Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

A divided three-judge panel of the US Court of International Trade (CIT), in Slip Op. 26-47 (Court Nos. 26-01472 and 26-01606, decided 7 May 2026), held 2-1 that President Trump's Proclamation 11012 — which imposed a temporary 10% ad-valorem import surcharge under Section 122 of the Trade Act of 1974 — exceeded statutory authority because the proclamation did not identify a "fundamental international payments problem" as defined by the 1974 Congress (the balance-of-trade or current-account deficit relied upon by the government is not the type of balance-of-payments deficit the statute contemplates). The court issued a permanent injunction prohibiting CBP from collecting Section 122 duties from the three prevailing plaintiff- importers and ordered refunds with statutory interest for duties already paid; it declined to issue a nationwide injunction. The US Court of Appeals for the Federal Circuit (CAFC) entered an administrative stay of the CIT injunction on 12 May 2026 pending appeal, and the CIT denied the government's own motion to stay its ruling on 20 May 2026; the CAFC appeal is now pending.

Argentina's Ministerio de Economía issued Resolución 531/2026 on 20 April 2026, closing the changed-circumstances review under the anti-dumping regime of Resolución 915/2021 and excluding disassembled sports footwear with non-leather soles or uppers (HS 6401.10.00–6405.90.00) imported from China from the existing USD 15.70/pair minimum-FOB-value anti-dumping measure. The Comisión Nacional de Comercio Exterior (CNCE) recommended the exclusion following requests from domestic manufacturers Topper and Puma Sports Argentina, finding that high-performance sports footwear requires components and materials unavailable from domestic suppliers and that assembly operations add approximately 20% local value while supporting employment. The measure operationalises the Milei administration's deregulatory programme via a CNCE-mediated precedent for dismantling legacy protectionist AD measures without formal statutory repeal.

On 19 March 2026 the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, imposed a £390,000 monetary penalty on Apple Distribution International Limited (ADI), the Ireland-incorporated subsidiary of Apple Inc. The penalty relates to two payments totalling approximately £635,000 made in 2022 to Okko LLC, a sanctioned Russian app developer, for App Store revenue. ADI's failure to cancel the payments amounted to conduct in the UK that breached regulation 12 of the Russia (Sanctions) (EU Exit) Regulations 2019, which prohibits making funds available to a person owned or controlled by a designated person. The enforcement is notable as the **first use of OFSI's new settlement mechanism** (introduced February 2026), which allows OFSI and a subject of an enforcement action to resolve a civil monetary penalty case via time-bound negotiation. OFSI applied a 35% discount to the £600,000 baseline penalty to reach the £390,000 final figure, reflecting ADI's voluntary self-disclosure (made 4 October 2022) and cooperation.

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).

On 1 February 2026 India's Ministry of Finance tabled the Finance Bill 2026 alongside Customs Notifications 01/2026 to 03/2026-Customs, restructuring the customs tariff schedule across hundreds of HS lines. Duty rates rise on a range of consumer and finished-goods lines (e.g. umbrellas: 20% to "20% or ₹60/piece, whichever is higher"; potassium hydroxide: 0% to 7.5%; INVAR steel: 5% to 7.5%; radio-trunking parts: 5% to 15%; video-game parts: 5% to 20%) while falling on nuclear and renewable-energy inputs (fuel elements and control/absorber rods for nuclear reactors: 7.5% to 0%; sodium antimonate for solar glass: 7.5% to 0%) and on personal-use dutiable imports under heading 9804 (20% to 10%, effective 1 April 2026). Roughly 80 exemptions previously granted by standalone notification are being written into the First Schedule of the Customs Tariff Act at unchanged rates, effective 1 May 2026 — converting administratively-reversible exemptions into statutory ones.

Presidential Decree No. 10813 (Resmî Gazete, 7 January 2026, issue 33130) amends Article 62 of Türkiye's Customs Law implementation decree (Decision 2009/15481) to abolish the simplified customs declaration regime for individual low-value imports arriving by post or express courier. Previously, shipments up to EUR 30 (inclusive of freight) qualified for a flat-rate, simplified declaration; from 6 February 2026 all such imports — regardless of value — must clear through standard customs procedures and the ordinary tariff schedule. Prescription medicines and medical supplements remain under the simplified regime up to EUR 1,500.

On 30 December 2025 the General Office of the Shanghai Municipal People's Government issued Hufubangui [2025] No. 20, a three-year action plan (1 January 2026 - 31 December 2028) to support the transformation and upgrading of advanced manufacturing. The plan sets quantitative targets — 100 new manufacturing enterprises with annual output above CNY 1 billion by 2028 (cumulative 600+), 500 new above-designated-size supply-chain enterprises, 100+ new national-level green factories, a robot density of 600 units per 10,000 workers, and 70%+ digital-equipment penetration — across next-generation electronics, intelligent connected new-energy vehicles, high-end equipment, advanced materials, green low-carbon and fashion consumer-goods industries, plus emerging bets on the low-altitude economy, commercial aerospace, embodied intelligence (robotics) and biomanufacturing. It is funded through tiered direct subsidies rather than tax relief: one-off R&D subsidies up to CNY 10 million, equipment/new-materials cost-share up to 30% of contract value (capped at CNY 20 million), technical- transformation loan/leasing interest support up to CNY 20 million cumulative, and 0.8-1.3% interest subsidies on component/material backup-inventory financing.

On 26 June 2026 the Canadian International Trade Tribunal (CITT) issued a final injury finding in Inquiry NQ-2025-008, determining that dumped and subsidized imports of thermoformed molded fibre tableware from China have caused material injury to the Canadian domestic industry. Final anti-dumping duties ranging from 81.7% to 332.4% of export price, plus countervailing (subsidy) duties ranging from 0.5% to 18.9%, are now collected by the Canada Border Services Agency (CBSA) on goods released on or after 26 June 2026. The case originated from a complaint by CKF Inc. (Hantsport, Nova Scotia).

Taiwan's Executive Yuan on 11 September 2025 passed the special budget "Central Government Special Budget for Strengthening Economic, Social and Livelihood National Security Resilience in Response to International Circumstances," allocating NT$46 billion (approx. USD 1.5 billion) to the Ministry of Economic Affairs for four industry-support measures aimed at firms hurt by US tariffs. The four measures — preferential export-loan guarantees, SME diversified-development loans, R&D/equipment-transformation subsidies, and overseas-market-expansion subsidies — had already been soft-launched on 7 August 2025 under an emergency "shift funds to urgent need first" principle, with the September budget formalising and funding them. As of the government's mid-October 2025 status update, over 1,200 applications had been received across the four programmes, generating roughly NT$8.9 billion in approved financing.

Commission Implementing Regulation (EU) 2025/1564 of 24 July 2025 is the EU's largest-ever trade countermeasure package: additional customs duties on approximately €93 billion of US-origin goods (Annexes I–XIII) plus an export prohibition on specified EU products to the United States (Annex XIV), adopted under Regulation (EU) No 654/2014 (the EU commercial-policy enforcement regulation) in response to the second Trump administration's Section 232 reinstatement and automobile tariffs. The regulation supersedes and repeals Commission Implementing Regulation (EU) 2025/778 and three earlier rebalancing CIRs. Application was suspended from 5 August 2025 following the EU-US trade framework agreement of 27 July 2025; the suspension was extended by a further six months from 4 February 2026. CIR 2025/1564 remains in force as a conditionally-reinstateable rebalancing framework while negotiations continue.

Bangladesh's National Board of Revenue gazetted SRO 225-Ain/2025/48/Customs and SRO 226-Ain/2025/48/Customs on 29 May 2025, revising the minimum customs valuation (tariff-value) floors used to assess duty on a range of imported consumer and industrial goods, effective 2 June 2025. The amendment raised minimum import values for chocolate and cocoa-containing food preparations, removed the minimum-value floor for base oil used by petroleum processing/blending industries, and adjusted floors — mostly downward — for soap and other cleaning preparations and a handful of additional product lines. Minimum-value schemes set a customs-assessable price floor per unit regardless of the invoiced transaction value, so a higher floor functions as a de facto increase in the duty base (and hence landed cost) for under-invoicing-prone product categories, while a removed or lowered floor eases the duty base for the affected goods.

President Trump signed Executive Order 14257 on 2 April 2025 declaring a national emergency over US trade deficits and imposing a baseline 10% ad-valorem tariff on imports from nearly all trading partners effective 5 April, with higher country-specific "reciprocal" rates effective 9 April. The rate schedule was constructed from a formula tied to bilateral goods-trade deficits and ranged from 10% (UK, Singapore, Brazil, Australia, others) through 20% (EU), 24% (Japan), 25% (Korea), 32% (Taiwan, Indonesia, Switzerland), 34% (China, later raised to 84% then 125% during the April escalation), 46% (Vietnam), 49% (Cambodia). Multiple subsequent EOs paused the country-specific rates for 90 days for non-China destinations on 9 April while keeping the 10% baseline, pending bilateral negotiations.

Commission Implementing Regulation (EU) 2025/778 of 14 April 2025, adopted under Regulation (EU) No 654/2014 (the EU enforcement regulation for international trade rights), reinstates the EU's 2018 and 2020 commercial rebalancing measures against the United States and adds new countermeasures in response to the second Trump administration's 10 February 2025 Section 232 proclamations, which restored a universal 25% tariff on steel imports and raised the aluminium tariff to 25% effective 12 March 2025 (filed as 2025-02-11-us-section-232-steel-aluminum-global-tariff-reinstatement). The combined package targets approximately €26 billion of EU imports from the United States — matching the scope of US measures affecting EU exports — and combines the reinstatement of pre-existing duties on a first tranche of products (steel, aluminium, agricultural goods, motorcycles, and other industrial items originally subject to the 2018 and 2020 lists) with new duties on roughly €18 billion of additional US-origin goods spanning poultry, beef, certain seafood, nuts, eggs, dairy, sugar and vegetables on the agricultural side, and steel, aluminium, textiles, leather, appliances, plastics and wood products on the industrial side. Tariff rates layer onto MFN duties at up to 50% for some products, mirroring the structure of the 2018 measures. On the same day the Commission published Implementing Regulation (EU) 2025/786, which suspends application of Articles 2 and 3 of 2025/778 for 90 days, until 14 July 2025, to allow space for bilateral negotiations following the US 9 April 2025 announcement of a 90-day pause on its own reciprocal-tariff regime (2025-04-02-us-trump-reciprocal-tariff-regime). The legal scaffolding therefore exists and is in force, but no duties were collected during the suspension window. This is the first standalone EU rebalancing instrument adopted against the United States in the second Trump administration and the first major use of Reg 654/2014 since the 2018-2020 Section 232 episode.

Regulation (EU) 2025/40, published in the Official Journal on 22 January 2025 and entering into force on 11 February 2025, replaces the 1994 Packaging and Packaging Waste Directive 94/62/EC with a directly-applicable Regulation. It mandates binding recycled-content targets for plastic packaging (by polymer and format, reaching 30–65% by 2030 with higher targets by 2040), minimum reusable-packaging shares for beverages and transport, recyclability standards for all packaging placed on the EU market from 2030, deposit-return-scheme obligations for beverage containers from 2029, and bans on specified single-use plastic packaging formats. General application begins 12 August 2026, with staggered compliance windows extending to 2030 and beyond, affecting all non-EU exporters shipping consumer goods, beverages, or e-commerce fulfilment into the EU single market.

Bahrain's Ministry of Industry and Commerce issued Decision No. 53 of 2024, amending the conditions governing foreign ownership in commercial activities, effective 18 October 2024. The reform permits 100% foreign ownership of commercial enterprises — including wholesale and retail trade and authorized distribution — without a mandatory Bahraini local partner, where the foreign company operates in at least 10 countries or generates annual revenue above EUR 750 million. It simultaneously reduces the minimum capital requirement for foreign-owned companies in Bahrain by 95%, from BHD 2,000,000 (~EUR 5m) to BHD 100,000 (~EUR 240,000), materially expanding the addressable foreign-investor pool to mid-market commercial enterprises.

President Lukashenko signed Decree No. 278 on 10 July 2024, extending the prohibitive import customs duty regime established under Decree No. 16 (12 January 2024) through 30 June 2025, preventing its lapse at year-end 2024. The decree also expands the commodity list subject to elevated import duty rates. The measure explicitly frames the duties as retaliatory, targeting goods originating from states designated as "unfriendly" to Belarus — principally EU member states, the US, UK, Canada, Japan, Australia, New Zealand, Switzerland, Norway, Iceland, and other sanctioning jurisdictions. Co-ordinated with Russia's EAEU parallel-import framework (Resolution No. 506), the regime affects the cost arithmetic for sanctioned-goods routing through EAEU customs-union channels and signals continued institutionalisation of Belarus's counter-sanctions architecture.

On 13 March 2024 the State Council issued the Action Plan on Promoting Large-Scale Equipment Renewal and Consumer Goods Trade-In as Guo Fa [2024] No. 7, distributed by NDRC alongside ten implementing ministries. Branded the "Two New" (两新) initiative, it is the flagship Xi/Li-era domestic-demand industrial-policy instrument structured around four action lines (equipment renewal, consumer-goods trade-in, recycling and circular utilisation, standards uplift) with twenty specific tasks and 2027 quantitative targets including ≥25% increase in equipment investment vs 2023 across industry, agriculture, construction, transport, education and healthcare. Funded by CNY 150bn of ultra-long-term special treasury bonds in 2024, expanded to CNY 300bn earmarked in 2025, the programme drove >CNY 1.3 trillion of consumer-goods trade-in transactions (autos, appliances, home furnishings, e-bikes) in its first year and is the central pillar of Beijing's response to the property-sector slowdown.

The Bureau of Industry and Security published a final rule on 6 June 2022 (effective 2 June 2022) consolidating corrections, clarifications, and substantive amendments to the series of EAR Russia/Belarus rules issued between February and May 2022. The most significant substantive change eliminates the EAR99 food and medicine carve-out for 146 footnote-3-designated military end-user entities already on the Entity List, subjecting all items subject to the EAR — including previously exempt food and medicine — to licensing requirements with a policy of denial for the FSB, SVR, and GRU. Additional provisions clarify luxury goods value thresholds, oil refinery sector controls, and civil telecommunications license review policy, and correct cross-references in the Foreign Direct Product Rules for Russia and Belarus.

Canada amended the Special Economic Measures (Russia) Regulations via SOR/2022-102, registered 18 May 2022, adding Schedule 6 (luxury goods) and Schedule 7 (goods usable in weapons production/manufacturing) to the list of items prohibited for export to, and in Schedule 6's case also import from, Russia. Both schedules took effect 60 days after registration (17 July 2022). Schedule 6 covers luxury alcohol, tobacco, textiles, footwear, clothing, jewellery, kitchenware, art, and some machinery; Schedule 7 covers raw materials (including tungsten and aluminium), pumps, vehicle parts, construction equipment, watercraft, and medical/dental/surgical equipment. The regulation also added 14 individuals to the Schedule 1 asset-freeze list.

Russian Government Resolution No. 506 of 29 March 2022, signed by Prime Minister Mikhail Mishustin and effective 30 March 2022, authorises the Ministry of Industry and Trade (Minpromtorg) to designate categories of goods exempt from articles 1252(4), 1359(6) and 1487 of the Russian Civil Code on national/regional exhaustion of trademark and other intellectual- property rights. Followed by Minpromtorg Order No. 1532 of 19 April 2022 publishing an initial list of 55 goods categories and named brands — including pharmaceuticals, electronics, automotive parts, mineral fuels, industrial chemicals, paper, textiles, base metals, and consumer goods — for which parallel (grey-market) imports without IP-holder consent are legalised. Designed as a sanctions-circumvention and supply-substitution instrument after the Western corporate exodus of March 2022; extended annually and most recently re-authorised through 31 December 2026.

The Bureau of Industry and Security created Supplement No. 5 to 15 CFR Part 746, establishing a new licensing requirement for the export, reexport, or in-country transfer of luxury goods to Russia, Belarus, and to Russian or Belarusian oligarchs and malign actors anywhere in the world, effective 11 March 2022. Covered goods span over 570 HTS-6 line items across categories including spirits and tobacco (above de minimis thresholds), clothing and leather goods (>$1,000 per item), jewelry and precious gemstones, watches (>$100), vehicles (>$25,000), seafood/caviar (>$100), art and antiques, and recreational vessels. The rule targets both bulk commercial exports to Russia and Belarus and personal luxury procurement by designated oligarchs worldwide, with a policy of denial for all such licence applications.

The UK government announced on 15 March 2022 that it would ban the export of high-end luxury goods to Russia in response to the invasion of Ukraine. The measure was implemented via new regulation 46B of the Russia (Sanctions) (EU Exit) Regulations 2019, inserted by the Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022 (SI 2022/452), which was made on 13 April 2022 and came into force at 5pm on 14 April 2022. Regulation 46B prohibits the export, supply, or making available of luxury goods to, or for use in, Russia, covering goods with a sales price over £250 (excluding VAT) and vehicles over £42,000, spanning high-end fashion, works of art, jewellery, and vehicles, subject to licensing exceptions in Part 7.