On November 14, 2025, President Trump signed an executive order modifying the scope of reciprocal tariffs originally imposed under Executive Order 14257 of April 2, 2025, which declared a national emergency based on large and persistent U.S. goods trade deficits. The November 14 order exempts certain agricultural products from the reciprocal tariff regime, effective for
CIT Vacates CBP Forced Labor Finding Against Aluminum Importer
On September 23, 2025, the U.S. Court of International Trade (CIT) issued an opinion vacating and remanding U.S. Customs and Border Protection’s forced labor Finding against Kingtom Aluminio S.R.L., a Dominican Republic-based aluminum extruder. The court found that CBP’s determination, which prohibited the entry of Kingtom’s aluminum extrusions under Section 307 of the Tariff Act
DHS 2025 UFLPA Update Targets New Industries and Expands Entity List
On August 19, 2025, the Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security and including agencies such as the Department of Labor, released its annual update to the Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China. This update, required
U.S. Imposes 50% Tariff on Brazilian Goods
On July 30th, President Trump formally announced the Executive Order increasing the overall reciprocal tariff rate on the Republic of Brazil from 10% to 50% as previously signaled in a Truth Social post on July 9th, 2025. The reciprocal tariffs for Brazil are distinctive for the fact that they comprise
D.C. Circuit Dismisses Suit Concerning Cocoa Farm Forced Labor in Côte d’Ivoire for Lack of Standing
On July 22, 2025, the U.S. Court of Appeals for the D.C. Circuit dismissed an action brought by eight Malian citizens against seven U.S. cocoa importers (Cargill, Nestlé, Mondelēz, Hershey, Olam, Barry Callebaut, and Mars) for forming and operating a cocoa supply chain to provide themselves with cheap cocoa harvested by child labor. The action
Reciprocal Tariffs Suspended Again, New Start Date August 1
On July 7, 2025, President Trump issued an Executive Order extending the suspension of reciprocal tariffs to August 1, 2025. The suspension was initially set to expire on July 9, 2025. The suspension does not affect the 10% reciprocal tariff rate on China, which is in effect until August 12, 2025.
The country-specific reciprocal tariffs
De Minimis to be Eliminated July 2027 under Recently Enacted Megabill
As part of the tax and spending provisions included in the “Megabill” signed by Trump into law on July 4, 2025 are provisions that eliminate the de minimis exemption under Section 321 of the Tariff Act of 1930. The de minimis exemption currently allows shipments not exceeding $800 to enter the U.S. duty-free, excluding shipments
Ninth Circuit Decision Underscores Increasing False Claims Act Risks to U.S. Importers
On June 23, 2025, the Ninth Circuit issued a long-awaited decision in Island Industries Inc. v. Sigma Corp. affirming a $26M False Claims Act (“FCA”) judgment against the defendant importer. Sigma had appealed the judgment after a jury found the company violated the FCA by failing to pay customs duties owed to U.S. Customs
Update on Parallel Federal Court Cases Enjoining IEEPA
The Court of International Trade (“CIT”) and the District Court for the District of Columbia (“DDC”) both issued decisions enjoining the Trump IEEPA tariffs. In both venues, the government appealed the courts’ decisions, and both orders are currently stayed. The DDC stayed its own preliminary injunction pending appeal; the U.S. Court
Court of International Trade Blocks IEEPA Tariffs
On May 28, 2025, the Court of International Trade granted summary judgment in V.O.S. Selections, Inc. et al v. Donald J. Trump Case No. 25-cv-66, ordering that all the executive orders imposing tariffs on the basis of IEEPA (Executive Order 14193, Executive Order 14194, Executive Order 14195, Executive Order 14257), were declared to be invalid