The BR International Trade Report: October 2025

Recent Developments

U.S. Department of Commerce (“Commerce”) issues “Affiliates Rule” targeting unlisted subsidiaries of listed parties. Effective September 29, the new rule applies Entity List, Military End User List, and certain Specially Designated Nationals list restrictions to unlisted entities owned 50 percent or greater by such restricted parties. As part of its announcement, Commerce’s Bureau of Industry and Security (“BIS”) emphasized that “the [publicly available] Consolidated Screening List (“CSL”) will no longer comprise an exhaustive listing of foreign entities subject to Entity List license requirements” and recommends exporters consider the use of private sector screening resources. For additional information, please see Blank Rome’s October 3 client alert and register to attend Blank Rome’s October 23 live webinar.

U.S.-China trade relations again deteriorate after brief détente.

After reaching a temporary trade truce at a London summit in June, the United States and China again are clashing over trade issues, including the following: 

• China launches investigations into U.S. chips. On September 13, China’s Ministry of Commerce (“MOFCOM”) announced it was launching concurrentantidumping and anti-discrimination investigations into U.S. chips and chip policy, respectively. Following the announcements, a MOFCOM spokesperson remarked that U.S. trade policies “not only harm China’s development interests but also seriously undermine the stability of global semiconductor and industrial supply chains.”
• Chinese Ministry of Transport announces port fees for U.S. ships in retaliation for new U.S. rule. Following the conclusion of a Section 301 investigation by the Office of the U.S. Trade Representative (“USTR”) targeting Chinese shipbuilding, the Chinese Ministry of Transport released its own set of port fees on American vessels. The Chinese rule stipulates that, beginning October 14, American-owned, -operated, and/or -built ships will have to pay a fee of approximately $56 per net ton per voyage should they dock at a Chinese port. Notably, U.S. port fees on Chinese owners and operators, amounting to $50 per net ton, will take effect the same day.
• Beijing imposes additional export controls on critical minerals. On October 9, MOFCOM expanded export restrictions on the export of rare earths and permanent magnets. Under the new restrictions, which echo the “de minimis” and “see-through” rules under U.S. export controls, non-Chinese companies must seek approval from the Chinese government to export items that contain even small quantities of covered rare earth minerals.
• President Trump announces additional tariff and export control measures targeting China.
• In response to new Chinese export controls, on October 10, President Trump initially declared that, beginning November 1, the United States “will impose a Tariff of 100% on China, over and above any Tariff that they are currently paying. Also on November 1st, we will impose Export Controls on any and all critical software.”
• However, President Trump later remarked: “Don’t worry about China, it will all be fine! Highly respected President Xi just had a bad moment. He doesn’t want Depression for his country, and neither do I. The U.S.A. wants to help China, not hurt it!!!”
• U.S. Treasury Secretary Scott Bessent later struck a conciliatory tone, noting that U.S. and Chinese officials were in talks to ease tensions.
• Unclear whether President Trump and Chinese President Xi Jinping will meet in South Korea. In the face of increasing trade tensions, it is unclear whether President Trump will meet with his Chinese counterpart during his October trip to South Korea. At a White House event on October 10, President Trump told reporters: “I haven’t cancelled, but I don’t know that we’re going to have it . . . But I’m going to be there regardless, so I would assume we might have it.” Treasury Secretary Bessent later told reporters that the two leaders remained on track to meet.

Trump administration pursues Section 232 tariff investigations. 

• Robotics and industrial machinery: On September 2, Commerce launched an investigation into robotics and industrial machinery, according to a Federal Register notice published September 26. Interested parties may submit comments to BIS no later than October 17, 2025.
• Personal protective equipment, medical consumables, and medical equipment: Concurrent with its investigation into robotics and industrial machinery, BIS launched an investigation into imports of personal protective equipment, medical consumables, and medical equipment, including devices. Interested parties may submit comments to BIS no later than October 17, 2025.
• Trucks: On September 25, President Trump announced on Truth Social that he was imposing a 25 percent tariff, effective October 1, “on all ‘Heavy (Big!) Trucks’ made in other parts of the World.” President Trump later postponed the effective date until November 1, 2025.
• Pharmaceuticals: President Trump announced that, beginning October 1, the United States “will be imposing a 100% tariff on any branded or patented Pharmaceutical Product, unless a Company IS BUILDING their Pharmaceutical Manufacturing Plant in America. ‘IS BUILDING’ will be defined as, ‘breaking ground’ and/or ‘under construction.’” The White House appears to have paused efforts to impose the new tariffs to allow pharmaceutical companies additional time to negotiate agreements.
• Timber and lumber: On September 29, President Trump signed a presidential proclamation setting tariffs of 10 percent on softwood timber and lumber, and varying tariffs on upholstered wooded products and kitchen cabinets. The new duties took effect on Tuesday, October 14.

Trump administration paves the way for advancement of critical minerals road project in Alaska. In an October 8 executive decision, President Trump overturned the Biden-era blockage of the Ambler Road project, meant to connect the remote Ambler region—which possesses critical minerals such as cobalt, germanium, and gallium—to the rest of Alaska. The project, which is the subject of controversy due to its planned route, still faces other bureaucratic challenges. 

South Korea and the United States struggle to finalize terms of July trade deal. In late July, President Trump announced that Seoul and Washington had agreed to a trade deal in which, among other things, “South Korea will give to the United States $350 Billion Dollars for Investments owned and controlled by the United States, and selected by myself.” However, the terms of the July deal are somewhat unclear, as South Korea recently has indicated that its investment would take the form of loans and loan guarantees because it is not able to pay $350 billion in cash.

Federal Communications Commission denies applications of 15 Chinese “bad labs.” In September, the Federal Communications Commission’s (“FCC”) Office of Engineering and Technology (“OET”) withdrew its approval of 15 Chinese-controlled telecommunications testing laboratories. FCC Chairman Brendan Carr commended the OET’s action, remarking “foreign adversary governments should not own and control the labs that test the devices the FCC certifies as safe for the U.S. market. This is an important step in restoring trust in the Commission’s equipment authorization process, and combatting foreign adversary threats.” 

Mexico prepares tariff increase on Chinese autos. On September 10, Mexican President Claudia Sheinbaum announced a tariff increase from 20 percent to 50 percent on Asian autos, most likely targeted at China, whose auto manufacturers have a large market share in the country. China has accused Mexico of acting under U.S. pressure—possibly in an effort to lower U.S. tariffs on Mexican-origin products—while Mexico says the tariff increase will protect its domestic auto manufacturing industry. The tariff increase still must pass in Mexico’s Congress. 

U.S. Department of State revokes its finding that Colombia is a “cooperating country” with respect to drug trafficking. For the first time since 1997, the U.S. designated Colombia as “having failed to demonstrably during the previous 12 months to both adhere to their obligations under international counternarcotics agreements and to take the measures required by section 489(a)(1) of the [Foreign Assistance Act of 1961, as amended (“FAA”)].” As a result of the designation, the United States may impose additional sanctions against Columbia until such time that it is deemed to be acting in compliance. Colombia responded to the designation by halting its purchase of weapons from the United States. 

Global political developments: 

• Japan’s Komeito party withdraws from coalition with the Liberal Democratic Party (“LDP”) and refuses to back the confirmation of LDP leader Sanae Takaichi as Prime Minister. Komeito’s withdrawal marks the end of 26 years of cooperation between the two parties. If confirmed, Takaichi will become Tokyo’s first female Prime Minister.
• Sebastien Lecornu resigns and is reappointed as Prime Minister of France. On October 6, after only 26 days in office, French Prime Minister Sebastien Lecornu resigned from his role—making him the third French prime minister to resign in eleven months. President Macron quickly reappointed Lecornu to the position of Prime Minister, which Lecornu accepted “out of duty.” Prime Minister Lecornu has vowed to do “everything possible to provide France with a budget by the end of the year and to address the daily life issues of [France’s] citizens.”

For continuous, up-to-date information on the evolving administrative landscape, check out Blank Rome’s Trump Administration Resource Hub. Explore previous BR International Trade Reports here.