Recent Developments

U.S. tariffs on Canada and Mexico take effect. 

• On March 4, President Trump’s tariffs against Canada and Mexico took effect following a one-month pause.
• Canadian Prime Minister Justin Trudeau responded by levying retaliatory tariffs on C $30 billion (~USD $21 billion) of U.S. goods, which eventually could range up to C $155 billion (USD $108 billion) total, although to date, Mexican President Claudia Scheinbaum has held off on announcing retaliatory measures.
• On March 5, following conversations with leaders in the automotive industry, the Trump Administration announced a one-month pause on tariffs for imported automobiles that comply with the rules of origin under the United States-Mexico-Canada Agreement (“USMCA”).
• Shortly thereafter, the administration carved out an exemption for all imports from Canada and Mexico that fall under the USMCA—estimated to account for approximately 38 percent and 50 percent of imports from Canada and Mexico, respectively.
• On March 10, Ontario Premier Doug Ford announced a 25 percent surcharge on electricity exports to New York, Minnesota, and Michigan. In response, on March 11, President Trump announced the doubling of tariffs on Canadian steel and aluminum from 25 percent to 50 percent. Later that day, both parties agreed to suspend these threatened actions. 

President Trump doubles tariffs on imports from China. On March 3, President Trump amended Executive Order 14195 (“Imposing Duties to Address the Synthetic Opioid Supply Chain”) to increase tariffs on Chinese goods from 10 percent to 20 percent, effective March 4, 2025. Beijing responded in kind, implementing tariffs on U.S. agricultural imports (including wheat, soybeans, pork, etc.), suspending imports of U.S.-origin lumber, and adding 15 American companies to its export control list and 10 countries to its unreliable entity list. The Chinese Embassy in the United States stated on X, “If war is what the U.S. wants, be it a tariff war, a trade war or any other type of war, we’re ready to fight till the end.” 

President Trump’s tariffs on steel and aluminum go into force, and trading partners retaliate. On March 12, the United States imposed 25 percent tariffs on steel and aluminum products, as President Trump had previously promised. The European Union and Canada immediately announced that they would impose retaliatory tariffs on U.S. exports. The European Union’s countermeasures are scheduled to come in two phases, a first set of tariffs on $8 billion in goods on April 1, and an $18 billion package sometime in mid-April. At press time, it was being reported that Canada would impose duties on C $29.8 billion (USD $21 billion) worth of goods, to go into effect at 12:01 am Thursday March 13. Other exporters of steel and aluminum to the United States have not yet announced any countermeasures.

White House unveils “America First” investment policy. On February 21, President Trump issued a Memorandum to various U.S. executive departments regarding the administration’s “America First” investment policy. The memorandum calls for “fast track” review by the Committee on Foreign Investment in the United States (“CFIUS”) of investments by allied country investors that can demonstrate “verifiable distance” from China, as well as the curbing of U.S. investments by China-linked parties. Furthermore, the memorandum refers to potential new restrictions on U.S. outbound investment into China across various sectors. See our alert.

President Trump initiates Section 232 investigations into copper and lumber imports. On February 25 and March 1, President Trump directed the U.S. Department of Commerce (“Commerce”) to begin investigations under Section 232 of the Trade Expansion Act into copper and lumber imports, respectively. Generally, a 232 investigation requires Commerce to evaluate the national security risks associated with the imported product under investigation. Commerce has until November 22 and November 26 to issue its reports and tariff suggestions for copper and lumber, respectively. President Trump followed these measures with an executive order to immediately expand U.S. domestic timber production.

President Trump confirms goal of instituting “reciprocal tariffs” on April 2. As previously reported, President Trump requested an assessment no later than April 1 on instituting a reciprocal tariff regime. In this regime, the United States will impose tariffs on countries that impose trade barriers on U.S. goods, e.g., tariffs and unfair trade practices. The Office of the United States Trade Representative solicited public comment in support of this assessment. President Trump has since stated that he intends for these tariffs to come into force on April 2.  

Taiwan Semiconductor Manufacturing Co. announces $100 billion investment into chip manufacturing operations in the United States. On March 3, Taiwan Semiconductor Manufacturing Co. (“TSMC”) Chief Executive Officer Dr. C.C. Wei and President Trump announced an additional $100 billion investment by TSMC into U.S. chipmaking operations. This move aims to bolster U.S. national security efforts by increasing domestic chip production and reducing reliance on foreign-made semiconductors. The investment announcement came just days before President Trump called for the repeal of the CHIPS Act, a bipartisan law that provides for subsidization of U.S. semiconductor manufacturing. 

Ukraine accepts U.S.-led ceasefire proposal, putting ball in Russia’s court and setting up a critical minerals deal. On March 11, Ukraine agreed to an American-led ceasefire proposal following negotiations in Saudi Arabia, although the deal still awaits Russia’s response. The agreement marked a turnaround in U.S.-Ukraine relations following Ukrainian President Volodymyr Zelensky’s contentious February White House meeting with President Donald Trump and Vice President J.D. Vance, which had set off a chain of events resulting in the United States suspending military aid to Ukraine, a move that the Trump Administration immediately reversed upon reaching the ceasefire agreement. Furthermore, the U.S.-Ukraine Joint Statement following the March 11 meeting notes that President Trump and President Zelensky agreed “to conclude as soon as possible” an agreement regarding U.S. development of Ukrainian critical mineral resources.

Conservatives secure majority vote in German federal election. In late February, Friedrich Merz’s CDU/CSU alliance claimed victory in the German federal election, securing approximately 28.5 percent of the vote and positioning Merz to become the next Chancellor. The CDU/CSU intends to form a coalition with the Social Democrats (“SPD”) instead of the Alternative for Germany (“AFD”) party, which became the second-largest party in the Bundestag. Following the victory, Merz remarked during a post-election debate, “My absolute priority will be to strengthen Europe as quickly as possible so that, step by step, we can really achieve independence from the USA.”

Vice President Vance remarks at Munich Security Conference rankle European countries. On February 14, Vice President J.D. Vance, speaking at the 61st Munich Security Conference, delivered remarks that criticized European restrictions on free speech and its approach to security, arguing that the continent was stifling open discourse. The speech drew negative reactions from U.S. allies, including German Defense Minister Borris Pistorius, who said that the vice president’s comments were “not acceptable.”

U.S. Department of State designates certain Latin American cartels as terrorist organizations. On February 20, the U.S. Department of State (“State”) designated certain international cartels, including Mara Salvatrucha (“MS-13”), South America-based Tren de Aragua (“TdA”) and Cártel de Jalisco Nueva Generación (“CJNG”), as both Foreign Terrorist Organizations (“FTOs”) and Specially Designated Global Terrorists (“SDGTs”). The terrorist designations could present significant compliance challenges for companies that operate in areas controlled by cartels. See our alert.

U.S. trade deficit rose sharply in January ahead of Trump tariffs. The U.S. trade deficit grew by 34 percent in January to $131.4 billion, largely driven by a 10 percent increase in imports, which grew to $401.2 billion. Reports indicate that the spike in the deficit may have been driven by American companies frontloading imports in anticipation of upcoming tariffs.

George T. Boggs and Kathleen H. Shannon contributed to this article