Tariffs Tighten, CBAM Widens, Enforcement Heats Up — Year-End Compliance Brief
NEWSLETTER | Trade Insight AI
Bulk Classification in Trade Insight AI: Speed with Legal Precision
Trade Insight AI • recently
Spotlight: A bulk HS classification capability in Trade Insight AI designed to accelerate throughput while preserving legal defensibility and audit trails for compliance teams.
Tariff Strategy and Rulemaking
USTR Greer details tariff-tier regime and 'Turnberry' dealmaking push
USTR Press Releases •December 22, 2025
In an FT op-ed, USTR Jamieson Greer brands 2025 “the year of the tariff” and outlines a July 31 tariff regime—10% on surplus partners, 15% on small-deficit partners, and higher for large-deficit countries—paired with accelerated “Turnberry Round” talks. He touts agreements with the EU, Japan, Korea, and several Southeast Asian and Latin American economies to cut tariffs on U.S. goods, streamline NTBs, reinforce IP and forced-labor rules, and coordinate on export controls. For trade operators, this signals a durable tariff‑first posture with targeted market access gains and heightened compliance expectations in digital, labor, and technology controls.
USTR Sets Path for Additional Tariff on Chinese Semiconductors
STR Trade Report •December 24, 2025
USTR found China’s semiconductor industrial policies unreasonable under Section 301 and will impose an additional tariff on China-origin semiconductor imports covering specified HTSUS lines. The new tariff is set at 0% as of Dec. 23, 2025, and will rise on June 23, 2027 to a rate USTR will announce at least 30 days in advance; it is on top of the existing 50% Section 301 tariff on semiconductors tied to forced technology transfer. The move signals further cost pressure on Chinese chips and gives importers a 2027 planning horizon for sourcing and classification decisions.
Year-end Hill flurry targets trade: tariffs, carbon, export controls
STR Trade Report •December 23, 2025
Between Dec. 15–19, lawmakers introduced a wide slate of trade measures spanning tariff transparency and potential refund planning if IEEPA tariffs fall, heightened scrutiny of UFLPA enforcement, a USMCA push to align investment screening, and a carbon border adjustment starting at $60/ton and rising 6% above inflation for energy‑intensive sectors (expanding to downstream goods in 2028). Bills would also tighten export controls (returning some arms licensing to State, covering cloud-based remote tech access, restricting advanced AI chips and certain ICs), reshape FTZ treatment with clearer CBP rules, withdraw MFN from China, and tweak AD/CVD distributions; the Senate also confirmed two senior USTR officials. Importers and exporters should assess exposure to prospective carbon charges, evaluate FTZ strategies, prepare for stricter tech controls, and watch potential tariff refund processes depending on Supreme Court outcomes.
CIT Sets Standard Stay Procedures for New IEEPA Tariff Lawsuits
CIT News •December 23, 2025
On December 23, 2025, Chief Judge Mark A. Barnett issued Administrative Order 25-02 establishing procedures for entering stays in newly filed lawsuits challenging tariffs imposed under the International Emergency Economic Powers Act. The order is intended to streamline administration of the growing IEEPA tariff docket and provide clearer expectations for litigants on case management and timelines.
Enforcement and Compliance Actions
Trade Week Ahead: PFAS Deadline, VEU Removals, Fish Ban, Mexico Tariffs
STR Trade Report •December 26, 2025
Key deadlines arrive this week: Dec. 29 is EPA’s comment cutoff on a proposed PFAS import reporting exemption, and Dec. 31 BIS will remove three companies from the Validated End-User list. On Jan. 1, a prohibition on imports of fish and fish products from specified foreign fisheries takes effect, the window opens to request expansion of Section 232 tariffs to additional auto parts, and Mexico’s higher import duties begin. Importers and exporters should assess exposure, update 2025 pricing and sourcing, and prepare any required filings.
CBP Detains Serbian-Made Linglong Tires Under Forced Labor Order
STR Trade Report •December 24, 2025
Effective Dec. 18, CBP issued a withhold release order detaining all U.S. imports of automobile tires made in Serbia by Linglong International Europe D.O.O Zrenjanin after identifying nine forced labor indicators, including intimidation, withheld wages, excessive overtime, and abusive conditions. Importers must either export or destroy detained shipments or prove the tires were not produced with forced labor. The action, enforced under 19 USC 1307, brings CBP’s active WROs to 55 and signals heightened risk for automotive supply chains relying on this plant.
FDA issues new import alerts; seafood, devices face DWPE
STR Trade Report •December 24, 2025
The FDA issued or updated import alerts this week covering seafood from Bangladesh, Burma, Pakistan, Thailand, and Vietnam; energy drinks and noodles from Afghanistan; laser products and tea drinks from China; medical instruments from Pakistan; microneedling machines from Germany; and various foods and consumer goods from Mexico, Taiwan, Indonesia, and Egypt. Shipments under these alerts risk detention without physical examination (DWPE), so importers should verify supplier red/green list status and prepare documentation to demonstrate compliance to avoid refusal.
ITC Opens 337 Probes on Earpieces, Vapes; Toy Case Terminated
STR Trade Report •December 26, 2025
The USITC instituted Section 337 patent investigations into open‑ear earpiece devices (337‑TA‑1470; Bose; respondents in China, Hong Kong, England) and vaporizer devices and cartridges (337‑TA‑1469; NJOY/Altria; U.S. respondent), while InterDigital filed a new complaint targeting video‑capable electronic devices with proposed U.S. respondents. Separately, the toy projectile launcher case (337‑TA‑1325; Hasbro/Spin Master) was terminated without import restrictions. Importers in audio, vaping, and video electronics face potential exclusion orders if violations are found and should review sourcing and contingency plans; toy import risk from this matter has abated.
DEA Schedules Nitazene Analogs; Strict Import/Export Controls Start Jan. 22
STR Trade Report •December 26, 2025
The DEA issued a final order placing N‑desethyl isotonitazene and etonitazepipne (nitazene-class opioids), including their isomers, esters, ethers, and salts, in Schedule I of the Controlled Substances Act effective Jan. 22. This permanently subjects importers, exporters, manufacturers, distributors, researchers, and instructors to Schedule I controls, limiting trade to narrowly authorized activities and exposing noncompliance to administrative, civil, and criminal penalties.
Market Access and 2026 Outlook
Canada Hits Steel Derivatives; WTO Stalls; Asia FTAs Accelerate
STR Trade Report •December 26, 2025
Canada will impose 25% tariffs on steel derivative products from all countries effective Dec. 26, 2025, raising costs and compliance burdens for importers. WTO reform prospects dim as the chair rules out a deal at the next major meeting, citing consensus-rule gridlock. Meanwhile, Asia-Pacific market access widens: China launches a $113 billion Hainan duty‑free pilot with a 30% local value‑add threshold and broader services access; New Zealand and India conclude an FTA removing duties on 95% of NZ exports and all Indian goods alongside a $20 billion NZ investment; and India also signs a pact with Oman as it seeks to offset U.S. tariffs.
EU targets 2028 CBAM expansion and tighter anti-circumvention
STR Trade Report •December 24, 2025
The European Commission proposed strengthening CBAM with a Jan. 1, 2028 scope expansion to 180 downstream goods with high steel/aluminum content, including machinery, vehicle components, domestic appliances, and construction equipment. The plan would close circumvention gaps by accounting for pre-consumer scrap, tightening traceability and reporting, and addressing emission misdeclarations, while adding a temporary support scheme for EU producers. Importers should expect broader emissions-data requirements as CBAM charges phase in from 2026 and prepare to map affected products and supplier disclosures.
China challenges India at WTO over solar, IT tariffs, local content
WTO Latest News •December 22, 2025
On 23 December 2025, China requested WTO consultations (WT/DS644/1) with India over alleged discriminatory tariff treatment and measures tied to domestic content for solar cells/modules and IT goods. The filing opens the dispute process; if talks fail within 60 days, China can seek a panel. The case heightens scrutiny of India’s renewable and electronics trade policies and could affect duty exposure and sourcing strategies for firms serving the Indian market.
2025 Trade Recap: Tariff Volatility, Enforcement Surge, New Security Rules
STR Trade Report •December 24, 2025
A year-end roundup flags pivotal shifts: Supreme Court skepticism of IEEPA-based tariffs that could enable refund claims; potential easing of U.S. tariffs, shipping fees, and export controls on China; and removal of reciprocal duties on food products. Looking ahead, Section 232 could expand to ten more critical minerals while petitions target additional Chinese goods. Compliance pressures are rising as CBP intensifies duty‑evasion enforcement, Mexico reverses its IMMEX footwear policy, CTPAT pilots broader 3PL participation, EPA proposes exempting PFAS imports from reporting, and air cargo faces expanded data requirements—warranting 2026 reviews of sourcing, duty‑recovery, and security programs.
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