US
New tariffs on imported steel and aluminum apply from 12 March
On 12 March, increased tariffs on all steel and aluminum imports to the US came into effect. The tariffs have been increased to a flat rate of 25% (from the previous rate of 10%) “without exceptions or exemptions”. Existing country exceptions, quota deals and product-specific tariff exclusions for both metals have been eliminated under the new rules, which now also extend to downstream products using foreign-made steel. This includes products such as fabricated structural steel, aluminum extrusions and steel strand for pre-stressed concrete. To prevent imports of minimally processed metals, a requirement for steel imports to be “melted and poured” in the US is also introduced.
Impact: The new tariffs will raise costs for businesses importing steel and aluminum materials, and have potential to disrupt supply chains as companies try to find alternative suppliers. Importers will need to ensure compliance with the new rules, including providing documentation to verify the origin and processing of steel articles.
Further tariff announcements expected
Announcements on further tariffs are expected on 2 April, following the delivery of reports directed by the America First Policy Memorandum, and Defending American Companies and Innovators from Overseas Extortion and Unfair Fines and Penalties memorandum. These are likely to include announcements of reciprocal tariffs on the EU and various other countries, as well as the introduction of tariffs or investigations into several industries (including the pharmaceuticals, automobiles and semiconductors).
The current status of tariffs on goods from Mexico and Canada may also be subject to change. 25% tariffs on goods imported from Mexico and Canada, and 10% tariffs on energy resources from Canada came into effect on March 4. However, on March 6 a temporary exemption was introduced for certain goods under the United States-Mexico-Canada Agreement (USMCA).
In addition, President Trump has ordered investigations into the copper, timber and lumber industries, which could result in additional tariffs on imports. Investigation reports are due in November 2025.
For more information please see our Trump Administration Legal Impact Hub, and briefing on Executive Orders on timber and lumber.
Proposed measures to crackdown on de minimis shipments
In a series of Executive Orders from the start of 2025, President Trump has signaled a halt to low-value import exemptions. Currently, a shipment is eligible for the de minimis exemption if the value of the articles imported is less than $800 per day per person.
Similar measures aimed at low-value imports from Canada and Mexico, were announced and then paused until March 4, 2025. After initially coming into force for goods from China, on February 7, 2025, President Trump paused the measure. In the first week of March 2025, President Trump signed further Executive Orders to provide that products of Canada and Mexico entered into the US using the de minimis exemption could continue to do so. This is intended to give the Commerce Department time to make the order workable.
Impact: Although there is some uncertainty on the timings and the extent of the proposed measures, a crackdown on the de minimis exemption could happen in 2025 as there is political consensus. The Biden administration announced measures to restrict low-value imports in September 2024.
Some businesses, particularly in China, have expanded in the US with direct-to-consumer business models based on the $800 de minimis rule to keep prices low. These importing manufacturers may face higher costs and increased tariffs on low-value goods. This change could disrupt supply chains and raises prices for consumers. Manufacturers may have to navigate more complex customs procedures and compliance requirements, impacting their operational efficiency and profitability.
Extra customs checks could also impact shipping operators.
Executive Order imposing tariff on Chinese goods
On February 4, President Trump’s Executive Order imposing a 10% tariff on all products from China became effective. This amount was subsequently increased to 20% on March 3. This action is in response to China’s reported failure to control the export of fentanyl and related chemicals. President Trump confirmed these tariffs will remain until adequate steps are taken to alleviate the issue.
Impact: The 20% tariff on Chinese goods will increase import costs, potentially raising prices for U.S. consumers and businesses. Supply chains may face disruptions as companies seek alternative sources or adjust procurement strategies. The tariffs could also further strain US-China trade relations, impacting broader economic and trade dynamics.
Executive Order establishing a Sovereign Wealth Fund
On February 2, President Trump signed an Executive Order to establish a US Sovereign Wealth Fund. The plan, to be developed by the Treasury and Commerce Secretaries, will include funding mechanisms, investment strategies, and a governance model. The fund seeks to enhance fiscal sustainability, reduce tax burdens, and secure economic security for future generations. The plan will be submitted to the President within 90 days.
Impact: Once established, the wealth fund may provide financial stability and investment in infrastructure, technology, and innovation. This could enhance domestic production capabilities, reduce reliance on foreign suppliers, and strengthen supply chain resilience. Additionally, strategic investments might support critical industries, further securing supply chains against global disruptions.
Inflation Reduction Act funding frozen
On January 22, an Executive Order was issued suspending all funding disbursements for the Inflation Reduction Act and the Infrastructure Investment and Jobs Act. Federal agencies have 90 days to review and submit spending recommendations.
Impact: The decision aims to eliminate regulatory barriers and simplify permitting processes. This suspension affects supply chains for clean energy projects, potentially delaying or halting ongoing and planned initiatives. Businesses involved in these projects may need to reassess their operations and secure alternative funding.
Stargate project Announced
On January 21, the Stargate project, a Government joint venture with several private organizations was announced by President Trump at a press conference. The plan involves investing up to $500 billion in AI infrastructure, aiming to build data centers and electricity generation. The project seeks to enhance AI development, optimize supply chains, and drive innovations in digital health records and customized vaccines.
Impact: The Stargate project’s announcement will have both direct and indirect impacts on supply chains. Directly, the investment in AI infrastructure, such as data centers and electricity generation, will enhance the efficiency and resilience of supply chains by optimizing logistics, improving inventory management, and predicting demand more accurately. Indirectly, advancements in AI technology can lead to innovations in various industries, further improving supply chain processes and creating new opportunities for growth and efficiency.
Executive Order on Trade Policy
On January 20, an Executive Order was issued, that emphasizes the use of tariffs and trade barriers to protect American industries and jobs. Under President Trump, trade policy will be treated as a critical component of national security, aiming to reduce dependence on foreign countries for key security needs. The order will lead to the establishment of an External Revenue Service, which will collect tariffs, duties, and other foreign trade-related revenues.
Impact: This Executive Order underscores the wider shift towards self-reliance under the Trump administration. As a result of the higher tariffs implemented, the flow of international goods may be affected, requiring businesses linked to the US to re-evaluate and adjust their supply chains to mitigate potential impacts.
Amendments to H-1B visa eligibility requirements published
On January 17, the final rule updating H-1B visa eligibility requirements became effective. The rule revises the definition of "specialty occupation," updates definitions for nonprofit and governmental research organizations, and clarifies visa petition requirements.
Impact: Employers should prepare for potential disruptions as new forms and standards are implemented. Businesses may need to adjust hiring practices, update compliance procedures, and train staff on new requirements to ensure smooth operations and avoid disruptions.
Final Rule to Ban Imports, Sales of Connected Vehicles with China/Russia Links published
On January 16, the Department of Commerce Bureau of Industry and Security issued a final rule prohibiting the import and sale of connected vehicles and systems with components from China or Russia. This rule targets Vehicle Connectivity Systems (VCS) and Automated Driving Systems to mitigate national security risks. It emphasizes due diligence and recordkeeping for supply chains, requiring declarations of conformity and prohibiting transactions involving VCS hardware or software from entities linked to China or Russia.
Impact: The rules require automotive manufacturers and suppliers to verify that the connected vehicle or advanced autonomous vehicle software used in their products has not been developed in China, Russia or other similar countries. Certain importers and manufacturers are required to submit annual Declarations of Conformity to certify their compliance with the prohibitions.
The rule will be implemented from model year 2027 for software-related prohibitions, and from model year 2030, or January 1, 2029, for hardware-related prohibitions.
For more information, please see our briefing.
FDA issues proposed rule on packaging nutrition labelling
On January 14, the Food and Drug Administration (FDA) issued a proposed rule on front-of-package nutrition labeling. The rule requires food products to display a “Nutrition Info” box on the top third of the principal display panel, showing the percent Daily Value (%DV) for sodium, saturated fat, and added sugars, with interpretive markers “High,” “Med,” or “Low.” The rule aims to help consumers make healthier dietary choices. Comments are due by 16 May 2025.
Impact: This proposed rule is significant for both domestic and global supply chains as it standardizes nutrition labeling, potentially influencing international food labeling practices. Businesses will need to update their packaging to comply with the new labeling requirements, ensuring accurate %DV information and interpretive markers are displayed. This may involve redesigning labels, adjusting production processes, and training staff to understand and implement the new standards.
Supply Chain Resiliency Initiative approved
On January 7, the Export-Import Bank of the United States approved the Supply Chain Resiliency Initiative to reduce reliance on China for critical minerals and rare earth elements. This initiative provides financing to secure these materials from trusted international partners, supporting U.S. manufacturing and national security. It aims to strengthen domestic supply chains, protect American jobs, and foster economic growth by ensuring critical resources are available for transformative technologies like battery storage and semiconductors.
Impact: The Supply Chain Resiliency Initiative will diversify supply sources, reducing dependency on China for critical minerals and rare earth elements. This will enhance the stability and security of supply chains, support U.S. manufacturing, and ensure the availability of essential materials for advanced technologies, fostering a more resilient and robust supply chain network.
Consultation launched on potential unmanned aircraft system technology rules
On January 2, the Department of Commerce’s BIS issued an advance notice of proposed rulemaking to secure the Information and Communication Technology and Services (ICTS) supply chain for unmanned aircraft systems. The notice seeks public comment on definitions, risk assessments, and mitigation measures related to UAS components from foreign adversaries. This step aims to protect U.S. national security by addressing vulnerabilities in the commercial drone market. Public comments are due by March 4, 2025.
Impact: The proposed rules aim to secure the ICTS supply chain by addressing risks from foreign adversaries. This could lead to stricter security measures, supply chain disruptions, increased costs, and market shifts favoring domestic suppliers. While enhancing national security, these changes may drive innovation but also pose challenges for businesses adapting to new regulations.
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