Possible 100% Additional Duties on Chinese Goods
On October 9, China announced the imposition of large-scale export controls on most every product made in China. This includes rare earth metals. These export controls will affect every country.
In a social media post, President Trump announced his intent to respond with an additional 100% tariff on all Chinese products, beginning November 1. As of today, we have seen no formal announcements from the White House implementing these tariffs and reports indicate that Trump could ease his stance. However, if these tariffs do go into effect, Carmichael will be ready by taking additional steps for our clients.
Starting immediately, if importers wish to hold off entry process for any shipments of Chinese products, importer should immediately contact our operation team to provide instructions to hold off entry process for all or any shipments they wish to hold or to process. Carmichael will hold off entry process only if importers provide instructions to do so.
We will follow this process until we can confirm that the duties will not be assessed. If you have any questions, please give us a call.
Section 301 Report Concludes Nicaragua Violating Human and Labor Rights
On October 20, 2025 the Office of the U.S. Trade Representative (USTR) released a Section 301 Investigation report concluding that Nicaragua is in violation of human and labor rights and that the authoritarian actions taken by the Nicaraguan government directly and indirectly harm U.S. commercial interests.
In the report the USTR found that responsive action in regards to these violations is appropriate and recommended several possible courses of action including but not limited to suspension of the Dominican Republic-Central America-United States Free Trade Agreement (CAFTA-DR) benefits either immediately or phased in, the application of a 100% tariff on Nicaraguan exports either immediately or phased in, or the application of a 100% tariff on some Nicaraguan benefits either immediately or phased in.
A Federal Register notice is scheduled to be published. This notice invites the public to provide written comments on the proposed action by November 19.
To view the extent of the report released by USTR, click here.
Section 232 Tariffs to Take Effect November 1 for Medium- and Heavy-Duty Vehicles, Parts, and Buses
In a proclamation issued late on October 17, 2025. Trump has indicated that Section 232 tariffs on heavy- and medium-duty trucks and their parts as well as buses will take effect at 12:01 AM on November 1, 2025. The tariff percentages will be set at 25% for heavy- and medium-duty trucks and 10% for buses.
USMCA preferential treatment will be available, with approval, for vehicles subject to this order other than buses and other vehicles under heading 8702. This treatment will allow U.S. content to enter without the additional duty while the non-U.S. Content will be subject to the tariff. For parts subject to USMCA will enter duty free until the Commerce Department has designed a methodology for applying the tariffs to the non-U.S. content of parts. However, this USMCA treatment will not apply for knock-down kits or equivalent parts compilations.
For medium- and heavy-duty trucks assembled in the U.S., an offset of 3.75% is possible, like the offset set out for passenger vehicles and light trucks. Heavy truck engine manufacturers are also eligible for the offset. This offset will remain at this level until 2030.
These tariffs will apply to used and remanufactured trucks and buses if they were manufactured in the last 25 years. Any Japanese or European truck parts or heavy-duty engine parts will be subject to the 15% all-inclusive rate rather than the 25% rate.