25% Chip Tariff, UAS Carve‑outs, IEEPA Refund Path, FGV WRO Eased
NEWSLETTER | Trade Insight AI
U.S. Imposes 25% Section 232 Tariff on Advanced Chip Imports
STR Trade Report • January 16, 2026
Following a Jan. 14 proclamation under Section 232, the U.S. imposed a 25% tariff—effective Jan. 15—on imports from all countries of certain advanced computing chips, with covered goods exempt from some other additional tariffs listed in an annex. Exemptions include use in U.S. data centers, repairs/replacements, R&D, startups, non–data center consumer and civil industrial uses, public sector applications, and other uses that strengthen domestic tech supply chains or manufacturing. Broader semiconductor tariffs and a domestic manufacturing offset program are under consideration; Commerce will report by July 1 on data‑center chip markets, and USTR/Commerce talks could trigger additional country‑specific duties.
Tariff & Market Policy Watch
CIT Order Paves Refunds for Importers if Supreme Court Nixes IEEPA Tariffs
STR Trade Report •January 16, 2026
On Jan. 14, the Court of International Trade applied a government stipulation across cases, confirming that if the Supreme Court strikes down IEEPA tariffs, refunds will likely be available to all importers challenging all such tariffs—not just the “reciprocal” and “fentanyl” duties. The order extends potential relief to tariffs on Brazil and India and reduces the need for future stipulations or liquidation injunctions; importers should monitor liquidations and file protests to preserve refund rights pending the Supreme Court’s ruling.
CBAM Launches as EU-Mercosur, US-Taiwan, UAE-Philippines Deals Advance
STR Trade Report •January 15, 2026
The EU’s Carbon Border Adjustment Mechanism entered into force Jan. 1, with the Commission citing seamless data connectivity to keep import procedures running—ushering in immediate carbon-cost and compliance obligations for covered imports. Meanwhile, trade pacts gained momentum: the EU voted to proceed with the Mercosur agreement pending national ratifications; Taiwan reported a general consensus with the U.S. on reciprocal tariff cuts and preferential Section 232 treatment for semiconductors; and the Philippines and UAE signed their first free trade deal to expand goods and services. Ukraine also plans to discuss a zero-tariff FTA with the U.S., signaling potential future market-access shifts that companies should factor into tariff and sourcing plans.
CBSA Sets 2026 Compliance Audits: TRQs, Surtaxes, Auto Origin
STR Trade Report •January 15, 2026
Canada’s border agency issued its 2026 trade compliance priorities, signaling targeted verifications across TRQs for supply‑managed goods, GST/excise (including vaping products and precious metals), origin under USMCA auto rules and EU/UK FTAs, and surtax orders covering EVs, steel, and aluminum. Energy commodities—especially electricity imports—and duties relief licensees also face reviews, and CBSA notes priorities may shift during the year. Importers should strengthen classification, origin, and valuation support, validate TRQ and excise/GST coding, and confirm surtax applicability to mitigate audit risk.
U.S. Trade Deficit Plunges to 16-Year Low on Export Surge
STR Trade Report •January 14, 2026
The U.S. trade gap fell 39.1% to $29.4 billion in October—the lowest since 2009—as exports hit a record $302.0 billion and goods imports dropped 4.5% to $255.0 billion, led by a sharp pullback in pharmaceuticals. Goods exports rose 3.7% to a record $195.9 billion on surging non‑monetary gold and other precious metals; the goods deficit fell to $59.1 billion while the services surplus eased to $29.8 billion. Bilateral balances set record deficits with Mexico, Thailand, and Taiwan and record surpluses with Switzerland, the U.K., and Brazil, though the year‑to‑date gap remains 7.7% wider than 2024.
Ambassador Greer Meets Honduras’ President-elect Asfura, Signaling Trade Engagement
USTR Press Releases •January 15, 2026
USTR reported that Ambassador Greer met with Honduran President-elect Nasry Asfura, underscoring early engagement with the incoming administration on bilateral economic ties. While the readout offers limited detail, the meeting signals continued coordination within the broader CAFTA-DR relationship, with follow-on announcements likely to clarify priorities and timelines.
Technology Trade & Supply Chain Controls
FCC Carves Out Drone Import Exemptions Until Jan. 1, 2027
STR Trade Report •January 16, 2026
On Dec. 19, the FCC added all foreign-produced uncrewed aircraft systems (UAS) and critical components to its national security Covered List, effectively blocking new imports for U.S. use or sale. A subsequent notice creates time-limited exemptions through Jan. 1, 2027 for UAS on the Defense Contract Management Agency’s Blue UAS Cleared List and for products that qualify as domestic end-products under the Buy American Standard. Importers and integrators can maintain limited sourcing under these carve-outs but should verify eligibility and maintain documentation to mitigate compliance risk.
BIS Fines Firm $1.5M for EAR99 Transfers to Entity List in China
STR Trade Report •January 16, 2026
BIS imposed a $1.5 million penalty for 13 alleged EAR violations after a company enabled in‑country transfers of nearly 900 EAR99 items to a Chinese Entity List end user building a semiconductor fab without a required license. The case highlights gaps in distributor oversight and misunderstanding of U.S. jurisdiction over in-country transfers in China; the company investigated, retained outside counsel, and voluntarily disclosed. Takeaway: end-user screening and licensing controls are essential even for EAR99 items and intra‑China movements.
ITC 337 Actions Target Power Converters, Rosin Esters, Wearables
STR Trade Report •January 15, 2026
The U.S. ITC received a new Section 337 complaint involving power converters and circuit board assemblies (Vicor) and instituted two investigations: 337-TA-1476 on glycerol esters of rosin (T&R Chemicals) and 337-TA-1477 on wearable devices with fall detection (UnaliWear). Respondents span Taiwan, China, the U.S., France, Portugal, Switzerland, and Korea, and potential exclusion or cease‑and‑desist orders could restrict imports of affected components and finished goods. Importers and OEMs in electronics, chemicals, and wearables should assess exposure and prepare sourcing or design contingencies.
USTR Launches Critical Minerals Talks to Bolster Clean‑Tech Supply Chains
USTR Press Releases •January 14, 2026
USTR announced the start of negotiations on a critical minerals framework intended to secure and diversify supply chains while aligning high-standard labor and environmental practices. The outcome could shape sourcing strategies for EV batteries and clean energy technologies, influence rules of origin and eligibility for incentives, and signal deeper cooperation on traceability and permitting; stakeholders should monitor for consultation opportunities as scope and timeline emerge.
Enforcement, Case Law & Market Access
CAFC Affirms Transaction Value; Backs CBP Liquidation Extensions
STR Trade Report •January 16, 2026
The Federal Circuit upheld the CIT’s finding that transaction value applies to Christmas ornaments routed through Canada because the sales were for exportation to the United States, rejecting the importer’s push to use deductive value under 19 USC 1401a(b)(1). The court also sustained CBP’s extensions of the one‑year liquidation deadline to complete audits, concluding the agency acted within its discretion. The ruling reinforces that intent and destination drive valuation and confirms CBP latitude on liquidation timing, shaping how importers structure sales and manage audit risk.
Sunset Reviews Favor Maintaining Orders; New PET Film Margins Posted
STR Trade Report •January 15, 2026
Commerce and the ITC issued sunset review findings signaling continued AD/CVD coverage for acetone (Belgium, Singapore, South Africa, South Korea, Spain), tow-behind lawn groomers from China (dumping up to 386.28%), steel wire rod (Brazil, Indonesia, Mexico, Moldova, Trinidad & Tobago; Brazil CVD 2.76–6.74%), and utility-scale wind towers (Canada, Indonesia, Korea, Vietnam; Canada and Vietnam CVD 1.13% and 2.84%). Separately, preliminary reviews on Indian PET film set a 24.14% dumping margin for July 1, 2023–June 30, 2024 and CVD rates of 10.03% and 12.41% for calendar 2023. Importers should plan for ongoing duty exposure and verify current cash-deposit rates and scope coverage.
CBP Modifies WRO, Reopens U.S. Market to FGV Palm Oil
CBP Media Releases •January 15, 2026
On Jan. 15, 2026, U.S. Customs and Border Protection modified its September 2020 Withhold Release Order on Malaysia’s FGV Holdings Berhad, allowing palm oil and palm oil products to enter the U.S. after the company remediated forced labor issues. The first WRO modification of FY 2026, the move underscores that documented corrective actions can restore market access; since 2019, CBP actions in Malaysia’s palm oil and glove sectors have yielded over $85 million in repayments to workers. Importers may resume sourcing from FGV but should maintain strong forced-labor due diligence and ensure shipments remain otherwise compliant with U.S. laws.
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