JD Supra Trade Law

US Steel and USW File Antidumping Petitions Targeting Tin Mill Products from China, Taiwan, and Turkey

Clark Hill LLP published an analysis of antidumping and countervailing duty petitions filed by US Steel Corporation and the United Steelworkers Union with the U.S. Department of Commerce and U.S. International Trade Commission. The petitions seek AD duties on tin mill products from China, Taiwan, and Turkey, and CVD duties on imports from China. Petitioners alleged dumping margins of 202.02% to 1077.08% for China, 152.15% to 160.37% for Taiwan, and 190.95% to 192.91% for Turkey, with countervailing duties alleged above de minimis for China.

Dutch Bill Aims to Significantly Modernize and Strengthen Sanctions Enforcement

The Dutch House of Representatives received a proposal for the International Sanctions Measures Act (WIS) on February 19, 2026. The bill would replace the current Sanctions Act (Sanctiewet 1977) and introduce administrative enforcement powers alongside existing criminal penalties for sanctions violations. It also enables government appointment of administrators to direct or replace company management in specific circumstances.

CIT Orders CBP Refund IEEPA Duties

Kelley Drye & Warren LLP reports that the U.S. Court of International Trade ordered U.S. Customs and Border Protection to refund all IEEPA duties for importers in the Euro-Notitions Florida case, regardless of whether entries have been liquidated. Judge Eaton consolidated this case with the dismissed Atmus Filtration matter, continuing the IEEPA refund mechanism. The government appeal deadline is June 8, 2026, and CBP must provide a status update by April 14.

Section 232 Tariffs Restructured for Metals, Pharmaceuticals

President Trump issued two Section 232 proclamations on April 2, 2026, restructuring steel, aluminum, and copper tariffs (effective April 6) and imposing 100% tariffs on patented pharmaceuticals (effective July 31 for large companies, September 29 for others). Importers of metals must now pay duties on full customs value rather than metal content alone, while pharmaceutical imports face significant new cost burdens.

100% Tariffs on Patented Pharmaceuticals and APIs Under Section 232

The Trump Administration issued a proclamation on April 2, 2026 imposing Section 232 tariffs on patented pharmaceuticals and active pharmaceutical ingredients for the first time in the statute's history. The default tariff rate is 100% ad valorem, with reduced rates of 20% for companies with approved onshoring plans and 0% for those with both onshoring plans and MFN pricing agreements with HHS. Trade-deal countries receive preferential rates of 10-15%. Compliance deadlines are July 31, 2026 for 17 large Annex III companies and September 29, 2026 for all others.

Trump Overhauls Section 232 Tariffs on Patented Pharmaceutical Products

President Trump issued a Section 232 proclamation imposing tariffs up to 100% on patented pharmaceutical products and ingredients. Generic drugs, biosimilars, and specialty pharmaceuticals including orphan drugs and cell therapies are excluded. Companies with approved onshoring plans receive reduced rates of 20% until 2030, while those with pharmaceutical pricing agreements pay 0% until January 2029.

U.S. Steel Producers File CVD Petition Against Algeria

Clark Hill PLC reports that U.S. steel producers (Charter Steel, Commercial Metals Company, Liberty Steel USA, Nucor Corporation, and Optimus Steel LLC) filed a countervailing duty petition with the U.S. Department of Commerce targeting carbon and alloy steel wire rod imports from Algeria. The petitioners allege that Algerian producers/exporters receive countervailable subsidies from the Government of Algeria warranting remedial duties under U.S. law. Because Algeria is not a 'Subsidies Agreement' country, the case proceeds before Commerce without a parallel injury determination by the ITC at the preliminary stage.

OFAC Advisory Warns: Sham Transactions Do Not Evade Sanctions

OFAC issued an advisory clarifying that sham transactions designed to evade sanctions do not extinguish a sanctioned person's interest in blocked property. The advisory identifies seven red flag categories indicating potential sham transactions, including commercially unreasonable transfers, transfers to family members or close associates, and unduly complex corporate structures. The guidance supplements OFAC's '50 Percent Rule' and applies a functional, totality of circumstances approach to sanctions compliance due diligence.

100% Tariffs on Foreign Brand-Name Pharmaceuticals Announced

Jones Day analyzes the Trump administration's April 2, 2026 Proclamation imposing 100% tariffs on foreign-manufactured brand-name pharmaceuticals under Section 232. The tariff stems from a Commerce Department national security investigation finding that roughly 53% of domestically distributed drugs are produced overseas. Lower rates of 15%, 10%, or 0% apply for jurisdictions and manufacturers with bilateral agreements or MFN/onshoring commitments.

China Enacts Comprehensive Regulations on Industrial and Supply Chain Security

China's State Council published the Regulations on Industrial and Supply Chain Security on April 7, 2026, effective immediately with no transition period. The Regulations create a unified national security–driven framework consolidating export controls and anti-sanctions provisions, monitored by over 15 government agencies including MOFCOM, MIIT, and CAC. Multinational companies face expanded regulatory scrutiny including restrictions on supply chain data collection and potential enforcement for commercial decisions to exit China-related supply chains.