PFAS Reporting Relief, China 301 Pause, and Critical Minerals Watch
NEWSLETTER | Trade Insight AI
EPA Moves to Exempt Imported Articles from PFAS Reporting
STR Trade Report • November 14, 2025
EPA proposed narrowing TSCA PFAS reporting—exempting imported articles, PFAS at or below 0.1% in mixtures/products, certain non-commercial byproducts/impurities, and R&D uses—with comments due Dec. 29. If finalized, the change would lift significant supply-chain data burdens for importers of finished goods while maintaining obligations for PFAS substances and higher‑concentration mixtures. The agency would also reset the filing window to begin 60 days after the final rule and run three months, supplanting the current April 13, 2026 deadline, so companies should reassess compliance plans and consider commenting.
China Deal Implementation and 301 Actions
USTR Suspends China Maritime, Logistics, Shipbuilding 301 Actions One Year
USTR Press Releases •November 9, 2025
USTR has suspended for one year—effective 12:01 a.m. EST November 10, 2025—the responsive actions in its Section 301 investigation into China’s targeting of the maritime, logistics, and shipbuilding sectors. The move follows a U.S.–China trade and economic deal announced November 1 and shifts the process to negotiations under Section 301, while the United States continues domestic and allied efforts to revitalize U.S. shipbuilding. For companies across these supply chains, the pause reduces immediate escalation risk but leaves future measures contingent on the negotiation outcome and details in the formal notice.
U.S. Suspends China Ship Fees, Port Tariffs, 50% Export Rule
STR Trade Report •November 11, 2025
The U.S. paused fees on Chinese-owned/operated or Chinese-built vessels and delayed 100% tariffs on Chinese ship-to-shore cranes and cargo-handling equipment, while BIS stayed its expanded “50% rule” for Entity List/MEU subsidiaries—each through Nov. 9, 2026. USTR will accept comments through Nov. 12 on further adjustments, including carve-outs for LPG/ethane carriers under long-term charters, extending vessel fees to ships up to 10,000 DWT through at least Apr. 18, 2029, and potential tariffs up to 150% on certain cargo-handling equipment. Near-term relief for carriers, ports, and exporters comes with late-2026 policy risk as Section 301 talks with China proceed and U.S. shipbuilding initiatives advance.
China Eases Rare Earth, Dual-Use Curbs; Delists U.S. Entities
STR Trade Report •November 12, 2025
China moved to implement last month’s U.S.-China trade accord by suspending newly announced export controls on rare earths, graphite and lithium-battery inputs effective Nov. 7 through Nov. 10, 2026, and by pausing a strict 0.1% de minimis licensing rule set for Dec. 1. Beijing will also allow, from Nov. 9, 2025 to Nov. 27, 2026, licensed exports to the U.S. of dual-use items containing gallium, germanium, antimony and graphite, and has removed 21 U.S. firms from its unreliable entity list and 31 from export control lists. The time-limited relief should ease supply pressure and compliance burdens for U.S. manufacturers, though licensing persists and policies could snap back after 2026.
Tariffs and Global Trade Measures
U.S. Finalizes 2025 Critical Minerals List; Section 232 Tariffs Weighed
STR Trade Report •November 13, 2025
The Interior Department finalized the 2025 critical minerals list, adding 10 materials—boron, copper, lead, metallurgical coal, phosphate, potash, rhenium, silicon, silver, and uranium—bringing the total to 60. A Section 232 investigation launched in April 2025 at the President’s direction could replace current reciprocal rates with new tariffs and other import restrictions, include anti-circumvention safeguards, and pair measures with incentives for domestic production, processing, and recycling. Importers and manufacturers across energy, defense, agriculture, and electronics should assess exposure to these minerals and derivative products as tariff and compliance obligations may shift.
G20 Restrictions Quadruple; 22% of Imports Under Trade Measures
WTO Latest News •November 12, 2025
WTO monitoring shows G20 import restrictions surged between mid‑Oct 2024 and mid‑Oct 2025, with USD 2.6 trillion (14.3%) of imports newly affected—quadruple the prior period—and total restrictive measures covering about USD 2.9 trillion when export actions are included. Despite rising protectionism, G20 members also enacted 184 trade‑facilitating steps covering USD 2.1 trillion and largely avoided retaliation, while trade remedies—especially anti‑dumping—accounted for 55% of goods measures with 28.5 new probes per month. The cumulative stock now touches 22% of G20 imports (USD 4.0 trillion), heightening compliance and cost exposure but creating targeted opportunities where facilitation lowers barriers.
Tariff Refunds Loom; China Curbs Chemicals; Mexico Slaps Sugar Tariffs
STR Trade Report •November 13, 2025
U.S. importers say potential Supreme Court-ordered refunds of tariffs imposed by the Trump administration could be executed without major disruption unless implementation is complicated by the administration. Beijing restricted exports of certain chemicals to the U.S., Canada, and Mexico while allowing shipments elsewhere without a license; Mexico imposed steep duties of 156% and 210% on cane, refined liquid and beet sugars, and syrups to counter market distortions, and Trump hinted at an India visit as trade talks resume, though New Delhi has not confirmed his claims of reducing imports. October containerized imports from the top 10 sources rose 1.3% month over month on China’s recovery, while shipments from India, Thailand, and Vietnam fell 19%, 6%, and 4.8%, signaling tariff-driven caution across Asia.
Americas Agreements and Market Access
USTR Unveils Reciprocal Trade Frameworks with Argentina, Ecuador, El Salvador, Guatemala
USTR Press Releases •November 13, 2025
The United States announced joint statements establishing frameworks toward Agreements on Reciprocal Trade with Argentina, Ecuador, El Salvador, and Guatemala. The initiative aims to lower trade barriers and open markets for U.S. workers and producers, signaling upcoming bilateral workstreams but no immediate tariff or rule changes. Companies should review the released joint statements and fact sheets to gauge sector priorities and prepare for potential negotiations.
U.S.–Ecuador Reciprocal Trade Framework Opens Agriculture, Eases Industrial Export Rules
USTR Press Releases •November 13, 2025
The United States and Ecuador agreed on a framework for a reciprocal trade agreement that cuts tariffs on U.S. farm goods—including ending Andean price-band surcharges—and streamlines import licensing and facility registration to deliver more predictable market access. Ecuador will accept remanufactured goods and U.S. standards for vehicles, medical devices, and pharmaceuticals; end pre-shipment inspection; expand the AEO program to express carriers within three months; and avoid discriminatory digital taxes while supporting the WTO e‑transmissions moratorium. The package adds IP, labor (including a forced‑labor import ban), and environmental commitments plus security and export‑control cooperation; the U.S. would grant MFN rates to certain Ecuadorian goods not produced domestically, positioning exporters to build on $10.2B in 2024 U.S. sales.
U.S., El Salvador Set Framework to Cut Non‑Tariff Barriers, Boost CAFTA Trade
USTR Press Releases •November 13, 2025
The United States and El Salvador agreed to a framework for a reciprocal trade pact aimed at streamlining market access and reducing non‑tariff barriers. Commitments include accepting U.S. standards and certificates for autos, medical devices and drugs; recognizing remanufactured goods; easing agricultural approvals while safeguarding common cheese/meat terms; adopting good regulatory practices; strengthening IP enforcement; refraining from discriminatory digital services taxes and supporting the WTO moratorium on e‑transmission duties; and tightening labor and environmental enforcement. In return, the U.S. plans to remove reciprocal tariffs on select Salvadoran goods and provide preferential treatment to qualifying textiles and apparel under CAFTA‑DR, with finalization targeted in coming weeks and 2024 two‑way trade at $10.7 billion (U.S. exports: $6.7 billion).
U.S. and Guatemala Set Framework to Pursue Reciprocal Trade Deal
USTR Press Releases •November 13, 2025
The United States and Guatemala announced a framework to guide work toward a reciprocal trade agreement, signaling potential expansion of bilateral market access. While details and timelines are not yet public, the initiative could influence tariffs, regulatory alignment, and sector priorities across agriculture, manufacturing, and services. Companies active in U.S.–Guatemala trade should monitor forthcoming scoping documents and consultations to gauge opportunities and compliance implications.
Compliance, Licensing, and Border Operations
FDA updates import alerts; DWPE risk for cosmetics, devices, seafood
STR Trade Report •November 12, 2025
The FDA issued and modified multiple import alerts this week covering cosmetics, medical devices, seafood, snack foods, sunscreen, and nicotine products from countries including Brazil, China, India, Mexico, Vietnam, Afghanistan, Hungary, and Iceland. These alerts authorize detention without physical examination (DWPE); importers should verify supplier status on red/green/yellow lists and be prepared with testing and documentation to demonstrate compliance or risk refusal of entry.
BIS Lifts Restrictions: One Chinese Entity, Six Aliases Delisted
STR Trade Report •November 12, 2025
BIS issued a final rule effective Nov. 10 removing one Chinese entity and six aliases tied to another entity from the Entity List, lifting EAR license requirements for transactions involving them. The agency cited clarified affiliations and commitments to stronger export compliance, concluding these parties no longer pose a significant security or foreign policy risk. Exporters should update screening lists and reassess licensing needs, noting other EAR controls may still apply.
WTO Valuation Committee Reviews 63 Notifications, Adopts Transparency Report
WTO Latest News •November 9, 2025
At its 10 November meeting, the WTO Committee on Customs Valuation reviewed 63 notifications from 37 members—including first filings from Guyana and Indonesia—and concluded reviews for Cabo Verde, Mauritania, Philippines, and Senegal. It adopted a draft report to the Council on Trade in Goods to improve the rate, quality, and timeliness of notifications via experience-sharing, workshops, and outreach; to date, 121 members have notified legislation and 94 have submitted checklist responses. The WCO briefed delegates on a new explanatory note clarifying the “price actually paid or payable” and on draft e-commerce fulfillment guidelines, while the Committee scheduled information sessions on preshipment inspection and the PSI Independent Entity.
CBP Requires eCBP Portal for Individual Broker License Applications
STR Trade Report •November 14, 2025
Effective Nov. 14, CBP will require all individual customs broker license applications and fees to be filed through the eCBP portal; hand-delivered, mailed, or emailed submissions will be returned. Applicants will use their existing login.gov credentials, pay by credit/debit with no added fees, receive electronic receipts, and enter the current processing queue. Organization license applications remain manual for now, with CBP signaling eventual automation—adjust internal workflows accordingly.
CBP outbound check seizes 8,984 rounds at Los Indios Bridge
CBP Media Releases •November 13, 2025
On Nov. 9, CBP officers at the Los Indios International Bridge in Brownsville intercepted 8,984 rounds of unreported ammunition during an outbound inspection, locating mixed calibers hidden in a 2008 Chevrolet driven by a 65-year-old Mexican citizen with assistance from a canine team and nonintrusive imaging. The ammunition and vehicle were seized and HSI arrested the driver, highlighting ongoing outbound enforcement that could affect southbound inspection times and underscores compliance risks for border-crossing traffic.
Regional Programs and Supply Chains
U.S. Seeks PNTR, Supply Chain Links with Central Asia
STR Trade Report •November 14, 2025
The U.S. and Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan agreed to pursue deeper economic engagement, including regulatory reforms, customs transparency, and development of the Trans‑Caspian trade corridor to connect critical minerals to global value chains. Companion bills in the House and Senate would repeal Jackson‑Vanik and grant PNTR, enabling column 1 duty rates; if enacted, this could reduce tariff risk, expand market access, and catalyze investment in energy and other high‑growth sectors. The initiative also signals a strategic push to diversify trade routes and influence in a region long shaped by Russia and China.
Mexico Restores IMMEX for Finished Footwear, But 25% Tariff Remains
STR Trade Report •November 13, 2025
Mexico’s Oct. 29 resolution reinstates, for one year, the ability to temporarily import finished footwear under IMMEX if firms meet strict conditions: current IMMEX compliance, at least $500,000 in monthly exports, full inventory turnover above twice per year, and a plan to substitute imports with domestic production. The 25% minimum tariff on footwear from non‑FTA countries stays in place through end‑2026, meaning the shift mainly restores logistics flexibility rather than duty relief; limited benefits may accrue to operators doing minor processing in Mexico to lower dutiable value. Companies should weigh the added complexity against modest gains, especially as the loss of U.S. de minimis duty-free entry has reduced earlier fulfillment advantages.
WTO reviews Guatemala’s trade regime; reports inform market access
WTO Latest News •November 11, 2025
Guatemala’s fourth WTO Trade Policy Review is underway on 12 and 14 November 2025, with findings debated in the Trade Policy Review Body. Newly released Secretariat and government reports offer an updated view of the country’s trade and related policies, giving traders and compliance teams insight into market access, procedures, and the policy outlook.
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