The United States has imposed additional 50% duties on certain Canadian-origin imports pursuant to Section 338 of the Tariff Act of 1930, marking the first use of a rarely invoked authority in decades. The duties, which took effect on imported certain Canadian products entered or withdrawn from warehouse for consumption beginning at 12.01am Eastern Time on August 22, 2026 following a brief three-day suspension, target a broad range of Canadian products in response to alleged…
On August 13, 2026, the Trump Administration released a report announcing its focus on illegal transshipment, where goods allegedly enter the United States through intermediary jurisdictions to reduce or avoid otherwise applicable duties, as a customs enforcement priority. The announcement arrives amid a sustained enforcement focus from the Administration on tariff evasion. Our prior blog posts on the U.S. Department of Justice to actively investigate tariff evasion-related misconduct, and an Executive Order directing agencies to…
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…
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…
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…
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.…
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…
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…
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…
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…