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Wide-ranging tariffs President Trump has imposed under the authority of the International Emergency Economic Powers Act will remain in place for at least several more weeks, and possibly longer, raising the possibility that “reciprocal” tariffs could snap back to higher levels on July 9 as currently scheduled.

The Court of International Trade ruled last month that the IEEPA tariffs imposed to date are unlawful and gave the federal government ten days to stop collecting them. However, the CIT’s  decision was immediately appealed to the Court of Appeals for the Federal Circuit, which paused the ruling’s effect while it considered a government request for a longer stay during the appeal proceedings.

On June 10 the CAFC approved that request, meaning the IEEPA tariffs (including both the “reciprocal” tariffs on imports from all countries as well as separate tariffs on imports from China, Canada, and Mexico) will continue to be collected. However, the CAFC also said that because this litigation presents “issues of exceptional importance” warranting expedited consideration, it will hold oral argument July 31, and the case will be considered by the full CAFC rather than the usual three-judge panel.

The outcome of these court decisions may determine the future of trade and tariff policy, making it important for any Virginia company engaged in international trade to monitor these developments. Please reach out to your VEDP trade manager if you have any questions. For more information on the court cases surrounding IEEPA, click here.

President Trump issued, on June 16, an executive order to implement the economic prosperity agreement reached last month with the United Kingdom. For autos, the EO establishes an annual tariff-rate quota under which 100,000 vehicles that are products of the United Kingdom will be subject to a Section 232 tariff rate of 7.5 percent instead of 25 percent (which will apply to imports in excess of the TRQ). The TRQ for 2025 will be adjusted to reflect the May 8 date of the initial U.S.-UK agreement and will be effective seven days after the EO is published in the Federal Register.

For aerospace, the EO exempts products of the UK that fall under the World Trade Organization Agreement on Trade in Civil Aircraft from “reciprocal” tariffs and Section 232 tariffs on steel and aluminum. This exemption will be effective as of the date a notice making associated changes to the HTSUS is published in the Federal Register. For more information, click here.

The U.S. is currently negotiating trade deals with more than 15 countries around the world, many of which are trying to finalize deals before July 8, the expiration date for the Trump Administration’s pause on reciprocal tariffs.

On June 16, Canadian leadership indicated their intention to finalize a trade deal within 30-days, and Vietnam’s trade delegation has stated that talks with the U.S. has made “significant progress.” Trade negotiators from Indonesia have made some progress with Indonesia agreeing to import an additional $18 billion in order to equalize the current trade deficit the U.S. has with Indonesia. 

So far in 2025, Canada remains the largest consumer of Virginia exports, and Vietnam and Indonesia rank 22 and 26, respectively, as the largest import market for Virginia goods. Virginia companies exporting to these locations need to monitor these developments. For more information, click here.

The European Union announced May 7 a 200+-page list of U.S. exports that could be subject to “countermeasures” (likely increased tariffs) if the U.S. does not remove tariffs on imports from the EU, including a “reciprocal” tariff (which is currently at 10 percent but could increase to 20 percent as of July 9), a Section 232 tariff of 25 percent on automobiles and auto parts, and a Section 232 tariff of 25 percent on steel, aluminum, and derivative products.

The EU said it will accept public comments on this list, which targets about €95 billion worth of U.S. goods, through June 10. The EU will then use those comments to finalize a proposal for the adoption of countermeasures and consult member states. The EU aims to have a legal act imposing countermeasures ready to use in case ongoing negotiations with the U.S. “do not produce a satisfactory result.”

The EU is also (1) initiating a public consultation on possible restrictions on €4.4 billion worth of EU exports of steel scrap and chemical products to the U.S., (2) launching a World Trade Organization dispute against the U.S. reciprocal and auto/auto parts tariffs, (3) monitoring the potential diversion of global exports from the U.S. to the EU, and (4) continuing to pursue negotiations with other trading partners to find new export outlets and diversify sources of supply. These potential tariffs will have a substantial impact on Virginia companies, as the EU market, in its entirety, is the largest destination for Virginia company exports. For more information, click here.

President Trump has issued a proclamation that increased Section 232 tariffs on imports of steel and aluminum from 25 percent to 50 percent as of June 4. This increase applies to imports from all countries except the United Kingdom, for which tariffs remain at 25 percent, though the White House said that could change as early as July 9 “depending on the status of the U.S.-UK Economic Prosperity Deal.”

For goods classified under HTSUS chapters 73 and 76, the increased tariff applies only to the value of the steel or aluminum content. “Reciprocal” (and other applicable) tariffs apply to any non-steel/non-aluminum content of all steel and aluminum articles and derivative articles. Virginia companies exporting these products need to be aware of potential retaliation on their products in the months ahead. In the first four months of 2025, Virginia companies exported nearly $150 million in products under HS 73 and 76. For more information, click here.

The U.S. and China have agreed to substantially lower some of their tariffs on two-way trade for 90 days while they work to negotiate a trade agreement. According to information from the White House, the U.S. will lower the “reciprocal” tariff it is imposing on imports from China under the International Emergency Economic Powers Act from 125 percent to 10 percent and China will lower its retaliatory tariffs on imports from the U.S. from 125 percent to 10 percent. These suspensions took place on May 14 and remain in effect for at least 90 days.

Also, China agreed to “adopt all necessary administrative measures to suspend or remove the non-tariff countermeasures taken against the United States since April 2, 2025.” It is important to note that all U.S. imports from China will remain subject to applicable most-favored-nation duty rates, an IEEPA tariff of 20 percent imposed due to concerns about shipments of fentanyl, and either the IEEPA reciprocal tariff of 10 percent or a Section 232 tariff of 25 percent (if the products are subject to such tariffs). Many imports from China will also still be subject to longstanding Section 301 tariffs of 7.5 to 100 percent. China is the fourth largest importer of Virginia exports in 2025. For more information, click here.

The Office of the U.S. Trade Representative is accepting comments through July 16 on the operation of the Caribbean Basin Initiative, including the performance of each beneficiary country and whether they are meeting CBI criteria.

The Caribbean Basin Economic Recovery Act and the Caribbean Basin Trade Partnership Act are commonly referred to together as the Caribbean Basin Initiative. Barbados, Belize, Curacao, Guyana, Haiti, Jamaica, Saint Lucia, and Trinidad and Tobago receive benefits under both CBERA and CBTPA. Antigua and Barbuda, Aruba, The Bahamas, British Virgin Islands, Dominica, Grenada, Montserrat, Saint Kitts and Nevis, and Saint Vincent and the Grenadines currently receive benefits only under CBERA. Many of these countries are not large purchasers of Virginia company exports, but they remain important trading partners. For more information, click here.

Importers and others can now seek changes in the eligibility of sub-Saharan African countries to receive benefits under the African Growth and Opportunity Act as part of the Office of the U.S. Trade Representative’s annual review. USTR will hold a public hearing July 18; pre-hearing written comments, requests to testify, and written testimony are due by June 30; and post-hearing written comments, briefs, supplementary materials, and written statements are due by July 31.

Public comments will be considered in developing recommendations on AGOA country eligibility for 2026 (assuming the program is reauthorized past its scheduled Sept. 30, 2025, expiration date). In addition, comments related to the AGOA child labor criteria may be considered by the Department of Labor as it prepares its required report on that issue. For more information, click here.

U.S. Customs and Border Protection routinely issues monthly updates of various trade statistics. Its recent May 2025 highlights (compared to April) include the following.

• Completed 67 audits (up 103 percent) that identified $139 million (up 18.8 percent) in duties and fees owed to the U.S. government stemming from improperly declared imports.
• Collected over $29 million (up 61.1 percent) of this identified revenue and from previous fiscal years’ assignments.
• Stopped 132 shipments (down 5.7 percent) valued at more than $4.5 million (up 23.3 percent) for further examination based on the suspected use of forced labor.
• Seized 2,973 shipments (up 13.8 percent) that contained counterfeit goods valued at more than $317 million (down 36.9 percent).

For more information, click here.

U.S. Customs and Border Protection has updated its schedule for deploying additional functionality to the Automated Commercial Environment. For aluminum, functionality newly planned for deployment June 28 will allow ACE to accept “unknown” in lieu of an ISO country code for the country of primary smelt, secondary smelt, or cast for derivative aluminum imports subject to Section 232 tariffs.

For de minimis shipments, CBP has accelerated from September to Aug. 12 the deployment of functionality to withhold release of ineligible shipments in ACE to enforce the $800 threshold. An enhancement adding bond validations for low-value shipments remains scheduled for July. However, an enhancement automating the removal and restoration of entry type 86 test participants, previously slated for April, has been put on hold. For more information, click here.

Section 321 of the Tariff Act of 1930 allows for the informal entry of articles that have a retail value of $800 or less and are imported by one person in one day. These de minimis shipments are generally free of duty and taxes and subject to expedited clearance processing.

Earlier this year U.S. Customs and Border Protection issued separate proposed rules (see here and here for more information) that would remove de minimis eligibility for imports subject to certain tariffs and require additional data elements for de minimis entries. President Trump has since terminated de minimis eligibility for imports from China (including Hong Kong and Macau) as of May 2 and indicated an interest in eliminating de minimis entirely. That goal was echoed in an April 2025 report from the president asserting that the de minimis exemption is “a means by which fentanyl, counterfeit goods, and various deadly and high-risk products enter the United States with little scrutiny.”

Virginia companies that import de minimis packages need to carefully monitor these developments to ensure compliance with all applicable rules and regulations. For more information, click here.

The Department of Commerce has published procedures that can be used to ease the Section 232 tariff on imports of automobiles that took effect April 3. This tariff does not apply to the U.S. content (i.e., the value of the automobile attributable to parts wholly obtained, produced entirely, or substantially transformed in the U.S.) in vehicles imported from Mexico and Canada that qualify for preferential tariff treatment under the U.S.-Mexico-Canada Agreement.

The DOC notice provides that, beginning May 20, importers of such vehicles may seek to take advantage of this tariff exclusion by submitting documentation that identifies the following information: total declared customs value of an automobile in the model line at the time of importation, the total value of U.S. and non-U.S. content, vehicle production location(s), country of final assembly, certification of USMCA preference eligibility, importer name, importer of record number, manufacturer name and facility, country of origin, and vehicle year, make, and model. 

VEDP is planning a trade mission to Mexico from September 22-26, 2025. Please reach out to your VEDP trade manager for more information.  For more information, click here.

The Office of the U.S. Trade Representative is accepting comments through July 7 on the following potential modifications of certain aspects of the trade actions associated with its Section 301 investigation of China’s targeting of the maritime, logistics, and shipbuilding sectors for dominance. USTR has previously stated that, beginning Oct. 14, 2025, foreign-built vehicle carrier vessels will be required to pay $150 per car equivalent unit capacity on or before entry into a U.S. port. This fee may be suspended for a particular vessel for up to three years if the vessel owner orders and takes delivery of a U.S.-built vessel of equivalent or greater CEU within that period.

USTR has now determined to propose modifications to (1) provide for a targeted coverage provision pertaining to vessels in the Maritime Security Program, which reduces dependence on China, and (2) change the basis of the fee from car equivalent units to net tonnage, “which is appropriate to address administrability and in light of the potential for fee evasion.” Comments are invited on the implications (and suggested duration) of the targeted coverage provision as well as the potential impact of the fee change. For more information, click here.

The Office of Foreign Assets Control recently announced its imposition of a $216 million penalty on a U.S. firm for violating OFAC’s Ukraine-/Russia-related sanctions and failing to comply with an OFAC subpoena.

OFAC states that this is the statutory maximum civil monetary penalty. Aggravating factors included the willful nature of the violations and their facilitation of a sanctioned Russian national’s access to, and use of, the U.S. financial system. The firm’s lack of an OFAC penalty in the previous five years was a mitigating factor, but OFAC notes that given the totality of the circumstances no penalty reduction was warranted. For more information, click here.

The Trump administration recently announced two actions related to a May 12 executive order seeking to lower prices for prescription drugs in the U.S. First, the Office of the U.S. Trade Representative is accepting comments through June 27 on any act, policy, or practice that may be unreasonable or discriminatory and has the effect of forcing U.S. patients to pay for a disproportionate amount of global pharmaceutical research and development, including by suppressing the price of pharmaceutical products below fair market value in foreign countries. 

Separately, noting that under the May 12 EO the Department of Health and Human Services has published price targets for prescription drugs to lower U.S. health care costs, U.S. Customs and Border Protection has issued a reminder to the trade community that declaring an incorrect value on import or export documentation submitted to CBP is considered trade evasion and that CBP will pursue any violations to the fullest extent possible. For more information, click here.