What Happened This Month In International Trade (September 2025)

Another busy month in international trade news. Here's the full roundup:

Administration

• On September 5, 2025, President Trump signedExecutive Order 14257 modifying the scope of reciprocal tariffs. The EO carves out dozens of items, including nearly 40 minerals.
• President Trumpthreatened a 301 investigation of the European Union if it does not stop its "discriminatory actions" of large fines against U.S. tech companies.
• The Administration published the Spring 2025Unified Agenda of Regulatory and Deregulatory Actions. Several regulations impacting international trade were identified, including regulations from the State Department, FDA, Treasury, USDA, and the FMC.
• President Donald Trump announced viasocial media that the Administration will be imposing new tariffs on kitchen cabinets, bathroom vanities, upholstered furniture, brand-name pharmaceuticals, and heavy trucks. The tariffs are set to begin on Oct 1.

Customs and Border Protection (CBP)

• CBP published a new 2025 tariff requirements cheat sheet. Viewhere.
• CBP published a press releaseannouncing enforcement and processes for the end of the de minimis exception.
• CBPannounced at the September COAC meeting that the agency is planning to release a dedicated forced labor portal in FY 2026 that importers will be required to use.
• CBPissued a withhold release order blocking imports of bicycles, bicycle parts, and accessories from Taiwanese manufacturer Giant Manufacturing.
• The customs broker permit user feewill change from $180.57 to $185.38. All broker permits issued on or after October 1, 2025, are subject to the new user fee.

Industry News

• The Supreme Courtwill hear two cases that challenge the legality of tariffs imposed under the International Emergency Economic Powers Act. Arguments are set for the first week of November.
• On September 25, 2025, the U.S. Court of Appeals for the Federal Circuit (CAFC) upheld the legality of Lists 3 and 4A of the Section 301 tariffs in HMTX Industries LLC v. United States. The Section 301 tariff originated from the first Trump administration, where the U.S. Trade Representative, through Section 301 of the Trade Act of 1974, imposed tariffs ranging from 7.5% to 25% on imports from China.

Department of Justice (DOJ)

• The DOJlaunched a cross-agency Trade Fraud Task Force to ramp up enforcement against importers who seek to defraud the United States.
• Two company executives from Chinawere sentenced to 25 and 15 years in prison for fentanyl precursor importation.

Department of Commerce

• Commerceannounced an investigation into the import of and supply chains for personal protective equipment, medical consumables, medical equipment, and medical devices. The investigation is to determine if the import of these goods is a threat to national security under Section 232.
• Commerceannounced an investigation into the import of industrial machinery and robotics, and whether domestic producers should be protected to improve U.S. national security.
• Commerceannounced that tariff cuts for automobiles and auto parts under the US-EU trade deal will apply to goods entered for consumption on or after August 1, 2025.

International Trade Commission (ITC)

• Three U.S. quartz manufacturersfiled a petition asking the ITC to conduct a Section 201 safeguard investigation on imports of quartz surface products. The petition seeks to safeguard quotas and tariffs on these products.

Bureau of Industry and Security (BIS)

• BISannounced that the first window for requests for new auto parts to be covered by Section 232 tariffs will open Oct. 1. The submission window will remain open for 14 days, followed by a 60-day review period.
• BISannounced the agency is again accepting requests for new products to be included under Section 232 tariffs on steel and aluminum derivatives. Requests will be accepted through Sept. 29.

Office of Foreign Assets Control (OFAC)

• OFACannounced that a Houston-based freight forwarder has agreed to pay $1.6M to settle its potential civil liability for apparent violations of multiple OFAC sanctions programs, including those on Venezuela and Iran.
• Updates to the Specially Designated Nationals list.

United States Trade Representative (USTR)

• The USTR isseeking comments for its annual National Trade Estimate Report on Foreign Trade Barriers. Comments are due by Oct. 30.
• USTR isseeking comment on how the USMCA is working, as the three participating countries begin a joint review of the pact in July 2026. The comment period began Sept. 17 and will last for 45 days.
• USTR isseeking comments on whether any of the 178 existing Section 301 exclusions should be extended past Nov. 29. Comments must be submitted by Oct. 16.

Food and Drug Administration (FDA)

• The FDAplaced four companies on Import Alert for improperly weighing seafood.
• The FDA announced the launch of theFDA Adverse Event Reporting System (FAERS) Public Dashboard for Cosmetic Products, an interactive tool designed to facilitate the public's ability to query real-time adverse event data on cosmetic products.

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