TradeLane

On October 30, 2025, the White House suspended the implementation of the BIS 50% rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities for one year, starting on November 10, 2025. This delay is due to a reciprocal agreement with China. The rule would have extended export-licensing requirements to companies' majority-owned by parties on the Entity List, Military End-User List, or certain OFAC Specially Designated Nationals. The delay in implementation of this rule has generated a mixed reaction from the export industry.

U.S. importers of steel, aluminum, and certain derivative products continue to face heightened scrutiny under Section 232. While the tariffs themselves are well established, recent clarification from U.S. Customs and Border Protection (CBP)—particularly from the Base Metals Center of Excellence and Expertise (CEE)—has reinforced how steel and aluminum content must be valued and reported for duty purposes. 

Recent clarification from U.S. Customs and Border Protection (CBP), including guidance from the Base Metals Center of Excellence and Expertise (CEE), has reinforced how steel and aluminum content must be valued and reported for Section 232 duty purposes, with important implications for importer compliance and reasonable care 

 What Happened

On March 6, 2026, the U.S. Court of International Trade (CIT) issued an order in Atmus Filtration, Inc. v. United States that temporarily pauses U.S. Customs and Border Protection (CBP) from taking immediate action to remove or refund tariffs imposed under the International Emergency Economic Powers Act (IEEPA).

 On March 4^th, the US Court of International Trade (CIT) ordered that unliquidated entries entered subject to IEEPA duties be liquidated without regard to IEEPA duties, and liquidated entries where liquidation is not final be reliquidated without regard to IEEPA duties.  

On February 20, the U.S. Supreme Court issued a ruling invalidating the International Emergency Economic Powers Act (IEEPA) as a mechanism to levy tariffs. While the tariffs are invalidated and stopped being collected on February 24^th at 12:01 AM, the ruling did not provide operational clarity for importers seeking refunds of IEEPA duties already paid.