Maureen E. Thorson

On May 9, the U.S. Department of Commerce (Commerce) released an advanced notice soliciting public comments on an investigation into the national security impacts of imported commercial aircraft and jet engines, and parts for commercial aircraft and jet engines. This notice is scheduled for publication in the Federal Register on May 13, with interested parties invited to submit comments by June 3, 2025.

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 15, 2025, the Trump Administration issued an Executive Order (EO) directing the Secretary of Commerce to initiate an investigation under Section 232 of the Trade Expansion Act of 1962 (Section 232), to determine whether imports of processed critical minerals and their derivative products pose threats to national security. The EO notes that processed critical minerals and their derivative products are essential for economic security and resilience, but that the U.S. manufacturing and defense industrial bases remain dependent on foreign sources for processed critical mineral products, creating a potential national security risk.

On April 14, 2025, the U.S. Department of Commerce (Commerce) released draft Federal Register notices soliciting public comments in two previously unannounced investigations into the national security impacts of imported pharmaceuticals and pharmaceutical ingredients and semiconductors, semiconductor manufacturing equipment, and derivative articles. The notices are scheduled for publication on April 16, and comments are due within 21 days of publication – that is, by, May 7, 2025.

The Trump administration has made tariffs a key part of its foreign and economic policy, making sweeping changes to the United States’ tariffs regime over recent weeks. These changes have profound implications for US companies doing international business or with international components to their supply chains. This CLE provides guidance for businesses affected by these changes. International trade law attorneys Maureen Thorson and Adam Teslik (Wiley Rein LLP) will provide a primer on tariffs and an update on the tariffs landscape under Trump, outlining key developments and foreshadowing what may yet come. International disputes attorney Lexi Menish (Menish Dispute Resolution LLC) will then discuss tariff-related contractual disputes and provide guidance on the types of contractual provisions parties should consider including to protect themselves in the event that increased tariffs substantially alter the economics of their deals.

A discussion of the June 21, 2022 implementation of the Uyghur Forced Labor Prevention Act (UFLPA), the latest news on enforcement, and an understanding of the new U.S. government guidelines that will be essential for business compliance.

Over the past four years, the United States has levied special tariffs on a wide variety of imports under Sections 201 and 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. An overview of the current implementation of these tariffs, recent developments with the potential to affect their continuation, and what U.S. importers, manufacturers, and purchasers can expect for the future.