Client Alerts
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Where Are we now on USMCA and Sec. 232 Tariffs?
This will provide a brief outline of key developments last week regarding the current delay and potential re-implementation of tariffs on products of Canada and Mexico, imposed under the International Economic Emergency Powers Act (“IEEPA”) and Section 232 (National Security) duties on steel and steel derivative products and aluminum and aluminum derivative products.

Expansion of Section 232 Steel and Aluminum Tariffs
President Trump’s new proclamations expand Section 232 tariffs on steel and aluminum, raising rates to 25% and eliminating exemptions. Businesses should assess supply chains, review exclusions, and prepare for broader tariff coverage.

Tariffs Affecting Canada-US Trade: Navigating the Uncertainty
President Trump’s recent executive orders imposing and suspending tariffs on Canadian goods highlight ongoing trade tensions. While the tariffs are currently on hold, businesses should analyze product classifications, explore exemptions, and review contracts to prepare for potential implementation.

EU “Best Efforts” Obligations Under Russia Sanctions Regulations
On 22 November 2024, the European Union issued an FAQ providing detailed guidance on the “best efforts” obligations for EU entities. These obligations require EU entities to ensure that activities undertaken by their non-EU subsidiaries do not undermine EU sanctions on Russia.

DHS Updates the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List to Add Metals and Food Producers
The DHS has added 29 entities to the UFLPA Entity List for forced labor links in China’s Xinjiang region, including key players in the metals and food sectors.

EU Regulation Alert: Carbon Border Adjustment Mechanism (CBAM) Comes into Effect
The EU’s Carbon Border Adjustment Mechanism (CBAM) now mandates reporting for imports of high-emission goods like steel and cement, with financial obligations starting in 2026 to align with EU carbon standards.