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
Modifications to Reciprocal Tariffs
Modifications to Scope
On Friday, September 5th, 2025, President Trump announced via Executive Order a large number of modifications to the scope of the reciprocal tariffs, which were initially announced on April 2, 2025, under the International Emergency Economic Powers Act (IEEPA). The Executive Order released on September 5th modified the scope of the
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
CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)
An update on Anti-Forced Labor guidance issued by US Customs in the context of Withhold Release Orders (WROs).
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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
District Court Denies Motion to Move Venue, Grants Preliminary Injunction
On May 29, a day after the U.S. Court of International Trade (“CIT”) issued summary judgment in V.O.S. v. Trump blocking the IEEPA tariffs, the District Court for the District of Columbia (“DDC”) exercised jurisdiction in Learning Resources, Inc., et. al., v. Donald J. Trump, et. al. (25-cv-1248), denying the government’s motion to transfer the
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
CBP Proposes Rule Imposing Greater Regulation of De Minimis Imports
U.S. Customs and Border Protection (CBP) issued a notice of proposed rulemaking concerning the de minimis exemption under 19 U.S.C. § 1321 (Section 321). Currently, the de minimis exemption allows goods with an aggregate value under $800 to enter the U.S. duty-free and via an expedited process. The proposed amendment is intended to stem the
Trump Announces 25% Tariff on Mexico and Canada
When Trump won the presidential election, he promised there would be tariffs. On November 25, 2024, we got a clearer picture of what those tariffs will look like. President-elect Donald Trump posted on social media that he would be imposing 25% tariffs on imports from Mexico and Canada on his first day in office. Additionally
Senate Finance Chairman Wyden Formalizes De Minimis Reform Legislation
Senate Finance Chairman Ron Wyden (D-OR) recently introduced a bill that formalizes the legislation he released in August, the Fighting Illicit Goods, Helping Trustworthy Importers, and Netting Gains (FIGHTING) for America Act. The FIGHTING for America Act would remove de minimis treatment for goods impacted by the Generalized System of Preferences (GSP) program, as