Industrial Policy & Trade Monitor· 2668 actions· ✨ 89 recent

On June 2, 2026, USTR published final actionability findings in 60 parallel Section 301(b) investigations — the largest simultaneous Section 301 action in US history — determining that all 60 economies maintain unreasonable acts, policies, or practices by failing to impose or effectively enforce a prohibition on imports produced with forced labor. USTR proposed two additional duty rates: 10% on the 14 economies with partial forced-labor regimes (Canada, Ecuador, EU, Indonesia, Mexico, Pakistan, Argentina, Bangladesh, Cambodia, El Salvador, Guatemala, Malaysia, Taiwan, UK) and 12.5% on the remaining 46 economies. Tariff rates remain proposed pending a July 7, 2026 public hearing and subsequent finalization; the actionability determination is final.

President Trump signed a Presidential Proclamation on 20 February 2026 invoking Section 122 of the Trade Act of 1974 (19 U.S.C. § 2132) to impose a temporary 10% ad-valorem import surcharge on articles imported into the United States, effective 12:01 a.m. EST on 24 February 2026. The proclamation was issued within hours of the US Supreme Court's 20 February 2026 ruling in Learning Resources, Inc. v. Trump, which held that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to set tariffs and vacated the IEEPA-based reciprocal-tariff regime previously in effect. The Section 122 surcharge is statutorily limited to 150 days (terminates 24 July 2026 absent Congressional extension) and the statute caps any such surcharge at 15% ad valorem. Goods qualifying as USMCA originating from Canada or Mexico are exempt; CAFTA-DR textile/apparel articles meeting specified rules of origin are exempt; and a substantial product-exception list excludes critical minerals, energy products, certain pharmaceuticals, electronics, vehicles, aerospace products, specified agricultural goods, and goods already subject to Section 232 duties (the Section 122 duty does not stack on Section 232).

The US Department of Commerce preliminarily determined that chromium trioxide (chromic acid anhydride, used in chrome plating and surface-finishing) from India and Türkiye is being sold in the United States at less than fair value, following a September 2025 petition by American Chrome & Chemicals. Commerce set a preliminary weighted-average dumping margin and cash-deposit rate of 14.44% for India's Vishnu Chemicals (12.00% cash-deposit rate) and 40.88% for Türkiye's Şişe ve Cam Fabrikaları, triggering suspension of liquidation and cash-deposit collection on covered entries from both countries effective 2026-05-22. The investigation period was July 1, 2024 - June 30, 2025; final determinations are scheduled for 2026-08-10 (Türkiye) and 2026-10-07 (India, aligned with the companion countervailing-duty case).

The US Treasury's Office of Foreign Assets Control designated 32 individuals and entities based in Iran, the UAE, Turkiye, China, Hong Kong, India, Germany and Ukraine for operating procurement networks that supply Iran's ballistic missile and UAV programmes, including missile propellant precursors and UAV components. The action is Treasury's second round of nonproliferation sanctions since the 27 September 2025 reimposition of UN sanctions on Iran ("snapback") over its non-compliance with international nuclear and missile commitments. Designated entities include Iran-based Kimia Part Sivan Company (KIPAS), which Treasury says has worked with the IRGC-Qods Force to advance Iran's UAV programme. All property and interests of the designated parties subject to US jurisdiction are blocked, and US persons are generally prohibited from transacting with them.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 29 entries — 26 entities and 3 addresses — to the Entity List under the destinations of China (19), Turkey (9), and the United Arab Emirates (1). BIS determined these parties were diverting US-origin items to Iran, including to parties already on the BIS Entity List and on OFAC's Specially Designated Nationals (SDN) List, in support of Iranian drone-parts and electronics-procurement networks. The rule is a final rule effective October 8, 2025; new license requirements apply to all items subject to the EAR for these listed parties under a presumption-of-denial review policy.

On 9 October 2025, the US Treasury's Office of Foreign Assets Control (OFAC) designated more than 50 individuals, entities and vessels for facilitating Iranian crude oil, petroleum-product and liquefied petroleum gas (LPG) exports, in a coordinated action with the State Department. The network included 33 vessels transporting Iranian crude and LPG, shipping entities registered in Panama, the Marshall Islands, Ukraine and Liberia, an Iranian petrochemical producer, four Turkish petrochemical trading entities, five Chinese entities importing/refining/storing Iranian petroleum (including a China-based petrochemical-terminal operator, Jiangyin Foreversun Chemical Logistics Co., Ltd.), three Singapore-based logistics entities, and 27 entities based in Hong Kong, the UAE and India engaged in trading and shipping. The action was taken pursuant to the National Security Presidential Memorandum 2 (NSPM-2) maximum-pressure campaign against Iran and blocks all US property/interests of the designated parties, exposing non-US counterparties to secondary-sanctions risk.

The US Treasury's Office of Foreign Assets Control designated 21 entities and 17 individuals across three procurement networks supplying Iran's Ministry of Defense and Armed Forces Logistics (MODAFL) and its subordinate weapons producers. The networks sourced ballistic-missile guidance components (accelerometers, gyroscopes, MEMS) for the Shahid Bakeri Industrial Group and Shahid Hemmat Space Group, dual-use radar/missile-guidance electronics routed through Hong Kong and China for Shiraz Electronics Industries, and helicopter parts — including a US-origin helicopter — routed through Germany, Türkiye, Portugal and Uruguay for Iran Helicopter Support and Renewal Company (PANHA). The action is Treasury's first nonproliferation-sanctions tranche following the 27 September 2025 UN Security Council "snapback" reimposing pre-JCPOA sanctions on Iran.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to add 32 entities to the Entity List, with the largest bloc — 23 entries — under the destination of China, plus India (1), Iran (1), Singapore (1), Taiwan (1), Turkey (3), and the United Arab Emirates (2). The rule also removed two addresses from one Russian entry (Intertech Rus LLC) and made 27 typographical corrections to existing entries. Several Chinese additions — including Shanghai Fudan Microelectronics, Sino IC Technology, GMC Semiconductor (Wuxi), and Chinese Academy of Sciences units (National Time Service Center; Aerospace Information Research Institute) — were given footnote 4 designations, extending the EAR's foreign-direct-product (FDP) reach to non-US-origin items destined for Russian military end use. Three Turkish entries (Atempo, EB Teknoloji, Dentun Elektronik) and one Indian entry (AR Sales Pvt Ltd) were footnote-3 Russian Procurement Entity designations. The rule is a final rule effective September 12, 2025; all listed parties are subject to a license requirement for all items subject to the EAR with a presumption-of-denial review policy.

The US Treasury's Office of Foreign Assets Control designated 22 entities based in Hong Kong (18), the UAE, and Türkiye under Executive Order 13224 for facilitating sales of Iranian oil that benefit the IRGC-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization. The front-company network moves refinery payments for Iranian oil through offshore accounts to fund IRGC-QF activity; the action is the second round of sanctions under National Security Presidential Memorandum 2's "maximum pressure" campaign, following a June 6, 2025 action against Iranian exchange-house money-laundering networks. All property and interests of the designated entities within US jurisdiction are blocked, and US persons are generally prohibited from dealing with them.

On 20 June 2025, the US Treasury's Office of Foreign Assets Control designated one individual, eight entities, and one vessel pursuant to Executive Order 13382 (WMD proliferators) for procuring and transshipping sensitive machinery to Iran's Rayan Roshd Afzar Company (RRA), a producer of UAV components and aerospace software for the IRGC. The vessel SHUN KAI XING, owned by Hong Kong-based Unico Shipping Co Ltd and chartered by Singapore-based V-Shipping Pte Ltd, was carrying the machinery for RRA and an affiliated firm when its cargo was inspected; the designated network — including China-based Shenzhen Xinxin Shipping, Dongguan Zanyin Machinery and Equipment, Athena Shipping, shipmaster Zhang Yanbing, and Turkiye-based Edisa Dis Ticaret Limited Sirketi — then falsified bills of lading to obscure the Iran-bound, RRA-consigned cargo after the inspection.

On 30 April 2025 the US Department of State designated seven entities and identified two vessels as blocked property for facilitating trade in Iranian petroleum and petrochemical products, under Executive Order 13846 and in furtherance of National Security Presidential Memorandum 2 (NSPM-2, "Restoring Maximum Pressure on the Government of Iran"). The action named four UAE-based sellers and one purchaser of Iranian petrochemicals — including Solvent Organics (over $300 million in exports of Iranian-origin petrochemicals to third countries) and Alseerah Trading (over $150 million) — plus a Turkiye-based petrochemical trader, an Iran-based cargo inspection company, and a marine management company involved in transporting millions of barrels of Iranian crude. Secretary of State Marco Rubio stated the goal was to drive Iran's illicit oil and petrochemical exports, including to China, to zero.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 18 persons to the Unverified List (UVL) and removing 5. Of the 18 additions, 5 are under China, 6 under Finland, 3 under Türkiye, 2 under Kazakhstan, 1 under Italy, and 1 under the United Kingdom — a geographic distribution dominated by Russia-adjacent diversion corridors. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends use of EAR license exceptions for shipments to listed parties and requires US exporters to obtain a UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 25 April 2025 (90 FR 17339).

President Trump signed two Presidential Proclamations on 11 February 2025 reinstating a universal 25% ad-valorem tariff on all steel-mill products and raising the aluminum tariff from 10% to 25% on all imports into the United States, effective 12 March 2025. The proclamations revoked every bilateral exclusion and quota arrangement negotiated by the Biden administration with the EU, UK, Japan, Korea, Australia, and others under the 2021-2022 "alternative measures" frameworks, returning all trading partners to the baseline Section 232 rate without product-level or country-level carve-outs.

The US Bureau of Industry and Security (BIS) final rule (89 FR 87261; FR Doc 2024-25411) added 40 entities under 42 entries plus four addresses to the Entity List under the destinations China (11), India (5), Malaysia (2), Russia (13), Singapore (1), and Turkey (14), and modified 52 existing entries across China, Estonia, Finland, India, Turkey, the UAE and the UK. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish, Indian, Malaysian and Singaporean entities listed for transshipping controlled US-origin items to Russian defense end users; the 13 Russia entries cover chemical and biological warfare R&D and defense procurement networks. License requirement is "all items subject to the EAR" with a policy/presumption of denial; four China addresses get the narrower "CCL + EAR99 supp. 7" scope. Effective on publication 2024-11-01.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 8 persons to the Unverified List (UVL) and removing 2. Of the 8 additions, 3 are under China, 2 under Germany, 1 under Pakistan, and 2 under Türkiye. Of the 2 removals, 1 is under Saudi Arabia and 1 under China. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting any item subject to the EAR. The rule was published and effective the same day, 16 October 2024 (89 FR 83428, FR Doc 2024-23638).

The US Bureau of Industry and Security (BIS) final rule (89 FR 68544; FR Doc 2024-19130) added 123 entities under 131 entries to the Entity List with destinations Russia (63), China (42), Iran (11), Turkey (8), and one each in Canada, Cyprus, Kazakhstan, Kyrgyzstan, Crimea Region of Ukraine, Ukraine, and the United Arab Emirates. The dominant rationale is Russia-diversion enforcement: Chinese, Turkish and other third-country firms (e.g., MAK Logistics, Megatek Ltd., Wellgo International, AllChips Limited, Chipgoo Electronics) named for supplying U.S.-origin electronics and dual-use items to Russian industry and military, plus designation of large numbers of Russian military manufacturers (e.g., JSC 75 Arsenal, FSE Aleksinsky Chemical Plant) as military end users. License requirement is "all items subject to the EAR" with policy/presumption of denial; case-by-case for EAR99 food and medicine to certain Russian military end users. Effective on publication 2024-08-27.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 13 persons to the Unverified List (UVL) and removing 8. Additions are under five destinations: China (8), Türkiye (2), Cyprus (1), Kyrgyzstan (1), and the United Arab Emirates (1). Removals span China (6), UAE (1) and Russia (1). The single Russian entry (EFO Ltd.) was removed from the UVL because BIS simultaneously moved it to the Entity List, allowing BIS to delete Russia entirely as a UVL destination. UVL placement does not impose a license-denial presumption (unlike the Entity List) but suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement before exporting items subject to the EAR. Published and effective the same day, 3 July 2024 (89 FR 55036, FR Doc 2024-14642).

The US Bureau of Industry and Security (BIS) final rule (89 FR 14385; FR Doc 2024-03969; Docket 240215-0050; RIN 0694-AJ54) added 93 entities under 95 entries to the Entity List, effective 23 February 2024, with destinations Russia (63), Turkey (16), China (8), UAE (4), Kyrgyzstan (2), India (1), and South Korea (1). The dominant rationale is enforcement of Russia-diversion controls: 46 Russian defense manufacturers are designated as military end users acquiring US-origin items for Russia's armed forces, five Chinese entities (including Dennex Enterprises Limited and Shenzhen Speed Industrial Materials Co.) are cited for facilitating diversion of controlled microelectronics to Russia, and 16 Turkish firms are cited as procurement hubs obtaining US-origin items of importance to Russia's war effort. Four UAE entities are designated for transshipment networks serving both Russia and Iran. All entities are subject to a presumption of denial for EAR-controlled items; Russian military end users are additionally subject to the Russia/Belarus FDP rule (15 CFR 734.9(g)).

On 8 December 2023 the Bureau of Industry and Security (BIS) published a direct final rule (88 FR 85479; FR Doc 2023-26532) making two export-liberalisation amendments to the Export Administration Regulations (EAR). First, BIS removes Chemical and Biological Weapons (CB) proliferation column controls from the Commerce Country Chart for exports of certain pathogens and toxins (ECCNs 1C351, 1C353, and 1C354) when destined to Australia Group (AG) member countries, on the basis that AG members operate equivalent domestic CBW-export controls. Second, the rule revises the Crime Control and Detection (CC) column entries for Austria, Finland, Ireland, Liechtenstein, South Korea, Sweden, and Switzerland, reflecting the updated US assessment of those countries' law-enforcement export-control standards. Both changes are effective on publication and reduce US export-licensing burdens for allied-country destinations without altering controls for non-allied markets.

The Bureau of Industry and Security (BIS) added 49 entities under 52 entries to the Entity List, effective October 11, 2023. The bulk of additions — 42 of 49 — are Chinese entities determined to be acting contrary to US national security or foreign policy interests, predominantly for supplying US-origin integrated circuits to Russian defense-sector consignees after March 1, 2023 in violation of export controls. Remaining entities span Estonia, Finland, Germany, India, Turkey, UAE, and the United Kingdom and were designated on similar Russia-diversion or end-use violation grounds. All listed parties face a license requirement for all EAR-subject items, reviewed under a presumption of denial.

The Bureau of Industry and Security (BIS) removed 35 persons from the Unverified List (UVL) effective 22 August 2023, spanning seven destinations: 27 entities in China, plus one each in Indonesia, Singapore, Turkey, and UAE; two in Pakistan; and two Russian entities removed as a conforming change after being escalated to the more restrictive Entity List. The 33 cooperative removals follow successful completion of end-use checks verifying each party's bona fides under §744.15(c)(2) of the EAR. Removal restores eligibility for EAR license exceptions and eliminates the UVL Statement requirement for US exporters shipping EAR-subject items to these parties.

The Bureau of Industry and Security (BIS) added 28 entities under 32 entries to the Entity List effective April 12, 2023, targeting front companies and logistics networks attempting to evade US export controls to acquire US-origin items in support of Russia's military and defense industrial base. Twelve of the entities are Chinese electronics and semiconductor distributors operating as procurement intermediaries; ten are Russian logistics and trading firms; six are spread across Armenia, Malta, Singapore, Spain, Syria, Turkey, UAE, and Uzbekistan as diversion facilitators. All listed entities are subject to a license review policy of denial for virtually all EAR-controlled items.

The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 32 persons across 13 countries to the Unverified List (UVL) on the basis that BIS was unable to verify their bona fides through end-use checks. The largest concentration is in China (14 entities), followed by the UAE (5) and Turkey (4), with single entries in Bulgaria, Canada, Germany, Indonesia, Israel, Malaysia, and Singapore. UVL placement suspends EAR license exceptions for shipments to listed parties and requires US exporters to obtain a signed UVL Statement and file Electronic Export Information in the Automated Export System before shipping any item subject to the EAR. Published 24 March 2023 (88 FR 17706, FR Doc 2023-06171); effective 24 March 2023.

The US Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding 37 entities under 40 entries to the Entity List, effective December 17, 2021. The additions span three distinct threat rationales: (1) support for Chinese military modernization across semiconductors, submarine cables, armored vehicles, and defense electronics; (2) the Academy of Military Medical Sciences and 11 affiliated institutes pursuing biotechnology processes for military end uses, including purported brain-control weaponry under EAR §744.11(b); and (3) a cross-border Iran sanctions-evasion network operating across China, Georgia, Malaysia, and Turkey that diverted US-origin items to Iran's defense industries and advanced conventional weapons programs. All 40 entries carry a presumption-of-denial licensing policy for all items subject to the EAR, with no license exceptions available.

The US Bureau of Industry and Security (BIS) added 47 entities across 51 entries to the EAR Entity List effective 22 September 2020, covering entities in China, Hong Kong, Iran, Pakistan, Canada, Malaysia, Oman, Thailand, Turkey, the UAE, and the UK. All 47 entities were determined to be acting contrary to US national security or foreign policy interests. For 39 of the 47 entities BIS imposed a license requirement for all EAR-subject items with a presumption-of-denial review policy; the remaining eight face case-by-case review. The round targeted Iranian dual-use procurement networks, Chinese military-affiliated research institutes, and Pakistan-linked proliferators, reinforcing the layered export-control perimeter across multiple adversary programs simultaneously.