Christopher B. Weld

On April 23, the U.S. Department of Commerce (Commerce) announced its initiation of investigations into the national security effects of imports of critical minerals and medium/heavy trucks, parts for such goods, and their derivative products, under Section 232 of the Trade Expansion Act of 1962. The investigation into critical minerals follows an April 15, 2025 Executive Order directing Commerce to begin an investigation.

On April 17, 2025, the Office of the U.S. Trade Representative (USTR) issued its final notice of action in its investigation into China’s unfair practices affecting the shipbuilding and maritime logistics sectors. According to the agency’s draft Federal Register notice and accompanying press release, the United States will begin charging fees on Chinese-owned, -operated, and -built vessels arriving in U.S. ports. There will be two phases of action.

On April 2, 2025, President Trump announced reciprocal tariffs on imports into the United States, with a minimum 10% tariff applied to imports from most sources with limited country and product carveouts as discussed below, and higher tariff rates imposed on more than 60 specific countries as further described in the link.

On March 26, 2025, President Trump issued a Proclamation that the United States will impose an additional 25% import duty, pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232), on: Passenger vehicles (sedans, sport utility vehicles, crossover utility vehicles, minivans, and cargo vans); Light trucks; and Certain automobile parts (engines and engine parts, transmissions and powertrain parts, and electrical components).

As a follow-up to President Trump’s recently announced “Fair and Reciprocal Plan” for implementing reciprocal tariffs, and according to a draft notice recently published on its website, the Office of the U.S. Trade Representative (USTR) is now accepting public comments on unfair trade practices and non-reciprocal arrangements pursuant to the America First Trade Policy Presidential Memorandum and the Presidential Memorandum on Reciprocal Trade and Tariffs. The deadline to comment is March 11, 2025.

2024 continues to be another extremely important year for international trade and national security law and policy, especially as the Biden Administration and Congress debate legislation and policy priorities all in the context of an election year. In addition, trade negotiations, new trade enforcement actions as well as recent legislation and regulatory challenges, and national security policies all have the potential to significantly affect companies and industries.

We anticipate that 2024 will be another extremely important year for international trade and national security law and policy. The Biden Administration and Congress will continue to debate trade legislation and policy priorities, all in the context of an election year. In addition, trade negotiations, new trade enforcement actions, and national security policies have the potential to significantly affect companies and industries.