Executive summary

This edition of Trade Talking Points provides updates on trade policy developments, including: United States (US) President Trump directing the US Department of Homeland Security (DHS) and Customs and Border Protection (CBP) to strengthen requirements for Importers of Record; the US adjusting tariffs on steel, aluminum and copper imports; the US Trade Representative (USTR) proposing additional tariffs on 60 economies in response to the Section 301 investigation into failure to take action against forced labor; the European Union (EU) announcing consultation on the "melted and poured" definition for steel imports; and China introducing legislation designed to enhance resilience in supply chains.

Latest US trade policy announcements

President Trump strengthens requirements for Importers of Record

On 3 June 2026, President Trump signed an Executive Order directing DHS and CBP to strengthen requirements for Importers of Record (IORs) within 180 days.

The proposed methods of strengthening requirements for IORs include:

• Increasing bonding requirements and requiring IORs to maintain a minimum level of tangible domestic assets, bonding or both at all times
• Subjecting foreign IORs to heightened requirements for formal entry
• Authorizing only US IORs to file for informal entry
• Imposing a "good standing" requirement on all IORs
• Increasing vetting procedures for all individuals and entities that are directly related to the importation of goods

Furthermore, the Executive Order directs:

• DHS and CBP to establish various disclosure and certification requirements designed to combat duty evasion and noncompliance with supply chain rules
• DHS and CBP to increase enforcement of existing customs laws, including by establishing a 50% minimum penalty floor, thereby limiting CBP's discretion to reduce assessed penalties on importers who violate customs laws
• DHS to enhance the seizure and disposal of non-compliant imports
• DHS to enhance transparency in customs, including by publishing annual transparency reports
• DHS to propose legislation to strengthen customs enforcement

USTR proposes additional tariffs in response to Section 301 investigation

On 2 June 2026, the USTR determined under Section 301 of the Trade Act of 1974 that the acts, policies and practices of 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor are unreasonable and burden or restrict US commerce.

As a result of the Section 301 investigation, the USTR has proposed an additional 10% duty rate on goods from economies that impose a forced labor import prohibition or have committed to impose and enforce such a prohibition through an Agreement on Reciprocal Trade, and economies that have imposed a partial regime with the effect of preventing the importation of certain forced labor goods.

For all other economies, the USTR has proposed a rate of 12.5%. Furthermore, the USTR has proposed a mechanism that would allow a certain volume of apparel and textile imports from certain economies to enter the US at a reduced Section 301 tariff rate.

The USTR will hold hearings on the proposed actions on 7 July 2026. Interested parties should submit requests to appear at the hearings by 22 June 2026 and provide written comments by 6 July 2026.

See EY Global Tax Alert, USTR issues Section 301 determinations on forced-labor investigations across 60 economies; additional duties proposed and comment period open, dated 3 June 2026.

US adjusts tariffs on steel, aluminum and copper imports

On 1 June, President Trump signed a proclamation adjusting tariffs on steel, aluminum and copper imports.

The proclamation expands the list of derivative products subject to the 15% tariff, reducing the tariff exposure from 25%. The products are defined as:

• Agricultural equipment, including combine harvesters and tractors
• Heating, ventilation and air conditioning (HVAC) systems
• Mobile industrial equipment and machinery, including bulldozers and forklifts

In addition, the proclamation modifies the requirements for an imported product to qualify as made "entirely" from American aluminum, steel or copper from 95% to 85%, allowing the goods to benefit from a 10% duty rate.

These revisions are effective for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on 8 June 2026, until 11:59 p.m. ET on 31 December 2027.

See EY Global Tax Alert, US issues proclamation further adjusting Section 232 tariff regimes for aluminum, steel and copper; expanded reduced rates and revised thresholds announced, dated 2 June 2026.

USTR announces outcome of Section 301 investigation on Brazil

On 1 June 2026, the USTR determined under Section 301 of the Trade Act of 1974 that certain of Brazil's acts, policies and practices relating to areas such as digital trade and electronic payment services, unfair preferential tariffs and intellectual property protection are unreasonable and burden or restrict US commerce.

The USTR will hold a hearing on the proposed action on 6 July 2026. Interested parties should submit requests to appear at the hearing by 22 June 2026 and provide written comments by 1 July 2026.

See EY Global Tax Alert, USTR issues Section 301 determination on Brazil, initiates Section 301 IP investigation into Vietnam; tariffs proposed and comment periods open, dated 2 June 2026.

USTR initiates Section 301 investigation on Vietnam

On 29 May 2026, the USTR initiated an investigation of Vietnam under Section 301 of the Trade Act of 1974.

The investigation will seek to determine whether Vietnam's alleged failure to resolve concerns regarding intellectual property (IP) protection and enforcement is unreasonable or discriminatory and burdens or restrict US commerce.

The announcement follows the USTR's identifying Vietnam as a Priority Foreign Country in the 2026 Special 301 Report on 30 April 2026.

The USTR has requested that interested parties provide written comments by 11:59 p.m. Eastern Daylight Time on 2 July 2026.

See EY Global Tax Alert, USTR issues Section 301 determination on Brazil, initiates Section 301 IP investigation into Vietnam; tariffs proposed and comment periods open, dated 2 June 2026.

Latest EU trade policy announcements

EU announces steel consultation to define "melted and poured"

On 4 June 2026, the European Union (EU) announced a consultation to determine the type of documentary evidence that importers of steel products into the EU will need to provide to demonstrate where the steel was originally melted and poured.

The consultation will run from 4 June 2026 until 11:59 p.m. CEST on 2 July 2026 and will seek input from steel producers, steel users, traders, importers, industry associations and other stakeholders.

Latest China trade policy announcements

China introduces new legislation to counter foreign extraterritorial jurisdiction

China's State Council has published (in Chinese) the "Regulations on Countering Improper Extraterritorial Jurisdiction by Foreign States." The regulation aims to target foreign

organizations and individuals that implement measures the Chinese government considers to be imposed through improper extraterritorial jurisdiction.

The measures introduced as a result of the legislation include:

• The Chinese government will have the authority to exercise jurisdiction over measures occurring outside of its borders if there are appropriate ties to China, a basis in Chinese law or international treaties or if actions are based on the principle of reciprocity.
• China's Ministry of Justice will lead an inter-agency group to assess and identify whether foreign measures are appropriately imposed against China. It will consider:
• Consistency with international law
• The strength of the connection between the foreign state and the regulated conduct
• Whether the measures harm China's sovereignty, security or development interests, or the rights of Chinese citizens and organizations

China introduces new legislation to safeguard supply chains

China's State Council has published (in Chinese) the "Regulations on Industrial and Supply Chain Security." The regulation aims to prevent security risks and enhance resilience in supply chains.

The measures introduced as a result of the legislation provide that the State Council will:

• Implement dynamic adjustments to minimize supply chain disruption in the production and circulation of raw materials, technologies, equipment and products in key areas
• Establish monitoring and early warning systems for security risks in supply chains in key sectors such as raw materials, technology, equipment and products, including assessing and monitoring their impact on economic and social stability and national security
• Organize physical reserves to support the functioning of critical supply chains
• Establish emergency measures in response to security risks to key supply chains; these measures will include the Chinese government's coordinating logistics within supply chains and releasing physical reserves