News & Analysis as of

Public Comment National Security Supply Chain

Torres Trade Law, PLLC

Semiconductor Tariff Exclusions & New Section 232 Investigations

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This article provides an overview of the most recent tariff updates affecting businesses operating within the semiconductor, pharmaceutical, and critical mineral industries. Below we outline recent tariff exclusions for...more

DLA Piper

Department of Commerce Announces Section 232 Pharmaceutical Investigation

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The Trump Administration issued a notice on Monday titled, “Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients,” which could serve...more

Holland & Knight LLP

Trump Administration Initiates Section 232 Investigation into Pharmaceuticals

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The U.S. Department of Commerce announced that it has initiated a Trade Expansion Act of 1962 Section 232 investigation to determine whether imports of pharmaceutical products and ingredients pose a national security risk to...more

White & Case LLP

Trump Administration Initiates Section 232 Investigations on Pharmaceuticals and Semiconductors

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On April 14, 2025, the US Department of Commerce Bureau of Industry and Security (BIS) announced the initiation of investigations into the effects on US national security of imports of pharmaceuticals and pharmaceutical...more

Alston & Bird

Commerce Seeks Comments on Section 232 Lumber Investigation

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The U.S. Department of Commerce has issued the notice of request for public comments on Section 232 investigation of lumber imports. This follows President Trump’s March 1, 2025 Executive Order 14223 instructing Commerce to...more

Blank Rome LLP

USTR Seeks Public Comment on Proposed Action in Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and...

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The Office of the United States Trade Representative (“USTR”) announced its proposed actions under Section 301 of the Trade Act of 1974 (“Section 301”), in connection with its Investigation of China's Targeting of the...more

Husch Blackwell LLP

CBP Proposes Changes to the De Minimis Entry Process

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U.S. Customs and Border Protection (CBP) issued a Notice of Proposed Rulemaking on January 13, 2025, regarding an update to the rules governing de minimis shipments. The public can make comments on the proposed rule until...more

Akerman LLP

Updated Advanced Computing and Semiconductor Manufacturing Export Controls Take Effect

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On October 17, 2023, the Commerce Department’s Bureau of Industry and Security (“BIS”) released two interim final rules (“IFRs”) that amended the Export Administration Regulations (“EAR”) to significantly expand export...more

BakerHostetler

Outbound Investment Restrictions Will Impact Investments in China

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On August 9, 2023, the President issued a widely anticipated executive order ("EO") establishing the framework for a U.S. outbound investment program to address threats to U.S. national security created by certain...more

A&O Shearman

Biden Administration Moves to Restrict Outbound Investment to China

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On August 9, 2023, the Biden Administration issued a long-awaited Executive Order (the EO) that is intended to address the potential national security threats posed by outbound investment from the United States to certain...more

Fenwick & West LLP

UPDATE: Secure Software Development Attestation: A(nother) Government Requirement

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As follow-on guidance to Office of Management and Budget’s (OMB) September 14, 2022 memo and the associated Executive Order on Improving the Nation’s Cybersecurity from May 2021, the Cybersecurity and Infrastructure Security...more

Akin Gump Strauss Hauer & Feld LLP

Section 232 National Security Investigation on NdFeB Permanent Magnets Initiated by Commerce

Key Points - The Department of Commerce initiated a Section 232 national security investigation into NdFeB permanent magnets, which are used in fighter aircraft, missile guidance systems, electric vehicles, wind...more

Wiley Rein LLP

DOD Calls for Public Comments on Strategic and Critical Materials Supply Chains

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Critical minerals are the raw materials that form the basis of everything essential to today’s economy and national security, including steel, semiconductors, supercomputers, batteries, emerging technologies, F-35 jets, and...more

Goodwin

Commerce Department Moves to Protect the Supply Chain for Information and Communications Technology and Services

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On January 19, 2021, the U.S. Department of Commerce published an interim final rule (the “ICTS Rule”) under former President Trump’s Information and Communications Technology and Services Executive Order issued in May 2019....more

Akin Gump Strauss Hauer & Feld LLP

FERC Seeks Comments on Risks to Bulk Electric System from Equipment and Services from Entities Identified as Risks to National...

On September 17, 2020, the Federal Energy Regulatory Commission (FERC or the “Commission”) issued a Notice of Inquiry (NOI) seeking comments on “potential risks to the bulk electric system posed by using equipment and...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Department Extends Export Controls over Foreign-Made Items in Huawei’s Contract Manufacturing Supply Chain

- The U.S. Department of Commerce has published a highly complex and novel interim final rule extending the controls of the Export Administration Regulations (EAR) over foreign-made items in Huawei’s contract manufacturing...more

Akin Gump Strauss Hauer & Feld LLP

Commerce Issues Proposed Rule Implementing “Supply Chain Executive Order”

Key Points - On November 26, 2019, the U.S. Department of Commerce (“Commerce”) issued a proposed rule to implement Executive Order 13873 of May 15, 2019, on “Securing the Information and Communications Technology and...more

A&O Shearman

US Government Actions Greatly Increase Oversight of US Supply Chains

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The U.S. government undertook several recent actions that will greatly increase its oversight of U.S. supply chains in a number of key business sectors, including technology, telecommunications, digital and data services and...more

Stinson - Government Contracting Matters

Managing Your Supply Chain Just Got Trickier: Interim FAR Rule Prohibiting Contracting for Telecommunications and Video...

Continuing threats to the supply chain pose increasing risks to our national security. The new interim Federal Acquisition Regulation (FAR) rule published on August 13, 2019, seeks to address certain of these threats by...more

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