U.S. Department of Commerce (DOC)

ICYMI: Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria

On November 7, 2025, the Office of Foreign Assets Control (OFAC), alongside the U.S. Department of State and the U.S. Department of Commerce, issued a Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria

The Advisory follows President Trump’s Executive Order on June 30, 2025, formally removing U.S. sanctions on Syria and directing agencies to take additional measures to encourage U.S. private sector and foreign partner reengagement in Syria.

New Opportunities & Remaining Restrictions

The Advisory outlines what business with Syria is now permissible as well as what restrictions remain.

Permissible Business:

  • The United States no longer imposes comprehensive sanctions on Syria. 
  • The Caesar Act is suspended, except for sanctionable transactions with Russia and Iran.
  • The transfer of most basic civilian use U.S.-origin goods, as well as software and technology, to or within Syria is permitted without a license. 

Remaining Restrictions:

  • Sanctions remain on “the worst of the worst:” Bashar al-Assad and his associates, human rights abusers, drug traffickers, and other destabilizing regional actors.
  • The U.S. Government continues to review Syria’s State Sponsor of Terrorism (SST) designation. 
  • Most Commerce Control List items going to Syria still require a U.S. export license.

What Exporters Should Do

The removal of Syria sanctions and the easing of […]

New AD/CVD Case Filed Against Van-Type Trailers and Subassemblies Thereof From Canada, Mexico, and China 

A new antidumping and countervailing duty action has been filed against Van-Type Trailers and Subassemblies Thereof From Canada, Mexico, and the People’s Republic of China (China). The allegation is that imports from Canada, Mexico, and China are unfairly subsidized and being dumped.  

Full list of exporters here. 

Full list of importers here 

Background on AD/CVD Investigations 

Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent. 

Scope of the Investigation 

The merchandise covered by these investigations is van-type trailers and subassemblies thereof, whether finished or unfinished.  

The products subject to the investigation are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under the following subheadings: 8716.39.0040, 8716.90.5060, 7308.30.5050, 7308.90.9590, 7326.90.8688, 8708.29.1500, 9708.99.8180, and 8716.90.5010.  

Full scope here.

Next Steps 

The Commerce Department will determine whether to initiate the investigations […]

By |2025-11-24T09:29:38-05:00November 24, 2025|AD/CVD, U.S. Department of Commerce (DOC)|0 Comments

Tariff Updates: Heavy Trucks, Timber & Lumber, Vessel Fees

Over the past several weeks, there has been a flurry of tariff updates affecting importers across multiple industries. From tariffs on heavy-duty vehicles and timber to 232 exclusions and vessel fees, the trade landscape is moving fast, and staying compliant is more challenging than ever. To help you keep up, we’ve summarized recent key tariff developments you need to know. For a full list of tariffs and trade deals, visit our tracker here.

Heavy-Duty Vehicles and Vehicle Parts

On September 25, 2025, President Trump, via Truth Social, announced his intention to impose a 25% tariff on heavy trucks. On October 17, 2025, he issued a Presidential Proclamation formalizing and clarifying these tariffs. The proclamation imposes a 25% tariff on imports of medium- and heavy-duty trucks and truck parts. This includes Class 3 to Class 8 vehicles, like large pick-up trucks, moving trucks, cargo trucks, dump trucks, and tractors for eighteen-wheelers. 

The Proclamation also imposes a 10% tariff on imports of buses, including school buses, transit buses, and motor coaches. The tariffs are set to take effect on November 1, 2025.

President Trump is imposing the new tariffs under section 232 of the Trade Expansion Act of 1962, citing national security concerns.

If medium and heavy-duty vehicles qualify for USMCA treatment, the importer may submit documentation to identify the amount of U.S. content, and, after the Department of Commerce’s […]

ICYMI: BIS Imposes New Affiliates Rule

[Update November 10, 2025]: BIS imposed a one-year suspension of the interim final rule. The suspension is set to end November 9, 2026, absent a future extension.

On September 30, 2025, the Bureau of Industry and Security (BIS) released an interim rule regarding “Affiliates.” Under the rule, any entity that is at least 50% owned by one or more entities on the Entity List or the Military End-User (MEU) List will itself automatically be subject to Entity List/MEU restrictions. This is a significant change from the current standard, which excludes entities that are not specifically included on the Entity List or MEU List, regardless of any affiliation with Entity List or MEU List organizations. 

This rule is effective September 29, 2025.

Entity, MEU List Background

The Entity List identifies persons (including businesses, research institutions, government and private organizations, individuals, and other types of legal persons) reasonably believed to be involved, or to pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States. These persons are subject to specific license requirements for the export, reexport, and/or transfer (in-country) of specified items.  

BIS first published the Entity List in 1997. Since its initial publication, grounds for inclusion on the Entity List have expanded to activities sanctioned by the State Department and activities contrary to U.S. […]

New AD/CVD Case Filed on Chromium Trioxide from India and Turkey 

A new antidumping and countervailing duty action has been filed on Chromium Trioxide from India and Turkey. The allegation is that imports from India and Turkey are unfairly subsidized and are being dumped.   

Full list of exporters here. 

Full list of importers here 

Full list of census data here.  

Background on AD/CVD Investigations 

Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent. 

Scope of the Investigation 

The merchandise covered by these investigations is chromium trioxide (Chemical Abstracts Services (“CAS”) registry number 133-82-0), regardless of form (dry or solution).  

The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheading 2819.10.0000.  

Full scope here.   

Next Steps 

The Commerce Department will determine whether to initiate […]

By |2025-09-30T12:45:15-04:00September 30, 2025|AD/CVD, U.S. Department of Commerce (DOC)|0 Comments
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