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Schulz Trade Tribune: September 19-25, 2025

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Schulz Trade Tribune: September 19-25, 2025


September 29, 2025



U.S.-EU HTSUS Modifications


As a result of the U.S.-EU Trade Framework Agreement, the Department of Commerce has published comprehensive Harmonized Tariff Schedule of the United States (HTSUS) modifications.  As such, various EU-origin product may be filed under a new or additional Chapter 99 subheadings, including:

-              Passenger vehicles and Light trucks,

-              Auto-parts,

-              Certain pharmaceuticals,

-              Certain civil aircraft and parts thereof, and

-              Certain natural resources.


Please contact Marina Mekheil or Matt Savage with questions.


Section 232 Comments: Medical Products


The Department of Commerce has initiated a Section 232 investigation into personal protective equipment used in health care settings, medical consumables, and medical equipment, including devices.  Interested parties must submit comments or pertinent investigation information to the Bureau of Industry and Security (BIS) by October 17, 2025.


Please contact Josh Rodman or Kelly Mccorkle with questions.


ACE Portal Electronic Refunds


Pursuant to Section 3 of Executive Order 14247, U.S. Customs and Border Protection (CBP) will enable authorized users to add their U.S. bank information to the Automated Commercial Environment (ACE) Secure Data Portal, thereby allowing electronic refund transactions.


Please contact Marina Mekheil or Matt Savage with questions.


Section 232 Comments: Machine Tools & Industrial Robots


The Department of Commerce has initiated a Section 232 investigation into machine tools, industrial robots, and industrial machinery.  Interested parties must submit comments or pertinent investigation information to BIS by October 17, 2025.


Please contact Josh Rodman or Kelly Mccorkle with questions.

 

Additional Tariffs from 25% to 100%


On September 25, 2025, President Trump announced via Truth Social that, effective October 1, 2025, the following products would be subject to an additional ad valorem tariff rate:

-              25% tariff rate for Heavy trucks,

-              30% tariff rate for Upholstered furniture,

-              50% tariff rate for Kitchen cabinets, Bathroom vanities, and “associated products,” and

-              100% tariff rate for branded or patented pharmaceutical products.


While the scope of President Trump’s additional tariffs remains unclear, along with the tariff mechanism President Trump intends to use to implement the tariffs, he has made it clear that these additional tariffs may be evaded if producers/manufacturers begin to onshore production to the United States.


Please contact Marina Mekheil or Matt Savage with questions.


North Korea & Myanmar OFAC Sanctions


On September 25, 2025, the Office of Foreign Assets Control (OFAC) announced sanctions for five individuals and one entity that participated in generating illicit revenue for North Korea’s Weapons of Mass Destruction (WMD) program.  As a result, Myanmar-based company Royal Shune Lei Company Limited and four of its employees/executive shall be added to OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List).


Please contact Josh Rodman or Kelly Mccorkle with questions.


Bike “Giant” Issued Withhold Release Order


On September 24, 2025, CBP issued a Withhold Release Order (WRO) against Taiwan-based bike company Giant Manufacturing Co. Ltd. after a CBP investigation reasonably indicated use of forced labor. Specifically, CBP identified the following forced labor indicators within Giant Manufacturing:

  • Abuse of vulnerability,

  • Abusive working and living conditions,

  • Debt bondage,

  • Withholding of wages, and

  • Excessive overtime.


As a result, CBP will detain any imports of bicycles, bicycle parts, and accessories manufactured by Giant Manufacturing Co. Ltd.


In response to the Withhold Release Order, Giant Manufacturing stated on September 25, 2025, that various policies have recently been implemented to negate these forced labor indicators, and that it will “seek the revocation of the WRO and explain that the company has already adopted appropriate measures.”

 



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Schulz Trade Law’s Role in Supporting Clients


While these changes may feel overwhelming for companies operating within their respective global sectors, Schulz Trade Law PLLC actively tracks these developments and offers advice on how to mitigate risk, assess tariff exposure, and adapt your compliance strategies. Our team is here to provide timely, tailored support and, importantly, help you make the trade.



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About Schulz Trade Law


We are a dedicated team of trade law professionals, committed to helping businesses navigate the complexities of international regulations and tariffs. With deep industry knowledge and a client-first approach, we provide clear, actionable insights to protect your interests and drive success in a dynamic global market.



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