Tariffs and Trade

Recent tariff measures now require supply chains to maintain a higher level of data granularity, including detailed information on inputs and production. Importers must be prepared to document and support value content declarations with a level of specificity that may not have been previously required.

Members are encouraged to consult with their customs broker or trade counsel for further guidance and to ensure compliance with all applicable tariff programs.

Commerce Announces Auto Parts Tariff ‘Inclusion’ Process

The U.S. Department of Commerce announced it will begin accepting quarterly requests from domestic producers to expand the list of auto parts subject to Section 232 tariffs. The new process allows petition submissions during four two-week windows in January, April, July and October, with the first window opening July 1, 2025.

After each submission window closes, a non-confidential version of each valid request will be posted on Regulations.gov and opened to public comment for 14 days. This review period will allow for final analysis and determination, including whether the product qualifies as an auto part and whether increased imports threaten to impair national security.

Requests must be submitted via Regulations.gov and include:

1. Applicant identification
2. Description of the requested auto part
3. Eight- or 10-digit HTSUS classification requested for inclusion
4. Explanation of why the article qualifies as an auto part
5. Information on the affected domestic industry
6. Statistics on imports and domestic production
7. Description of how and to what extent imports have increased in a way that threatens national security or undermines Section 232 objectives

The International Trade Administration will issue a determination within 60 days of receiving the request. This process may result in additional duties on imports not currently subject to the 25% Section 232 auto parts tariffs.

Department of Commerce Notice

Submission Portal

U.S.-Canada Trade Talks to Resume After Canada Withdraws Digital Services Tax

Canada rescinded its planned digital services tax just hours before its scheduled implementation on June 30, citing an agreement with the United States to resume bilateral trade negotiations. The tax, which would have been retroactive to January 2022 and targeted major U.S. technology firms, had led to a pause in trade talks and strong objections from the White House.

President Trump had previously stated that the United States would end all trade negotiations with Canada and impose new tariffs in response to the tax. Canada’s decision to withdraw the measure reopens the path for renewed engagement.

Canadian officials noted that the withdrawal was a condition for resuming discussions on a broader economic and security agreement, now expected to be finalized by July 21.

Government of Canada Statement

U.S., China Reach Trade Framework

The United States and China have agreed on the core details of a trade framework negotiated during June talks in London, according to China’s Ministry of Commerce. The framework includes provisions for rare earth exports and the easing of certain technology restrictions.

Treasury Secretary Bessent noted that tariffs on imports from China now start at 30%, consisting of a 20% IEEPA fentanyl-related tariff and a 10% reciprocal tariff. An official agreement has not yet been released.

Ministry of Commerce Statement

Trade Talks Could Conclude by Sept. 1

Treasury Secretary Bessent said that ongoing trade negotiations with key partners could conclude by Sept. 1. The administration is in talks with more than a dozen countries and has thus far announced a framework agreement with the United Kingdom and de-escalatory measures with China.

Bessent indicated that countries negotiating in good faith may receive flexibility if deals are not finalized by the current deadline. The administration had previously announced that reciprocal tariffs, initially paused for 90 days, are set to take effect on July 8. However, that deadline may be extended for countries actively engaged in negotiations.

Importer Urges Court to Reject White House De Minimis Policy Argument

Auto parts importer Detroit Axle filed a brief with the U.S. Court of International Trade opposing the administration’s legal justification for limiting de minimis treatment on certain low-value imports. The administration has argued that its restrictions, particularly on Chinese goods, are lawful under national security and equity authorities.

Detroit Axle contended that the administration’s interpretation is overly broad and that neither the Trade Act of 1974 nor other statutes support the executive branch’s claimed discretion to revoke de minimis eligibility based on foreign policy considerations. The case is part of broader litigation surrounding the scope of executive trade enforcement powers.