Safeguards on the Rise, CBAM Relief Advances, and Controls Tighten
NEWSLETTER | Trade Insight AI
Safeguard Petition Targets Quartz with 50% Tariffs, Country Quotas
STR Trade Report • September 19, 2025
A Section 201 petition filed Sept. 15 asks the ITC to investigate quartz surface products (slabs and fabricated) and consider country-specific import quotas or a 50% tariff—alternatively a weight-based specific duty. Petitioners argue existing AD/CVD orders on China, India, and Türkiye are being evaded via transshipment and misclassification, and seek broad, origin‑neutral relief covering HTSUS 6810.99.0020, 6810.99.0040, and 7020.00.6000. If the ITC makes an affirmative injury finding, it will recommend remedies to the president, who could impose tariffs/quotas/TRQs for up to four years (extendable to eight), potentially reshaping pricing and supply for engineered stone products.
Policy & Strategy Watch
EU Parliament Backs 50‑Ton CBAM Exemption for Most Importers
STR Trade Report •September 19, 2025
The European Parliament approved amendments to the EU’s Carbon Border Adjustment Mechanism creating a 50‑ton per‑importer annual threshold that would exempt roughly 90% of importers—mainly SMEs and individuals—from CBAM compliance, pending European Council endorsement. For remaining importers, the package streamlines authorization, emissions calculation, verification, and liability, while CBAM levies are still slated to phase in from 2026–2034 and a forthcoming review could extend coverage to downstream products and add anti‑circumvention measures.
USTR Opens USMCA Review: Comments Due Nov. 3, Hearing Nov. 17
STR Trade Report •September 18, 2025
USTR is soliciting public comments through Nov. 3 and will hold a Nov. 17 hearing to shape U.S. positions for the July 1, 2026 USMCA joint review, which will assess the agreement’s operation and decide on continuation beyond 2036. Input is sought on implementation, compliance, investment conditions, competitiveness and technology leadership, and strategies to bolster North American economic security and address non‑market practices. Early engagement can influence U.S. priorities on market access and supply chain resilience, as well as the Competitiveness Committee’s work on workforce development and maintaining trade flows during emergencies.
USTR invites comments on extending 178 China 301 exclusions past Nov. 29
USTR Press Releases •September 14, 2025
USTR is seeking public input on whether any of the 178 Section 301 tariff exclusions on Chinese goods—extended on September 2, 2025 and set to expire November 29, 2025—should be extended again. Importers relying on these exclusions should consider submitting comments to support continued relief and prepare for potential duty exposure if the exclusions lapse.
Export Controls & Tech Trade
BIS Adds 32 Entities to Entity List; Licenses Presumed Denied
STR Trade Report •September 19, 2025
BIS issued a final rule effective Sept. 12 adding 32 entities to the Entity List—23 in China, three in Türkiye, two in the UAE, and one each in India, Iran, Singapore, and Taiwan—while correcting 27 existing entries. All newly listed parties now require a license for any item subject to the EAR, with applications reviewed under a denial or presumption-of-denial policy; some listings also expand “items subject to the EAR” to include certain foreign-produced items. Shipments already en route on Sept. 12 may proceed under previous eligibility if completed by Oct. 14, giving exporters a brief window to clear affected transactions.
State Dept. Reclassifies Drone Export Reviews Under Fighter Aircraft Rules
STR Trade Report •September 19, 2025
The State Department will now review unmanned aerial system export requests under the same framework used for fighter aircraft rather than missile systems, aiming to streamline approvals. The shift complements recent MTCR-focused updates and builds on the 2020 UAS export policy, as part of broader reforms to the U.S. foreign defense sales system to improve accountability, transparency, and delivery. For exporters, the change could shorten timelines and expand market opportunities, while case-by-case reviews and nonproliferation safeguards remain.
Mexico Plans Tariffs, Tougher Customs; China Updates Trade Law; U.S. Export Shake-Up
STR Trade Report •September 18, 2025
Mexico is proposing import taxes on 1,400 products and advancing a customs law reform that expands customs agents’ obligations and toughens penalties, framed as part of ongoing talks with North American partners to bolster domestic industry and narrow deficits. China is moving to revise its Foreign Trade Law to codify a negative list for cross-border services, promote new trade models and digital trade, and establish a green trade framework. In Washington, President Trump withdrew the nomination of China hawk Heid to lead export administration at Commerce, creating near-term uncertainty for U.S. export control leadership, licensing timelines, and enforcement priorities.
Trade Remedies & Enforcement
AD/CVD Roundup: Hexamine Orders, Glycine Scope Expansion, Zero Citric Acid Margin
STR Trade Report •September 18, 2025
Commerce/ITC issued notable AD/CVD updates: final orders on Chinese hexamethylenetetramine effective Sept. 11 with cash deposits of 394.65% (AD) and 420.73% (CVD), and a final scope ruling bringing calcium glycinate under the multi-country glycine orders. Preliminary reviews set a zero dumping margin for Chinese citric acid/citrate salts (May 1, 2023–Apr. 30, 2024) and a 9.31% AD margin for Turkish circular welded pipe and tube for the same period, while final 2022 CVD rates on Chinese chlorinated isocyanurates were 3.61% and 4.55%. Importers—especially in chemicals and steel—should reassess sourcing and duty exposure and monitor final review outcomes for assessment and deposit implications.
USITC Clears AD/CVD on Chinese Counterbalance Torsion Springs; No Retroactive Duties
USITC News Releases •September 15, 2025
On September 15, 2025, the USITC found a U.S. industry materially injured by imports of overhead door counterbalance torsion springs from China sold at less than fair value and subsidized, enabling Commerce to issue antidumping and countervailing duty orders. The Commission rejected critical circumstances, so duties will apply prospectively upon order publication with no 90‑day lookback; importers should prepare for cash deposits at Commerce-set rates and assess sourcing options. The public report is expected by October 28, 2025.
AD/CVD Reviews: Zero for Turkish Pipe, 71.89% for China Cylinders
STR Trade Report •September 19, 2025
U.S. AD/CVD administrative reviews delivered mixed outcomes: a final AD review found a zero margin on Turkish large‑diameter welded pipe; preliminary CVD reviews on the same pipe set company-specific subsidy rates of 0.41% and 0.79% for Korea and 4.40% for Türkiye; preliminary AD rates were 3.06% for Omani PET resin and 71.89% for Chinese non‑refillable steel cylinders; final AD on Indian welded stainless pressure pipe was 21.77%, while preliminary AD on Indian silicomanganese was 0.48%. Importers should update cash deposits and reassess exposure for the 2023–2024 review periods, as shifts in margins may drive refunds, additional liabilities, or sourcing adjustments.
WTO & the Global Trade System
WTO Fisheries Subsidies Agreement Takes Effect, Targeting $22B in Harmful Aid
WTO Latest News •September 15, 2025
On 15 September, WTO members brought the Agreement on Fisheries Subsidies into force after surpassing the two‑thirds acceptance threshold, with Brazil, Kenya, Viet Nam, and Tonga among the latest to ratify. The deal bans subsidies for illegal, unreported and unregulated (IUU) fishing, for fishing overfished stocks, and for activities on the unregulated high seas—measures aimed at curbing an estimated $22 billion of the roughly $35 billion in annual fisheries subsidies. Governments should now review subsidy programs, strengthen monitoring and transparency via the new Committee on Fisheries Subsidies, and leverage the $18 million WTO Fish Fund for implementation support (first proposals due 9 October), as members push for universal ratification by the March 2026 ministerial.
WTO: AI Could Lift Global Trade up to 37% by 2040
WTO Latest News •September 17, 2025
WTO’s 2025 World Trade Report projects AI could raise cross-border trade by 34–37% and global GDP by 12–13% by 2040, contingent on open, predictable policies and closing digital infrastructure gaps. Access remains uneven: quantitative restrictions on AI-related goods climbed from 130 (2012) to nearly 500 (2024), and bound tariffs reach up to 45% in some low-income economies; a 50% narrowing of the digital gap could lift incomes 15% (low-income) and 14% (middle-income). The WTO urges members to expand ITA coverage, update GATS commitments, and invest in skills and labor policies to ensure inclusive gains.
WTO Public Forum 2025 puts digital trade governance, AI in focus
WTO Latest News •September 17, 2025
The WTO’s 2025 Public Forum opened in Geneva with 4,200 participants and 350 speakers, spotlighting how digital tools and AI are reshaping trade; the WTO also released its 2025 World Trade Report and convened an AI-focused panel. DG Ngozi Okonjo‑Iweala urged moving past pessimism—calling the system “bent, not broken”—and stressed that 72% of goods still trade under WTO terms while reforms are needed to restore predictability. New Trade Policy and WCP Research Hubs aim to bridge research and policymaking, signaling a push to align digital trade governance with business needs amid rising costs, SME pressures, and regulatory fragmentation.
WTO mobilizes partners to scale IFD needs assessments, unlock gains
WTO Latest News •September 16, 2025
On 16 September, DG Ngozi Okonjo-Iweala urged early implementation of the WTO’s Investment Facilitation for Development Agreement, calling for stronger partnerships to expand needs assessments that will target technical assistance under its special and differential treatment provisions. She cited potential global welfare gains of USD 295 billion–1.041 trillion, with most accruing to low- and middle-income countries, and noted that over 20 assessments are underway; 127 members are participating. Co-hosted by Chile and Korea, the dialogue drew support pledges from donors, development banks, UNCTAD, ITC, IDB and the World Economic Forum as members seek consensus to incorporate the plurilateral into the WTO rulebook.
WTO chief rallies parliaments for reform as fisheries pact takes effect
WTO Latest News •September 16, 2025
Addressing lawmakers in Geneva, DG Ngozi Okonjo-Iweala urged stronger parliamentary backing for WTO reform and multilateral cooperation, spotlighting the newly effective Agreement on Fisheries Subsidies, which targets roughly $22 billion in harmful subsidies tied to IUU fishing. She warned that unilateral tariffs have cut the share of world trade on MFN terms from 80% to 72%, reinforcing the need to update rules, overcome decision-making gridlock, and fix dispute settlement. She called for early, sustained political engagement to shape a reform package ahead of MC14 in Yaoundé in March 2026, with talks in Geneva facilitated by Norway’s Ambassador Petter Olberg.
Compliance & Operational Alerts
Commerce Codifies Quarterly Process to Expand Auto Parts 232 Tariffs
STR Trade Report •September 18, 2025
The Commerce Department issued an interim final rule establishing quarterly, two‑week filing windows for domestic automakers and parts producers to request inclusion of additional auto parts under Section 232 tariffs. The first window opens Oct. 1, 2025; valid requests will be posted for 14 days of public comment, with Commerce issuing determinations within 60 days and publishing any additions in the Federal Register. Comments on the procedures themselves are due Nov. 3, signaling imminent opportunities and risks for importers whose parts could be newly covered.
Annual FDA Device Facility Renewals Due Oct 1–Dec 31
STR Trade Report •September 18, 2025
U.S. and foreign medical device establishments—including contract manufacturers, specification developers, relabelers/repackers, initial importers, and foreign exporters—must renew FDA registrations annually, with most also required to list their devices. The renewal window runs Oct. 1–Dec. 31 each year; failure to submit, renew, update, or properly cancel can trigger import restrictions that block U.S. market access, even for products imported for export only. Trade teams should verify all supplier registrations (and U.S. agent coverage for foreign facilities) are current and renew regardless of the original registration date to avoid clearance delays or holds.
USTR Invites Input on 2026 NTE: Report Barriers by Oct. 30
USTR Press Releases •September 16, 2025
The Office of the U.S. Trade Representative is soliciting public comments on foreign measures that restrict U.S. exports of goods and services or U.S. foreign direct investment for inclusion in the 2026 National Trade Estimate. Comments are due October 30, 2025; submissions can shape USTR’s market‑access agenda, enforcement priorities, and future negotiations by elevating country‑ and sector‑specific barriers.
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