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Key Takeaway: Since the start of the Trump administration, the Office of the U.S. Trade Representative (USTR) has maintained a central role in shaping tariff policy, helping drive 48 major changes to tariff rates — likely more than were undertaken in the prior century. The earlier somewhat scattershot approach has now coalesced into a more defined strategy built around three Section 301 tariff regimes (the original China measures, forced labor tariffs, and the coming “manufacturing oversupply” tariffs) alongside a growing use of Section 232 duties (already implemented tariffs on steel, aluminum, automobiles and auto parts, and other sectors, and ongoing probes involving semiconductors, pharmaceuticals, copper, and critical minerals). At the same time, the administration is making a push for a major overhaul of the United States-Mexico-Canada Agreement (USMCA), which could lead to future tariff changes and new origination rules. With multiple Section 232 investigations still pending, and with broad new Section 301 tariffs on manufacturing oversupply expected to reach roughly 16 countries encompassing most major U.S. trading partners, importers and companies that depend on global sourcing should continue to prioritize flexibility in their supply chains, sourcing strategies, and customs planning.
This Week in International Trade: With March Madness still many months away, a gentle suggestion is that we create a “when will we hit the 50th major trade action?” pool. Instead of picking upsets and Final Four sleepers, participants can wager on whether the next big move comes through Section 301, Section 232, sanctions, or the unearthing of yet another never-before-applied tariff authority. Ties could be broken by predictions of how the Federal Circuit will rule in Section 122 tariff refund litigation. The winner could receive one glorious day of importing at 2024 tariff rates. The timing is ideal, because the odds are we will hit 50 well before the first tipoff in March.
While you check the latest Cargo Systems Messaging Service (CSMS) messages to see whether Customs and Border Protection (CBP) is adding betting-pool functionality to the Automated Commercial Environment (ACE), here are some updates on the latest international trade developments:
| • | U.S. and China Agree to Extension of Limited Trade Truce. The United States and China have agreed to extend their existing trade truce for two months, according to USTR Jamieson Greer, while continuing negotiations toward a broader agreement. Greer described the extension as a “compliance period” that will give U.S. officials more time to evaluate whether China is meeting commitments tied to the truce, including purchases of U.S. agricultural products and exports of key minerals to U.S. companies. He also said the two sides have agreed in principle to preferential tariff treatment for a subset of goods, potentially covering Chinese consumer goods and other “nonsensitive” products, as well as U.S. agricultural and medical device exports. The extension preserves a managed-trade arrangement that had paused certain planned U.S. sanctions and export control expansions and prompted China to ease some mineral export licensing measures. |
| • | CBP’s Authority to Offset Unrelated Debt Against IEEPA Refunds Remains Unresolved. The Court of International Trade declined to lift a stay in a case challenging CBP’s handling of International Emergency Economic Powers Act (IEEPA) duty refunds, ruling that the importer’s request to block offsets against disputed debts was premature because no offset had yet been applied to that exact litigant. But the issue seems likely to return to court soon, as CBP reportedly continues offsetting IEEPA refunds in other matters, raising unresolved questions about what authority the agency has to use those refunds as a debt-collection mechanism, particularly where the alleged debts remain disputed. |
| • | Potential New Russia Tariffs. The countdown to October 18, 2026, is underway under the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which gives the administration 30 days to decide whether, and to what extent, to impose sweeping new tariffs and sanctions on Russia and related third countries. The law authorizes tariffs of up to 500 percent on Russian-origin goods and up to 100 percent tariffs on the five largest purchasers of Russian oil and natural gas and the five leading facilitators of Russian sanctions evasion, while also expanding broader sanctions authorities and extending the Iran Sanctions Act through 2031. President Trump retains authority to waive some or all of these measures if he determines doing so is in the national interest. |
| • | Potential Section 201 Tire Tariffs Coming. The United Steelworkers is urging USTR to pursue a Section 201 safeguard investigation into tire imports, arguing that rising imports have contributed to a roughly 40 percent decline in U.S. tire production since 2000 and continued losses in domestic jobs and manufacturing. The union says existing Antidumping and Countervailing Duties (AD/CVD) orders have not solved the problem because production has shifted to countries not currently covered, making broader-based relief such as graduated import limits and tariffs important to protect the U.S. passenger, truck, off-road, and aircraft tire producers. If USTR backs the request, the matter would go to the International Trade Commission (ITC), which would have 180 days to determine whether imports are causing serious injury and, if so, what relief to recommend. |
| • | Polysilicon Anti-Stockpiling Rule Proposed. The Bureau of Industry and Security (BIS) has issued a temporary final rule aimed at preventing companies from stockpiling polysilicon and certain derivatives ahead of new import restrictions scheduled to take effect December 4, 2026, under the administration’s Section 232-related polysilicon measures. The rule allows BIS to identify importers bringing in volumes substantially above historic levels and, through CBP, bar them from making further entries before December 4 unless BIS grants a waiver. It also places strict volume caps on newer importers of record registered on or after August 6, 2026, and warns that importers and customs brokers could face enforcement action if they use multiple IORs or other arrangements to evade the limits. |
| • | Increased Mexican Customs Enforcement Potentially Coming. Mexico’s president has proposed amendments to the country’s customs law that would significantly increase customs scrutiny of declared import values. The proposal would eliminate the current 50 percent undervaluation threshold for precautionary seizure, require customs authorities to initiate verification procedures whenever they identify a declared value below that of identical or similar merchandise, and narrow the circumstances in which importers can avoid or replace a seizure. If enacted, the changes would lead to closer review of valuation practices and supporting documentation, particularly in related-party and other higher-risk transactions. |
Non-Trade Fun Fact of Interest Only to Me: Before the late 1800s, most cities set their clocks by the sun, so neighboring towns could keep slightly different local times. That worked well enough until railroads needed precise schedules across long distances, prompting U.S. rail companies to adopt standardized time zones in 1883 on what became known as “The Day of Two Noons,” because many towns reset their clocks at midday. The following year, the International Meridian Conference established the global framework centered on the Prime Meridian at Greenwich that underlies modern time zones—though a few quirks remain. France, due to its overseas territories, spans 12 time zones, while China geographically spans five but uses only one official national time, which simplifies business coordination but makes sunrise remarkably late in some places. All of which suggests that a Section 301 investigation into unfair time zone practices may be a trade remedy whose time has finally come. Gear up the USTR Section 301 tariff press.
