13 October 2025

BIS Adds 29 Parties to the Entity List

In a Federal Registers Notice (FRN) published on October 9, 2025, the Bureau of Industry and Security (BIS) announced the addition of 26 entities and 3 addresses to the Export Administration Regulations (EAR) Entity List due to these entities being “determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States.” These additions are being made due to “these companies divert U.S.-origin items to Iran, including to parties on the BIS Entity List and on OFAC's Specially Designated Nationals (SDN) List.” This rule went into effect on October 8, 2025.

FRN # 2025-19508 can be found here.

07 October 2025

BIS Introduces 50% Ownership Interim Final Rule for Entity List

In a Federal Register Notice (FRN) published on September 30, 2025, the Bureau of Industry and Security (BIS) announced an interim final rule establishing a 50% ownership threshold for the Entity List and Military End User List. BIS is adopting this rule from the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List and will impose export license requirements on any company that is at least 50% owned by a party on the Entity List or Military End User List. This interim final rule went into effect on September 29, 2025. BIS is accepting public comments on this rule until October 30, 2025. A temporary general license for “non-listed foreign affiliates of listed entities”, which permits certain export, reexport, and transfer (in-country) transactions involving non-listed foreign affiliates that are 50% or more owned by parties on the Entity List or Military End User List, will be valid for 60 days, until November 28, 2025.

FRN 2025-19001 can be found here.

10 September 2025

August 2025 Antidumping and Countervailing Duties Updates

In August 2025, the U.S. International Trade Administration (ITA) announced several antidumping duty (ADD) and countervailing duty (CVD) determinations, as well as the initiation of investigations. Details on these cases, including affected HTS numbers, can be found in the official notices linked below. The following ADD and CVD investigations were initiated: ADD and CVD investigations of crystalline silicon photovoltaic cells, whether or not assembled into modules, from India, Indonesia, and Laos ADD and CVD investigations of certain freight rail couplers and parts thereof from Czech Republic and India ADD investigation of unwrought palladium from Russia ADD and CVD investigations of high purity dissolving pulp from Brazil

USTR Announces Sugar Tariff-Rate Quota Allocations for 2026

In a press release published on August 15, 2025, the Office of the U.S. Trade Representative (USTR) announced the country-specific allocations of the tariff-rate quotas (TRQs) on raw cane sugar, refined sugar, and sugar-containing products for fiscal year 2026. These TRQs allow specific quantities of certain products to be imported into the U.S. at a lower tariff rate. All imports, including those imported on with a TRQ, will be subject to duties under the International Emergency Economic Powers Act (IEEPA).

Learn more.

28 July 2025

EU Releases Statement on Tariffs and Trade with the United States

In a press release published on July 27, 2025, the European Union (EU) Commission President issued a statement on the recent deal announced on tariffs and trade with the United States. The press release reviews some details of the deal such as: A single 15% tariff rate will apply to most EU exports, including cars, semiconductors and pharmaceuticals; A zero-for-zero tariffs on several strategic products; including all aircraft and component parts, certain chemicals, certain generics, semiconductor equipment, certain agricultural products, natural resources and critical raw materials; and The EU and the US will work together to ensure fair global competition on steel and aluminum.

A link to the EU Statement can be found here.

23 June 2025

CBP Updates Guidance on Reporting Unknown Countries of Aluminum Smelt and Cast

In a Cargo Systems Messaging Service (CSMS) bulletin published on June 13, 2025, U.S. Customs and Border Protection (CBP) updated guidance on how to report an unknown country of smelt and cast for aluminum products subject to Section 232. If an importer of derivative aluminum products does not know the country of smelt and/or cast, then the importer should report “UN” for “unknown” for the International Organization for Standardization (ISO) code. When a country of cast or smelt is unknown, the importer will be assessed the 200 percent Section 232 duties on imports of aluminum from Russia. The guidance goes into the specific details on how this information needs to be presented in the Automated Commercial Environment (ACE) and introduces two new messages added to the Entry Summary Error Dictionary to ensure compliance. The updated requirements will be deployed in ACE on June 28, 2025. CSMS # 65340246 can be found here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-3e50356?wgt_ref=USDHSCBP_WIDGET_2

29 May 2025

CBP Has 10 Days to Implement IEEPA Tariff Halt; Government Appeals

The government has 10 days to issue orders implementing the Court of International Trade’s May 28 permanent injunction shutting down International Emergency Economic Powers Act tariffs on China, Canada and Mexico, as well as the 10% and country-specific IEEPA reciprocal tariffs, according to a judgment issued by the court alongside its opinion. The government has already filed an appeal of the decision.

06 May 2025

CBP Publishes Guidance on Section 232 Automobile Parts

In a Cargo Systems Messaging Service (CSMS) bulletin published on May 1, 2025, U.S. Customs and Border Protection (CBP) issued guidance on certain automobile parts subject to Section 232 duties. This guidance reviews the 25% ad valorem tariffs on all imports of certain automobile parts from all countries that came into effect on May 3, 2025. The guidance provides entry filing instructions, including a review of the applicable chapter 99 Harmonized Tariff Schedule of the United States (HTSUS) classifications, exemptions, and chapter 98 provisions. No drawback shall be available for these automobile parts duties. Any automobile parts may only be admitted into a foreign trade zone under “privileged foreign status” and will be subject to these additional duty rates; unless the product is eligible for admission under “domestic status.” CSMS #64916652 can be found here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-3de8cac?wgt_ref=USDHSCBP_WIDGET_2

UK Announces Further Sanctions Against Russia

In a publication on www.gov.uk, the United Kingdom announced a new legislation, Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025, that expands trade sanctions against Russia. The new measures “prohibit the export, supply and delivery, and making available to, or for use in Russia, of newly sanctioned items as well as the provision of related ancillary services” under the following schedules: Schedule 2A (critical-industry goods and critical-industry technology); Schedule 3 (energy-related goods and energy-related technology); Schedule 3C (defence and security goods and defence and security technology); Schedule 3E (G7 dependency goods and G7 dependency technology); and Schedule 3I (Russia’s vulnerable goods and Russia’s vulnerable technology).

CBP Issues ACE Guidance for Processing of De Minimis Shipments from China

On April 18, 2025, U.S. Customs and Border Protection (CBP) issued a bulletin via its Cargo Systems Messaging Service (CSMS) providing guidance for processing of shipments of goods from China and Hong Kong once such items are no longer eligible for the de minimis exemption. The CSMS provides information on procedures and messaging in the Automated Commercial Environment (ACE) for shipments of products of China and Hong Kong that are under $800, specifically for shipments being cleared via manifest or shipments entering the U.S. via international mail. The CSMS also indicates products of China or Hong Kong entered using entry type 86 will be rejected. According to CBP, a notice will be published in the Federal Register prior to the effective date of May 2, 2025. The CSMS can be found here: https://content.govdelivery.com/bulletins/gd/USDHSCBP-3dca7b6?wgt_ref=USDHSCBP_WIDGET_2

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