Taxes, Tariffs & Trade

Updated October 6, 2025

NAFEM informs and represents its members on the complex issues of U.S. taxes, tariffs, and trade, advocating for open and fair policies and rules that maximize market opportunities and cost-effective supply chain sourcing. 

Tariff resources 

While NAFEM regularly updates this resource page, we recommend regular communication with your customs broker for up-to-the-minute tariff information relative to your business and its products.

Understanding New U.S. Tariff Landscape

Updated October 6, 2025

Tariff collections continue during shutdown 

U.S. Customs and Border Protection continues tariff collections during the government shutdown.  

U.S. Supreme Court to hear IEEPA arguments 

The U.S. Supreme Court (SCOTUS) will hear oral arguments in the International Emergency Economic Powers Act (IEEPA) tariffs case Nov. 5. Already, the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit struck down the IEEPA tariffs. However, the tariffs remain in place as court proceedings continue. Should the SCOTUS agree with the lower courts, these tariffs will be struck down, but it remains to be seen how and if potential refunds will be addressed. NAFEM members who are importers could be eligible for potential refunds for IEEPA tariffs that began February 2025. Members who source from importers-distributors would likely not receive refunds from these supply chain partners.  

Section 301 tariffs upheld by Federal Circuit Court 

In a unanimous opinion, the three-judge panel of the Court of Appeals for the Federal Circuit ruled that the first Trump administration was within its rights to expand the initial Section 301 tariffs on Chinese goods from $50 billion to $300 billion. The final step in this case is an appeal via a Writ of Certiorari (Cert) to the SCOTUS. If an appeal is not pursued or the SCOTUS denies the Cert petition, the Federal Circuit decision will be legally binding and the thousands of pending cases will be dismissed. NAFEM’s legal team at Barnes & Thornburg anticipates that the SCOTUS will deny the petition based on the Court’s other activities to date. 

Canada’s Response

• The Government of Canada maintains a list of U.S. products subject to counter tariffs.

China’s Response

• China lowered reciprocal tariffs to 10% during the second 90-day negotiation period through Nov. 10.

U.S. – EU Trade Agreement

• EU announcement re: the U.S.-EU Framework Deal
• Key provisions of the Agreement are provided by the Coalition of American Metal Manufacturers and Users (CAMMU).

The U.S. – U.K. Economic Prosperity Deal

• The May 8^th agreement addresses steel and aluminum tariffs and numerous other trade-related topics.

Additional U.S. Investigations

• The U.S. Department of Commerce opened a brief three-week comment period (April 16 – May 7) on its Section 232 investigation of the security risks of imports of semiconductors, semiconductor manufacturing equipment and their derivative products. The investigation also covers semiconductor substrates and bare wafers, legacy chips, leading-edge chips, microelectronics and manufacturing equipment components. The final report is due to President Trump Dec. 27, although the administration has stated its intent to move at a faster pace.
• President Trump initiated a Section 232 investigation to assess U.S. national security risks arising from the country’s increasing dependence on imported smelted and refined copper. Findings are due Nov. 22.  
• A similar Section 232 investigation is underway for imports of timber, lumber and their derivative products. Findings are due Nov. 26.  
• The U.S. Secretary of Commerce initiated a Section 232 investigation under the Trade Expansion Act to assess whether imports of robotics and industrial machinery, and parts/components, pose a risk to national security. The scope of the investigation includes CNC machining centers, turning and milling machines, grinding and deburring equipment, and industrial stamping and pressing machines. It also includes automatic tool changers, jigs and fixtures, and machine tools for cutting, welding and handling work pieces. Application-specific specialty metalworking equipment used to treat, form or cut metal, such as autoclaves and industrial ovens, metal finishing and treatment equipment, EDM machinery, and laser and water-cutting tools and machinery also is included. Comments are due Oct. 17.  
• The administration also launched a Section 232 investigation into Brazil’s trade policies. Comments were due August 18 and the U.S. Trade Representative held a hearing Sept. 3.
• Based on USTR’s Section 301 investigation on China’s Maritime, Logistics and Shipbuilding Sector dominance that was initiated March 2024, Customs and Border Protection (CBP) is implementing new fees for vessels owned, operated or built in China, and for all foreign-built vehicle carrier vessels, effective Oct. 14, 2025. In its guidance, CBP notes that, “The burden for determining if a vessel owes the fee is on the operator, NOT CBP.” NAFEM, the U.S. Chamber of Commerce and 100+ others advocated against the proposal that would increase shipping costs, raise prices and decrease exports and imports.

Global Market Access and Conformity Guide

NAFEM’s regularly updated resource to assist in the identification of international certifications, the Global Market Access and Conformity Guide provides certification contact information for fuel type, region and other data points to reduce research time. While this tool is updated periodically, we encourage companies to take all steps necessary to confirm and verify information for your specific products and market needs.

Additional Resources

• White House Website
• U.S. Department of Commerce (DOC)
• Office of the U.S. Trade Representative

Questions?

Contact advocacy@nafem.org