Industrial Policy & Trade Monitor· 2669 actions· ✨ 89 recent

Presidential Proclamation 11021 of 2 April 2026 (signed by President Trump, effective 6 April 2026 at 12:01 a.m. EDT, published 9 April 2026 at 91 FR 18201) consolidates and restructures the Section 232 tariff architecture for aluminum, steel, and copper. The proclamation modifies Proclamations 9704 (aluminum), 9705 (steel), and 10962 (copper) and applies tiered ad valorem duties to the full customs value of imported articles regardless of metal content: 50% on aluminum/steel articles and most copper articles; 25% on certain copper articles and on derivative articles substantially made of the three metals; 10% on derivative articles produced abroad using entirely US-smelted/cast metals; and 0% supplemental duty where existing tariffs already meet a 15% combined-rate floor. UK products receive preferential rates (25% on primary articles and 15% on certain derivatives) contingent on UK smelting/casting under the US–UK trade framework.

On 6 February 2026 Presidents Trump and Modi announced a framework for an Interim Trade Agreement that resets the bilateral tariff posture installed in 2025. Two operative instruments: (i) an executive order signed 6 February eliminating, effective 7 February 2026, the additional 25% IEEPA "Russian-oil" duty on Indian imports imposed by EO 14329 (27 August 2025), conditional on India's commitment to cease buying Russian crude and to expand defence cooperation; and (ii) reduction of the EO 14257 reciprocal-tariff rate on India from 25% to 18% on listed product categories (textiles and apparel, leather and footwear, plastics and rubber, organic chemicals, home décor, artisanal products, certain machinery), to take effect on finalisation of the Interim Agreement. India commits to eliminate or reduce tariffs on all US industrial goods and a wide range of agricultural products (DDGs, red sorghum, tree nuts, fresh and processed fruit, soybean oil, wine, spirits) and to purchase >USD 500bn of US energy, ICT, coal, aircraft and aircraft parts, and precious-metals products over five years. The framework also commits the parties to negotiating "robust, ambitious, and mutually beneficial digital trade rules" and to addressing non-tariff barriers in medical devices, ICT import licensing, and food/agricultural standards. US tariff reductions on Indian generic pharmaceuticals, gems, diamonds, aircraft parts, and certain automotive components are flagged as contingent on completion of the full Interim Agreement.

The US Department of Commerce preliminarily determined that unwrought palladium from Russia is being sold in the United States at less than fair value, setting a preliminary weighted-average dumping margin and cash-deposit rate of 132.83% ad valorem for the Russia-wide entity (calculated using facts available with adverse inferences after no respondent cooperated). The investigation covered the January 1 - June 30, 2025 period and was applicable from 2026-02-19. Commerce confirmed the same 132.83% margin in its final determination (2026-05-01), but the US International Trade Commission subsequently found no material injury to the US industry (2026-05-29), so no antidumping duty order was issued and the cash-deposit requirement was discontinued.

The US Department of Commerce preliminarily determined that Russian producers and exporters of unwrought palladium receive countervailable subsidies, and set a preliminary all-others countervailing duty cash-deposit rate of 109.10% ad valorem (the same rate applied to the two named respondents, JSC Urals Innovative Technologies and Prioksky Plant of Non-Ferrous Metals, both calculated using facts available with adverse inferences). The investigation was initiated 2025-08-19 covering the 2024 calendar-year period, with the preliminary determination effective 2026-03-11. A companion antidumping duty investigation on the same product ran in parallel; Commerce issued its final affirmative CVD determination on 2026-05-20.

President Trump signed Executive Order 14323, "Addressing Threats to the United States by the Government of Brazil," on 30 July 2025 (published in the Federal Register on 5 August 2025 as FR doc 2025-14896). Invoking IEEPA and the National Emergencies Act, the order declared a country- specific national emergency citing "policies, practices, and actions" of the Lula government — including the criminal prosecution of former president Jair Bolsonaro, asserted infringement of the free-expression rights of US persons via DSA-style platform-content rules, and retaliatory measures targeting US digital firms — as constituting an "unusual and extraordinary threat" to US national security, foreign policy, and economy. The EO imposed a 40% additional ad valorem duty on Brazilian-origin goods effective for entries on or after 12:01 a.m. EDT on 6 August 2025; stacked on top of the 10% baseline reciprocal rate from EO 14257/14326, the cumulative rate reached 50% for non- exempt goods. Annex I exempted civil aircraft and parts, orange juice, certain machinery, certain metals, and energy/energy products. The EO was amended on 20 November 2025 (effective for entries on or after 13 November 2025) to exempt 238+ HTSUS codes for agricultural products (beef, tropical produce, nuts, coffee, cocoa, cassava derivatives, etc.) following initial Trump-Lula bilateral negotiations on 6 October 2025. The IEEPA-tariff component was terminated by EO of 20 February 2026 ("Ending Certain Tariff Actions") within hours of the SCOTUS 6-3 ruling in *Learning Resources, Inc. v. Trump* holding that IEEPA does not authorize the imposition of tariffs.

The US Department of Commerce preliminarily determined that countervailable subsidies are being provided to producers and exporters of silicon metal from Laos, Australia, Norway, and Thailand, publishing four parallel preliminary affirmative CVD determinations on 2025-09-26 following an initiation on 2025-05-21 (petition by Ferroglobe USA, Inc. and Mississippi Silicon LLC). For Laos, Commerce set a preliminary countervailable-subsidy cash-deposit rate of 240.00% ad valorem for both the sole mandatory respondent, Lao Silicon Co., Ltd., and the all-others rate, based entirely on adverse facts available after finding the respondent did not cooperate. Companion CVD investigations against Australia, Norway, and Thailand were found affirmative the same day, each with its own preliminary subsidy-rate cash-deposit schedule. Commerce ordered CBP to suspend liquidation and require cash deposits at the indicated rates on covered entries from the Laos determination onward. Final CVD determinations are aligned with companion antidumping investigations on the same product.

The US Department of Commerce, following affirmative final less-than-fair-value determinations and an affirmative material-injury finding by the US International Trade Commission, issued antidumping duty orders on silicon metal from Angola and Laos, effective 2026-04-16. Commerce set a 68.45% ad valorem weighted-average dumping margin for Angola (both named respondents and the all-others rate) and a 94.44% margin for Laos, both based entirely on adverse facts available after the respondents did not cooperate with the investigation. The orders stem from an April 2025 petition by Ferroglobe USA, Inc. and companion less-than-fair-value investigations initiated 2025-05-21 that also covered Australia and Norway, where preliminary and final LTFV determinations followed on a later schedule.

Executive Order 14289 of 29 April 2025 provides that certain overlapping US tariffs should not have a cumulative effect. Where an article is subject to the Section 232 automobile and parts tariffs (Proclamation 10908), it is not subject to the northern- or southern-border duties (EO 14193 / 14194) or to the steel and aluminium Section 232 tariffs; border duties in turn take priority over the metals tariffs, while steel and aluminium tariffs may still stack with each other. The order applies retroactively to entries made on or after 4 March 2025.

BIS published a temporary final rule (FR Doc 2020-22608) establishing a certification procedure under which US importers holding contracts for certain Brazilian steel articles signed before Presidential Proclamation 10064 (28 August 2020) could apply for relief from the absolute quantitative limitation imposed by that proclamation. Eligible parties must certify that the contract was executed before 28 August 2020, specifies delivery before 31 December 2020, and that domestic procurement is infeasible. The relief mechanism lapsed at year-end 2020.

The US Department of Commerce preliminarily determined that producers and exporters of silicon metal from Kazakhstan received countervailable subsidies at a 120.00% economy-wide rate, and instructed US Customs and Border Protection to begin collecting cash deposits from importers at that rate. The countervailing-duty investigation was initiated 2020-07-27 following a June 2020 petition by Globe Specialty Metals, Inc. and Mississippi Silicon LLC, the same domestic petitioners behind the concurrent antidumping cases against Bosnia and Herzegovina, Iceland, and Malaysia. 2019 Kazakh silicon metal imports subject to the case were valued at approximately $14.9 million.

The US Department of Commerce preliminarily determined that silicon metal from Bosnia and Herzegovina and Iceland is being sold in the United States at less than fair value, and instructed US Customs and Border Protection to begin collecting cash deposits from importers. Bosnia and Herzegovina's sole respondent, R-S Silicon d.o.o., and the all-others rate were set at 21.41%; Iceland's sole respondent, PCC Bakki Silicon hf, received 47.54%, with the all-others rate at 37.83%. A concurrent antidumping investigation of silicon metal from Malaysia, initiated on the same 2020-07-27 date, was not part of this preliminary determination and remained pending. The case followed a July 2020 petition by Globe Specialty Metals, Inc. and Mississippi Silicon LLC.