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IEEPA tariff authority remains in legal limbo: Courts ruled that the president exceeded his authority under IEEPA in imposing tariffs tied to immigration, fentanyl, and trade imbalances, but an appellate stay remains in place, allowing the tariffs to continue while expedited appeals move forward.

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Section 232 scope continues to expand: The Department of Commerce added additional steel‑containing consumer products to Section 232 tariffs, with duties assessed based on steel content, signaling continued use of national security authorities to broaden tariff coverage.

U.S.–China deal framed as a temporary framework: U.S. and Chinese officials described recent talks as producing a framework agreement covering rare earths and semiconductors, with export licensing commitments and tariff levels outlined, pending final approval by both leaders.

Multiple tariff tools in play simultaneously: Ongoing litigation, expanding Section 232 actions, reciprocal tariffs, and negotiated deals underscore the administration’s layered approach to trade enforcement and negotiation.

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Latest on IEEPA Court Cases

On May 29, the U.S. Court of International Trade&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/TEFXCPN6oPuqr9oJFzfzhxtXuw?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">ruled</a>&nbsp;that President Trump exceeded his authority under the International Emergency Economic Powers Act (IEEPA) by imposing tariffs on imports from Canada, Mexico, and China, issuing a permanent injunction against their enforcement. The court found the tariffs were not sufficiently linked to the cited emergencies (immigration, fentanyl trafficking, and trade imbalances) and concluded that IEEPA does not authorize broad tariff-setting powers. In a separate but related case, the U.S. District Court for D.C.&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/3Az5CQWApQImEg3JuPhBhGWS4I?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">issued a preliminary injunction</a>&nbsp;blocking the collection of the IEEPA tariffs from certain plaintiffs, with the judge emphasizing that IEEPA does not allow the president to impose duties without clear congressional authorization. However, later that day, a federal appellate judge&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/eQjNCR68qRh8koRyFPiwh1zg3P?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">issued an administrative stay on the CIT’s ruling</a>.&nbsp;As such, the tariffs remain in effect at this time.&nbsp;The court recently decided to continue the stay, keeping the tariffs in place, and has expedited the proceedings given the case’s “exceptional importance.” It set deadlines for legal briefs in early June and scheduled oral arguments for July 31.&nbsp;

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Department of Commerce Adds Products to Section 232 Tariffs

The Department of Commerce (DOC) has announced that, effective June 23, additional steel derivative products will be subject to tariffs, with duties assessed based on the steel content of each product. These items include certain refrigerator-freezers, dryers, washing machines, dishwashers, cooking appliances, and welded wire racks.&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/gf3tCVOJxYC1Lm5zuJs6hEco3K?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">The revisions were published in the Federal Register</a>&nbsp;as a modification to Annex 1 of the Harmonized Tariff Schedule, following previous presidential directives to adjust steel and aluminum imports. While most tariff codes remain unchanged, the update specifically targets steel-containing consumer goods.

A Pending US-China Trade Deal

A spokesperson for China’s Ministry of Commerce&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/mb7qCW6WyZhvgZPNtmtyhopv12?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">affirmed President Trump’s claim</a>&nbsp;that a U.S.-China trade deal on rare earths and semiconductors was “done,” describing the recent talks in London as a framework building on previous negotiations in Geneva. The spokesperson confirmed some progress and noted that export licenses for rare earths would be granted based on reasonable demand, with compliant applications already approved. President Trump,&nbsp;&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/okXuCXDYz1F3yjqkT9u8hWJ_8o?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">presented the deal as finalized</a>&nbsp;pending his and President Xi’s approval, highlighting terms including 55% U.S. tariffs, 10% Chinese tariffs, rare earth supply commitments, and continued Chinese student access to U.S. universities. Commerce Secretary Howard Lutnick echoed that the agreement was&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/nXY3CYEVA2SPJmNjS3ClhxmuRq?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">essentially a “handshake for a framework,</a>" awaiting final sign-off by both leaders.

President Trump and Treasury Secretary Comments on Reciprocal Tariffs

President Trump said the administration&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/hDpQCZ6ZB3hyVADXcNFBhBc01g?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">will soon&nbsp;unilaterally release the specific tariff rates</a>&nbsp;for certain countries “over the next week or two,” emphasizing that this step is necessary and signaling that he isn't expecting to delay the July 8 deadline for implementing higher tariffs. Treasury Secretary Scott Bessent echoed this timeline to lawmakers&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/J1ghC1wVl2SKDxkLFmHDhVVJXx?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">during a House Ways and Means hearing</a>. The Trump Administration initially set the deadline after announcing a new tariff regime on April 2 targeting trade deficits, but postponed enforcement to allow time for negotiations. While only a&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/S6sRC2kGm3hAJWR0svIyh5UMox?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">framework agreement with the U.K.</a>&nbsp;has been announced so far, Commerce Secretary Howard Lutnick said multiple deals are forthcoming, possibly starting next week. Negotiations with the European Union have been the most challenging, and any deal with the EU is expected to be finalized last due to the complexity of working with its 27 member states.

Read the last alert from the MBS team&nbsp;<a href="https://url.us.m.mimecastprotect.com/s/32MLC31Yn4SVJoGWHjS5hQe7Nt?domain=rnn4sp8ab.cc.rs6.net" target="_blank" rel="noreferrer noopener">here</a>.

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Are you concerned about the impacts of the outlined trade issues?&nbsp;Please contact Sarah Helton, Michael Best Strategies’ Trade Practice Lead at&nbsp;<a href="mailto:sarah.helton@michaelbest.com" target="_blank" rel="noreferrer noopener">sarah.helton@michaelbest.com</a>&nbsp;for assistance.

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Trump Trade 2.0: IEEPA, Section 232, China Trade Deal, Reciprocals, Oh My!

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