Week Ten in Trade – First 100 Days of the New Administration
Commerce Department Establishes Standard Policy for Questionnaire Extensions in AD/CVD Proceedings
The Department of Commerce issued a new policy to create uniform filing deadline extensions in antidumping duty and countervailing duty proceedings. Overall, the policy will decrease the amount of time received in extension requests for initial and supplemental questionnaires. The specific policy updates include the following:
Read also: Week Nine in Trade – First 100 Days of the New Administration
- Initial questionnaires in AD/CVD investigations and review – Commerce will permit a one-week extension per deadline and three more days if a second request is made.
- Supplemental questionnaires with more than 20 questions – An initial response due within 10 calendar days, with the potential for a one-week extension first and then three additional days if a second request is made.
- Government responses in CVD investigations and reviews – Extension requests for Section II of the initial questionnaire will be granted for 10 days and then second extension requests may be granted for five additional days.
- Government responses for supplemental questionnaires:
- Questionnaires with less than 20 questions – An initial 10-day deadline, followed by a one-week first extension and three-day second extension.
- Questionnaires with more than 20 questions – An initial 13-day deadline, followed by a one-week first extension and three-day second extension.
Office directors will be required to approve all first and second extension requests, and the Deputy Assistant Secretary for Operations must sign off on any additional extensions.
Tariffs Imposed on Automobiles and Auto Parts Imported into the U.S.
On March 26, 2025, President Trump issued a Proclamation (titled “Adjusting Imports of Automobiles and Automobile Parts Into The United States”) to impose 25% tariffs on automobiles, with a carve-out for the value of the U.S. content of USMCA-qualifying autos. These tariffs are set to take effect on April 3, 2025.
The tariffs are also set to include automobile parts, which will take effect on May 3, 2025. The Annex identifying the specific parts that will be covered has not yet been published, though the tariffs will not apply to knock-down kits or parts compilations.
The 25% will be in addition to all other tariffs and duties, and no drawback will be available. We reviewed these new tariffs in greater detail here.
Tariffs Authorized on Imports from Countries Sourcing Oil from Venezuela
On March 24, 2025, President Trump issued an Executive Order (the “EO”) (titled “Imposing Tariffs on Countries Importing Venezuelan Oil”) allowing for 25% tariffs on all goods imported into the United States from any country that imports Venezuelan oil, whether directly from Venezuela or indirectly through third parties. These tariffs follow President Trump’s increasing pressure on Venezuela, which included revoking Chevron’s General License allowing it to conduct petroleum transactions in Venezuela with state-owned Petróleos de Venezuela, S.A. (“PDVSA”).
While the EO provides the structure to impose 25% tariffs on goods from countries who import oil from Venezuela, it does not mandate the imposition of such tariffs, nor does it authorize such tariffs to go into effect immediately. We discussed this E.O. in greater detail here earlier in the week.
BIS Adds 80 Parties to Entity List to Target China and Iran
On March 25, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) added 80 entities to BIS’s Entity List, primarily for activities related to China’s military modernization efforts and development of advanced artificial intelligence (“AI”) systems. Other additions included entities supporting Iran’s unmanned aerial vehicle programs.
The Entity List additions were published in two separate Federal Register notices, and the full list of entities can be found here and here. The entities are mostly in China but also include parties from Iran, the United Arab Emirates, South Africa, Taiwan, and Pakistan. In its announcement, BIS stated the latest round of designations are intended to:
- Restrict the Chinese Communist Party’s (CCP) ability to acquire and develop high-performance and exascale computing capabilities, as well as quantum technologies, for military applications;
- Impede China’s development of its hypersonic weapons program;
- Prevent entities associated with the Test Flying Academy of South Africa (TFASA) from using U.S. items to train Chinese military forces;
- Disrupt Iran’s procurement of unmanned aerial vehicles (UAVs) and related defense items; and
- Impair the development of unsafeguarded nuclear activities and ballistic missile program.
BIS May Have Funding Cut for FY 2025
The Trump Administration appears to have cut BIS’s budget by roughly 10.5%, or $20 million, reducing it to $171 million for fiscal year 2025. According to several Congress members, the reduction comes among other cuts made by President Trump to funds designated as emergency appropriations as part of the recently passed stopgap continuing resolution.
Last week, in the opening address at the BIS 2025 Update Conference, Commerce Secretary Howard Lutnick pledged a “dramatic increase” in export enforcement and penalties for export violations. It is unclear what impact, if any, a potentially reduced budget would have on BIS’s enforcement and other capabilities. Several Congress members have asked whether BIS’s staff will be reduced.
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