Tariffs/Trade Policy

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On April 17, 2025, the Office of the U.S. Trade Representative (USTR) announced targeted actions “to restore American shipbuilding” after its determination that China was implementing “unreasonable acts, policies, and practices to dominate the maritime, logistics, and shipbuilding sectors.” Although the specific details of the targeted actions differ from USTR’s proposed actions (see Update…

On April 11, 2025, President Donald Trump issued a Presidential Memorandum providing clarification of allowable exceptions under Executive Order 14257 of April 2, 2025 (i.e., implementation of reciprocal tariffs). The memorandum clarifies that one excepted product is the importation into the United States of “semiconductors.” The memo proceeds to define this term as including products…

On April 9, 2025, President Donald Trump issued an Executive Order (EO) announcing that he was pausing the country-specific reciprocal tariffs and, instead, leaving in place for 90 days the baseline 10% tariffs on all countries that was implemented on April 5, 2025. The President, however, noted that this pause would not apply to imports…

On April 8, 2025, President Donald Trump issued a new Executive Order (EO) to address China’s retaliatory 34 percent tariff it is scheduled to impose on all goods imported into China originating from the United States beginning on April 10, 2025. The President has stated that effective with respect to goods entered for consumption, or…

On April 8, 2025, U.S. Customs and Border Protection (CBP) issued further clarification on the “savings clause” issued under President Donald Trump’s Executive Order (EO) implementing reciprocal tariffs on over 60 countries (see Thompson Hine Update of April 3, 2025). The reciprocal tariff EO states that goods loaded onto a vessel at the…

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…

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…

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…

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…

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…