Tariff Whiplash: Refund Deadlines, India Surcharges, Critical Minerals 232
NEWSLETTER | Trade Insight AI
Tariff Refunds at Risk: Track Liquidations, File Protests Now
STR Trade Report • August 29, 2025
With sweeping IEEPA and expanded Section 232 tariffs in flux and key court appeals underway, importers face closing windows to preserve refund rights. Companies should monitor ACE for liquidation dates, request extensions, and file protests within 180 days—targeting issues like in‑transit exemptions, Chapter 98 claims, tariff stacking, de minimis repeal effective Aug. 29, content-based 232 assessments, and inconsistent COO/USMCA treatment. If courts ultimately invalidate IEEPA tariffs, refunds may be available only for entries protected by timely protests and, if needed, Court of International Trade actions.
Tariff & Policy Frontlines
Additional 25% Duty on Indian Imports Takes Effect; Key Exemptions Set
STR Trade Report •August 27, 2025
CBP issued HTSUS modifications implementing an additional 25% IEEPA tariff on India-origin goods, citing India’s direct or indirect imports of Russian oil. The duty applies to entries from 12:01 a.m. EDT Aug. 27, with an in‑transit carveout for shipments loaded before that time and entered by Sept. 17; it stacks on top of the 25% IEEPA “reciprocal” tariff effective Aug. 7 and any other duties. Exclusions cover Section 232 goods, items excepted under 50 USC 1702(b), articles exempt from the reciprocal tariff, and most Chapter 98 entries (with 9802 exceptions where duty applies to foreign value/repairs); CBP also specified HTS subheadings to claim exemptions, so importers should verify classifications and model cost exposure now.
DOI Drafts 2025 Critical Minerals List, Setting Stage for 232 Tariffs
STR Trade Report •August 28, 2025
DOI’s draft 2025 critical minerals list is open for comment through Sept. 25 and would add copper, lead, potash, rhenium, silicon, and silver while removing arsenic and tellurium; uranium and metallurgical coal are also under consideration. BIS’s Section 232 investigation into critical minerals and derivative products, with a final report due by mid-October, could recommend tariffs and other import restrictions that would replace the current reciprocal tariff rate and include anti-circumvention measures and domestic production incentives. Importers and manufacturers should map exposure to these minerals now and consider submitting comments.
USTR Extends Select China 301 Tariff Exclusions to November 29, 2025
USTR Press Releases •August 27, 2025
USTR has extended certain product exclusions under the China Section 301 tariffs that were set to expire August 31, 2025; they now run through November 29, 2025. The three-month extension preserves duty relief for covered imports, giving companies time to plan shipments and update broker instructions; details are in the Federal Register notice.
Trump escalates tariff threats; U.S.-Indonesia relief, Canada-Mercosur talks advance
STR Trade Report •August 28, 2025
Trump threatened substantial new tariffs and chip restrictions for countries with digital services taxes and warned of a 200% tariff on China if rare‑earth magnet exports are curbed, elevating tariff risk for tech and critical‑mineral supply chains. In contrast, the U.S. agreed in principle to lift tariffs on Indonesian palm oil, cocoa, and rubber in exchange for billions in Indonesian investment and purchases (crude, LPG, aircraft, agriculture) and a pledge of near‑zero tariffs on most U.S. goods—offering potential duty relief for U.S. buyers and new access for exporters. Canada and Mercosur will also restart FTA talks amid U.S. tariff uncertainty, potentially reshaping market access and sourcing options across the Americas.
Trade Remedies & Enforcement
U.S. AD/CVD: Tungsten Shot Orders, Broad Reviews, High Sunset Margins
STR Trade Report •August 28, 2025
Commerce issued AD/CVD orders on Chinese tungsten shot effective Aug. 27, with a 201.32% dumping margin and subsidy rates of 55.64% and 292.84%. Sunset reviews sustain the AD order on ceramic tile from China (margins up to 356.02%) and the CVD order on steel wire rod from China (178.46%–193.31%). Commerce also opened wide-ranging 2024–25 administrative reviews across numerous orders (including steel, tires, mattresses, PET film, and paper bags) and issued Q2 scope rulings that may affect product coverage.
AD/CVD: 294% Slag Pots, Quartz Sunset, German Paper Zero Margin
STR Trade Report •August 29, 2025
U.S. trade authorities issued a slate of remedy actions: final affirmative AD/CVD determinations on Chinese slag pots with a 294.43% dumping margin and a 226.16% subsidy rate; a sunset review finding that revoking the India quartz surface products order would likely lead to dumping up to 5.15%; and a zero dumping margin in the final administrative review of German thermal paper for 11/1/22–10/31/23. They also rescinded the 9/1/23–8/31/24 administrative review of Chinese magnesia carbon bricks and instructed CBP to liquidate entries at the applicable cash deposit rates. July scope ruling requests were filed covering Chinese magnesium metal and mobile access equipment, Italian pasta, and Indian stainless steel flanges—importers should monitor for coverage changes and duty exposure.
USITC Keeps Mexico Sugar Suspension Agreements After Expedited Sunset Review
USITC News Releases •August 28, 2025
On August 28, 2025, the USITC found that ending the suspended antidumping and countervailing duty investigations on sugar from Mexico would likely lead to continued or recurrent material injury, so the suspensions remain in place. The Commission conducted an expedited second five-year review after finding respondent participation inadequate; Chair Karpel and Commissioners Johanson and Kearns voted affirmative. A public report (USITC Pub. 5664) is due by October 3, 2025, signaling no near-term change to the existing regime for U.S. importers and Mexican exporters.
WTO panel report circulated on EU countervailing duties for Indonesian biodiesel
WTO Latest News •August 22, 2025
The WTO has circulated a panel report in Indonesia’s challenge to the European Union’s countervailing duties on biodiesel imports. The findings could shape how subsidies are assessed in the biofuels sector and affect EU market access for Indonesian producers; parties may appeal, potentially delaying any changes to duty rates and compliance obligations for traders.
North America Supply Chains & Border Ops
$535M donation agreements greenlight Otay Mesa East port of entry
CBP Media Releases •August 27, 2025
CBP, GSA, Caltrans, and SANDAG executed Donation Acceptance Agreements, authorizing construction of the Otay Mesa East port of entry as part of a $1.3 billion program. The new crossing is designed to strengthen security, reduce congestion and wait times, and improve freight flows in the San Diego–Baja California corridor. The deal leverages CBP’s Donations Acceptance Program to deliver added port capacity with taxpayer cost savings.
U.S. Triggers USMCA Labor Review at Alimentos Grole, Suspends Liquidation
USTR Press Releases •August 27, 2025
The United States invoked the USMCA Rapid Response Labor Mechanism to investigate alleged denials of freedom of association and collective bargaining at Alimentos Grole’s Ciudad Obregón meat plant, and suspended liquidation of unliquidated entries from the facility. A petition filed July 29 by workers affiliated with SITIES alleges intimidation, dismissals, and promotion of a company-aligned union; after a 30-day review, the Interagency Labor Committee found sufficient evidence to request Mexico’s review. Mexico has 10 days to accept and 45 days to complete the review; importers of the plant’s pork and chicken products should expect clearance uncertainty and potential facility-specific remedies if violations are confirmed.
Dulles CBP Seizes $111K; Global Entry Member Loses Status
CBP Media Releases •August 28, 2025
CBP officers at Washington Dulles seized $111,225 in unreported currency across August, including $77,135 from a Global Entry traveler bound for Lomé, Togo; other cases involved $19,790 from a Cairo arrival (Aug 21) and $14,300 from a Rome-bound passenger (Aug 14). CBP reiterated that amounts of $10,000+ must be declared via FinCEN Form 105—now available for e-filing—with noncompliance risking seizure, missed flights, potential criminal charges, and loss of trusted-traveler privileges. For corporate travel and compliance teams, the actions signal sustained currency interdiction ahead of holiday travel; CBP reports FY2024 daily average seizures of $152,418.
Tech Trade, Export Controls & IP
ITAR Final Rule Trims USML, Adds UUV License Exemption
STR Trade Report •August 28, 2025
Effective Sept. 15, the State Department’s final rule amends the ITAR, removing several items from the U.S. Munitions List and adding a targeted license exemption. Lead-free birdshot ammunition, GNSS anti-spoofing/anti-jam systems, and certain anti-jam antennas come off the USML; a new exemption covers specified activities related to unmanned underwater vehicles, alongside clarifications to USML entries. Exporters should reassess classifications and licensing needs ahead of the effective date.
CBP Reclassifies Wireless Dimmers to 8537; Duty Drops to 2.7%
STR Trade Report •August 29, 2025
CBP will reclassify certain wireless dimmers as boards for electric control under HTSUS 8537.10.91 (2.7% duty) instead of radio remote control apparatus under 8526.92.50 (4.9%), effective Oct. 20, 2025. In HQ H257143, CBP revoked NY N250956 and N250985, concluding that although the devices receive RF signals, they control lighting circuits via electrical connections and incorporate multi-switch boards consistent with headings 8536/8537. Importers of smart-home and building automation dimmers should update classifications and plan for duty savings on post–Oct. 20 entries.
ITC Ends Battery Case, Targets Car Seats, Bars Wearables
STR Trade Report •August 28, 2025
The ITC terminated the rechargeable batteries investigation (337-TA-1421) after settlements with the remaining respondents. It also opened a new Section 337 case (337-TA-1459) into child car seats, with complainants including Wonderland Switzerland, Iron Mountains, Nuna/Joie affiliates, and Graco, and respondents in Canada, China, Hong Kong, and the U.S. In the wearables case (337-TA-1398), the Commission issued a limited exclusion order and cease-and-desist orders against five respondents, creating immediate import risks for unlicensed products.
Related News
August 22, 2025
U.S.–EU Reset Leads Week as Enforcement and AD/CVD Actions Intensify
Read more →
October 3, 2025
Shutdown Fallout, 232 Lumber Tariffs, and BIS’s 50% Rule: This Week’s Trade Compliance Priorities
Read more →
September 5, 2025