On June 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that its recent designations to the Specially Designated Nationals and Blocked Entities (SDN) List targeted Iran’s steel, aluminum, copper, and iron sectors. OFAC designated eight entities operating in the Iranian metals sector including companies from Iran, the United
Aluminum
Commerce Seeks Comments on the Product Exclusion Process for Section 232 Steel and Aluminum Tariffs
The Department of Commerce has issued a Federal Register notice seeking public comment on (1) the appropriateness of the information its Bureau of Industry and Security (BIS) requested and considered in applying the Section 232 exclusion criteria to product exclusion requests, and (2) the efficiency and transparency of the product exclusion process itself. This request…
U.S. Departments of State and Treasury and U.S. Coast Guard Issue Advisory Addressing Illicit Shipping and Sanctions Evasion Practices
On May 14, 2020, the U.S. Departments of State and Treasury and the U.S. Coast Guard issued a global advisory to alert the maritime industry and those active in the energy and metals sectors to deceptive shipping practices used to evade U.S. economic sanctions. It is intended to provide exporters, shippers and others utilizing the…
USTR Grants Extensions for Imported Chinese Products With Section 301 Tariff Exclusions Expiring May 14, 2020
The Office of the U.S. Trade Representative (USTR), after seeking comments on whether to extend for up to 12 months exclusions from the Section 301 tariffs granted in May 2019 for certain imports from China (see Trump and Trade Update of March 2, 2020), has approved 13 extensions covering the following Harmonized Tariff…
USTR Issues Additional China Section 301 Tariff Exclusions for List/Tranche 3 Products
The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice exempting Section 301 tariffs for certain List 3 (imports from China with an annual trade value of $200 billion) products. The exemptions cover two 10-digit Harmonized Tariff System (HTS) subheading and 144 specially-prepared product descriptions, which cover 185 separately submitted exclusion…
Thyssenkrupp Materials NA, Inc. Becomes Latest U.S. Aluminum and Steel Importer to Challenge Section 232 Duties
On April 21, 2020, Thyssenkrupp Materials NA, Inc., and several of its related operating divisions filed a complaint in the U.S. Court of International Trade (CIT) against the United States alleging that the federal government’s administration of Section 232 aluminum and steel duties is unconstitutional. Thyssenkrupp is a Michigan-based importer of aluminum and steel products…
USTR Grants Extensions for China Section 301 Exclusions Set to Expire April 18, 2020
The Office of the U.S. Trade Representative (USTR), after seeking comments on whether to extend for another year certain product exclusions it granted in April 2019 (see Trump and Trade Update of February 5, 2020), has granted eight extensions covering the following Harmonized Tariff Schedule (HTS) subheadings and product descriptions:
- Roller machines designed
…
DOJ Argues President Can Modify Section 232 Tariffs at Any Time to Protect National Security
PrimeSource Building Products, Inc., a U.S. importer of various steel derivative products, filed an amended complaint in the U.S. Court of International Trade (CIT) on February 4, 2020, arguing that President Donald Trump’s Proclamation No. 9980 is unlawful and unconstitutional. This proclamation expanded the implementation of steel and aluminum tariffs under Section 232 of the…
USTR Issues Additional China Section 301 Tariff Exclusions for List/Tranche 3 Products
The Office of the U.S. Trade Representative (USTR) has issued a Federal Register notice exempting Section 301 tariffs for certain List 3 (imports from China with an annual trade value of $200 billion) products. The exemptions cover one 10-digit Harmonized Tariff System (HTS) subheading and 176 specially-prepared product descriptions, which combined cover 202 separately submitted…
In Annual Reports to Congress, USTR Continues to Criticize Russia and China for Poor WTO Compliance
Recently, the U.S. Trade Representative (USTR) issued its annual reports to Congress assessing how the People’s Republic of China (China) and the Russian Federation (Russia) have been complying with their World Trade Organization (WTO) accession agreements, including both their multilateral commitments and bilateral commitments with the United States. China became a member of the WTO…

