Trade Advisory Notices

On January 14, 2026, the White House issued a Section 232 Proclamation targeting vulnerabilities in the U.S. semiconductor supply chain. The action establishes a 25% tariff on select advanced high‑performance AI chips—including NVIDIA’s H200 and AMD’s MI325X—due to heavy reliance on foreign imports and related national security risks. The tariff includes exemptions for imports that directly support U.S. semiconductor manufacturing expansion. The administration also signaled that broader semiconductor‑related duties and a potential tariff‑offset incentive program may follow. The Section 232 findings highlight insufficient domestic production capacity for chips and key manufacturing equipment, creating strategic dependencies that affect defense, critical infrastructure, and AI innovation. Companies importing advanced computing chips should prepare for immediate cost impacts, evaluate country‑of‑origin exposure, revisit supply chain strategies, and assess whether current imports qualify for exemptions. With the possibility of additional tariffs on semiconductor components and downstream products, organizations are encouraged to conduct tariff exposure assessments, model cost scenarios, explore mitigation options, and monitor ongoing U.S. trade and export control developments.

On January 13, 2026, President Trump announced via Truth Social that any country conducting business with Iran will face a 25% tariff on trade with the U.S. However, no formal executive order or regulatory notice has been issued, leaving enforcement and scope unclear. Without official definitions or mechanisms, companies face significant compliance uncertainty and potential legal risk. Until formal guidance is published, businesses should maintain operations while preparing for rapid response strategies. Contact our Trade Consulting team for tailored exposure analysis and compliance planning.

U.S. Customs and Border Protection (CBP) will require all refund payments to be processed electronically through the Automated Clearing House (ACH) system, starting February 6, 2026. This transition, initiated to comply with federal electronic funds transfer standards, will discontinue nearly all paper Treasury checks in favor of secure, expedited electronic refunds. To support this change, CBP has enhanced the ACE Secure Data Portal and introduced automated tools for ACH refund authorization and importer application updates. Importers and designated third parties must enroll in ACH to avoid delays. Electronic payments will arrive within one to two business days, compared to three or more days for mailed checks. CBP will help stakeholders prepare for the new process through informational calls in January and February 2026. Description: Beginning February 6, 2026, U.S. Customs and Border Protection (CBP) will require all refunds to be issued electronically through the Automated Clearing House (ACH) system, eliminating nearly all paper Treasury checks except in limited waiver-based cases. This regulatory change, published on January 2, 2026, aligns CBP’s payment practices with federal electronic funds transfer requirements and is detailed in the Electronic Refunds Interim Final Rule. To facilitate compliance, CBP has enhanced the ACE Secure Data Portal, including the deployment of automated ACH Refund Authorization tools and updates to the importer account application process. Importers and designated third parties must ensure ACH enrollment in ACE to avoid refund delays. The transition offers faster, safer, and more cost-effective refund processing, with payments typically deposited within one to two business days. CBP will support the trade community through informational calls in January and February 2026, as announced via the Cargo Systems Messaging Service (CSMS).

The United States Trade Representative (USTR) and the Department of Commerce have implemented tariff modifications under the U.S.–Switzerland–Liechtenstein Framework Agreement. These changes are outlined in Federal Register Notice FRN 2025 23316 and apply retroactively to goods entered for consumption or withdrawn from warehouse on or after November 14, 2025.

Effective December 26, 2025, the Government of Canada is imposing 25 per cent tariffs on the full value of the steel derivative products listed below from all countries.

Mexico has approved a comprehensive tariff reform under code CD LXVI II 1P 082, amending the Tariff of the General Import and Export Tax Law (LIGIE/TIGIE). The reform enters into force on January 1, 2026, and raises MFN/BASE duties on a broad set of goods from countries without a free trade agreement (FTA) with Mexico.

Tariffs imposed on China, Canada and Mexico, learn more about the tariffs and the retaliation effect here.

As the U.S. government approaches a potential shutdown beginning October 1, we want to provide clarity and reassurance regarding the continuity of import and export operations. Based on historical precedent and current agency designations, most trade-related government functions will remain operational.