Information courtesy of ArentFox Schiff LLP
Recent developments in U.S. trade policy continue to create uncertainty for manufacturers and exporters doing business with the United States. Key updates include:
USMCA Review Continues
- The mandatory review of the USMCA is underway, with the U.S. signalling it may not extend the agreement in its current form.
- Discussions are focusing on stricter automotive rules of origin, including proposals to increase North American content requirements and introduce a U.S.-content requirement.
- Canada has not yet entered formal negotiations, raising concerns about potential impacts on Canadian manufacturers and supply chains.
Section 232 Tariff Changes
- The U.S. has revised its Section 232 steel and aluminum tariff framework, providing temporary relief for certain industrial equipment while expanding tariffs to additional derivative products.
- Manufacturers should review whether their products qualify for reduced tariff treatment and assess any exposure to newly covered products.
Customs Enforcement Increasing
- The U.S. Department of Justice continues to aggressively pursue customs fraud and tariff evasion cases, including country-of-origin misrepresentation and incorrect product classification.
- Companies exporting to the U.S. should ensure customs declarations, product classifications, valuation, and origin documentation are accurate and well supported.
Potential New Section 301 Tariffs
- The U.S. is considering new tariffs on goods from Brazil and is investigating Vietnam’s intellectual property practices, along with broader forced labour-related tariff measures affecting multiple countries.
- Businesses with global supply chains should monitor developments, as additional tariffs could affect sourcing decisions and material costs.
Import Refunds & Tariff Litigation
- Ongoing legal challenges surrounding certain U.S. tariffs continue to create uncertainty for importers.
- Companies with affected imports should monitor refund opportunities, appeal deadlines, and any future court decisions that may impact tariff recovery.
What This Means for CTMA Members
Canadian manufacturers should continue to:
- Monitor developments in the USMCA review and potential changes to rules of origin.
- Review supply chains for exposure to evolving U.S. tariff policies.
- Ensure customs compliance and documentation are accurate.
- Stay informed as trade negotiations and tariff policies continue to evolve over the coming months.
More information is available here.