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Tariffs. Customs. Trade Remedies

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Chandri Navarro (US)

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US: President Trump Imposes New Section 232 Measures on Polysilicon Products

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On August 6, 2026, President Trump issued a proclamation under Section 232 of the Trade Expansion Act of 1962, establishing new import restrictions on polysilicon and a range of downstream products. This is the result of a process that started in July 2025. The Administration concluded that increased reliance on foreign sources for these materials raises concerns over the resiliency of supply chains that support semiconductor manufacturing, solar technologies, defense applications, and other strategically important…

US: CBP Issues Implementation Guidance for Section 232 Tariffs on Patented Pharmaceuticals

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On July 30, 2026, the US Customs and Border Protection (“CBP”) issued implementation guidance for Section 232 tariffs on imports of patented pharmaceutical products and pharmaceutical ingredients, providing importers with reporting and classification instructions ahead of the tariffs’ effective dates. The guidance implements Presidential Proclamation 11020, issued on April 2, 2026, which imposes additional duties on certain patented pharmaceuticals and related active pharmaceutical ingredients and key starting materials. Generic pharmaceuticals and their associated ingredients remain…

United States: New 10 to 12.5% Section 301 “Forced Labor” Tariffs on Over 60 Countries Take Effect July 24, 2026, as Section 122 Duties Expire

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On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced final and immediate new tariffs on imports from 60 economies (59 countries and the European Union), including nearly all of the United States’ largest trading partners. The duties are imposed under Section 301 of the Trade Act of 1974 and are tied to USTR’s assessment of measures these economies have taken to adopt and enforce prohibitions on the importation of goods made…

US Proposes Additional 50% Tariffs on Canadian Origin Goods, Effective August 19

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On Monday, July 20, President Trump signed three Proclamations invoking Section 338 of the Tariff Act of 1930 to impose 50% tariffs on certain Canadian origin goods (Section 338 Tariffs). These tariffs are scheduled to enter into force at 12:01 AM EST on August 19, 2026. The Proclamations cite various actions by Canada that allegedly discriminate against the commerce of the United States in three core areas related to the USMCA/CUSMA: automotive, dairy, and alcohol products.…

U.S. Declines to Renew the USMCA/T-MEC/CUSMA, Setting Stage for Annual Review Cycles and Continued Negotiations

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On July 1, 2026, the United States formally declined to renew the United States-Mexico-Canada Agreement (USMCA, T-MEC, CUSMA, or the Agreement) during the Agreement’s first mandatory joint review meeting. Mexico and Canada had formally indicated their intention to renew the Agreement in the weeks leading up to the meeting. The US decision does not terminate the Agreement. Rather, it triggers the Agreement’s annual review mechanism, under which the parties will meet each year to determine…

US: Trump Administration Appeals CIT’s IEEPA Tariff Refund Injunction

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On June 2, 2026, the Trump administration appealed a US Court of International Trade (CIT) injunction directing US Customs and Border Protection (CBP) to reliquidate all entries by all importers without applying tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The government appealed both the above-referenced universal IEEPA tariff refund order and a CIT order compelling CBP Commissioner Rodney Scott’s testimony. Background: In a February decision, the Supreme Court held in Learning Resources…

US: USTR Proposes Section 301 Tariffs on 60 Countries Over Forced Labor Import Practices

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On June 2, 2026, the United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that 60 countries had failed to impose and effectively enforce prohibitions on the importation of goods produced with forced labor, and that the failure is unreasonable and burdens U.S. commerce. The report proposes ad valorem duties on all products of the investigated countries, with limited exceptions. The 60 countries investigated account for over 99% of…

US: New EO Calls for Overhaul of Importer of Record Framework and Increased Customs Enforcement

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On June 3, 2026, President Trump signed an Executive Order (EO) entitled “Strengthening Customs Enforcement.” The EO directs the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to undertake a sweeping set of actions to tighten and escalate customs enforcement, addressing specifically importer of record (IOR) eligibility, foreign IOR restrictions, disclosure requirements, and penalty standards. Enhanced IOR Requirements The EO directs DHS to revise importer eligibility regulations to require that an…

United States: President Trump Tariffs on Patented Pharmaceuticals Under Section 232

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On April 2, 2026, President Trump issued a proclamation adjusting imports of patented pharmaceuticals and associated pharmaceutical ingredients, including active pharmaceutical ingredients (APIs). The action followed an investigation by the Secretary of Commerce under Section 232 of the Trade Expansion Act of 1962, which the proclamation states concluded that imports of patented pharmaceuticals and related inputs were being imported into the United States in such quantities and under such circumstances as to threaten to impair…

United States: USTR Announces Probes of Trading Partners’ Overproduction and Reliance on Forced Labor, With Further Section 301 Investigations Expected

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On March 11, 2026, the United States Trade Representative (USTR) initiated a series of investigations under Section 301 of the Trade Act of 1974 (Section 301) targeting alleged structural excess capacity and overproduction in manufacturing sectors across a wide range of U.S. trading partners (the “Overcapacity Investigations”). Concurrently the USTR announced a separate set of investigations under Section 301 into whether certain trading partners have failed to take action to prevent trading in goods produced…