trump Announces General Terms to a Forthcoming Trade Deal with the United Kingdom, Keeping 10% Baseline Tariffs But Dropping Tariffs on British Autos, Steel, and Aluminum
On May 8, 2025, the White House published general terms for a future trade deal “to enhance [the] economic partnership” between the United States and the United Kingdom. The general terms, which names the forthcoming agreement as the U.S.-UK Economic Prosperity Deal, “do[] not constitute a legally binding agreement” but rather memorialize a set of…
White House Amends Automobile Parts Tariffs to Ease Burden on U.S. Automakers
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…
President Trump Issues Clarification on Application of Various IEEPA Tariffs
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’…
Department of Commerce Initiates Section 232 Investigation of Imports of Medium- and Heavy-Duty Trucks and Related Parts
On April 22, 2025, the Department of Commerce (Commerce) announced that, pursuant to Section 232 of the Trade Expansion Act of 1962, it was initiating an investigation to determine the effects on the national security of imports of medium-duty trucks, heavy-duty trucks, medium- and heavy-duty truck parts, and their derivative products.
The Federal Register notice…