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).

Recently there have been a lot of headlines about who will do what when it comes to trade. In the U.S. a big piece of the recent election turned to “protection” of industries, workers, etc. In fairness, I’m a free trade kinda guy. It directly pays my salary. I’m willing to bet there are a number of people who don’t realize their salary, in part at least, is also subject to free trade.

Free trade agreements don’t just work for goods that cross borders, they also play in a lot of other arenas. For instance, the service sector, which includes remediation of disputes, human rights, fair labor standards and practices.

Ever wonder why we haven’t had any “major” conflicts in the past 70 odd years? Trade in general and free trade specifically have a lot to do with it. Why would you want to go to war with your biggest customers?

In 1519 Ferdinand Magellan set sail on an expedition to be the first person to successfully cross the Pacific Ocean. Relying heavily on the navigational technology of his time he would have depended upon instruments such as hour glasses, palnispheres, quadrants and compasses, all of which would have been considered high technology.