1. Home
  2. |Insights
  3. |The Month in International Trade – October 2025

The Month in International Trade – October 2025

Client Alert | 13 min read | 11.06.25

Top Trade Developments

Crowell Welcomes

Crowell Speaks

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Anand Sithian or Simeon Yerokun or any member of the International Trade Group.

 

Top Trade Developments

Supreme Court Oral Argument on Presidential Tariff Authority

Yesterday, the Supreme Court of the United States heard oral argument in the consolidated case challenging the use of the International Emergency Economic Powers Act (“IEEPA”) to justify sweeping import tariffs. At issue is whether IEEPA authorizes the President, upon declaring a national emergency, to impose tariffs and, if so, whether that delegation is constitutionally permissible.

Click here to continue reading the full version of this article.

For more information, contact: Valerie Ellis

CBP Faces Legal Challenge Over Exclusion of Camel Energy’s Battery Imports

Camel Energy, a Michigan-based importer of lead-acid batteries, has recently filed a complaint at the Court of International Trade (CIT) contesting U.S. Customs and Border Protection’s (CBP) two recent exclusions of its shipments. CBP excluded these entries due to “suspicion of being made with forced labor and subject to the UFLPA.” Camel Energy maintains that these exclusions were unlawful.

Click here to continue reading the full version of this article.

For more information, contact: Simeon Yerokun, Pier Natta, Emily Devereaux

U.S. and China Announce Temporary Suspension of Certain Tariffs and Export Controls Following Trump–Xi Meeting in South Korea

On October 30, 2025, President Trump and Chinese President Xi Jinping met in Busan, South Korea. This marks the first time the two leaders have engaged in face-to-face talks since 2019, during Trump’s first term.

Click here to continue reading the full version of this article.

For more information, contact: Jeff Snyder, Zhiwei Chen, Dmitry Bergoltsev, Ivy Xun

Key Takeaways From a Consequential Month of Russia-Related Sanctions

The United States, European Union, and United Kingdom have significantly escalated Russia-related sanctions in the past month, including the Trump administration’s first sanctions directly imposed on Russia. These coordinated actions — which particularly target the Russian energy sector — indicate that Russia sanctions remain on the geopolitical agenda and require multinational companies to remain vigilant in their compliance with those sanctions.

Click here to continue reading the full version of this alert.

For more information, contact: Caroline Brown, Carlton Greene, Dj Wolff, Erik Woodhouse, Sophie Davis, Jeremy Iloulian

EU Adopts 19th Sanctions Package Against Russia

On October 23, 2025, the EU adopted a further sanctions package, its “19th Round,” against Russia in connection with its ongoing war in Ukraine.

Click here to continue reading the full version of this article.

For more information, contact: Dj Wolff, Vassilis Akritidis, Sophie Davis, Oleksii Yuzko

UK Sanctions Lukoil, Rosneft in Major Russia Sanctions Expansion

On October 15, 2025, the UK announced a significant expansion of its Russia-related sanctions regime, designating Lukoil and Rosneft — Russia’s two largest oil companies — as asset freeze targets.

Click here to continue reading the full version of this article.

For more information, contact: Dj Wolff, Sophie Daivs, Andrew Schlegel

Understanding the EU’s International Procurement Instrument

The European Commission recently adopted its first-ever measures under the International Procurement Instrument Regulation (IPI), restricting Chinese access to the EU public procurement market for medical devices. In this client alert, we take a closer look at the IPI and the measures the Commission decided to adopt with regard to China, and we consider how the Commission is likely to use the IPI in the future.

Click here to continue reading the full version of this alert.

For more information, contact: Vassilis Akritidis, Jean-Baptiste Blancardi

China Expands Rare Earth Export Controls and Adds 14 Entities to the Unreliable Entity List

On Thursday, October 9, 2025, China issued a series of new export control measures and designations on China’s Unreliable Entity List (UEL).

Click here to continue reading the full version of this article.

For more information, contact: Jeff Snyder, Zhiwei Chen, Dmitry Bergoltsev, Ivy Xun

BIS Adds 26 Entities, Mostly in China, to the Entity List for Supplying Iran With Drone Parts and U.S.-Origin Electronic Items

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a Final Rule on October 9, 2025, that will add 26 entities and three addresses to the Entity List for a total of 29 new entries (effective immediately). BIS’ Entity Review Committee (ERC) — composed mainly of the Departments of Commerce, State, Defense, Energy, and Treasury — targeted these entities for their alleged role in illegally supplying Iran with unmanned aircraft systems (UAS) parts and components, electronic and chemical manufacturing items (including of U.S. origin), as well as links to an illicit procurement network. 

Click here to continue reading the full version of this article.

For more information, contact: Scott Wise, Jeremy Iloulian, Chandler Leonard, Nate Young

Department of Commerce Restores Firearms Licensing Policy of First Trump Administration, Rescinds Biden Restrictions

On September 30, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule rescinding an interim final rule (IFR) introduced by the Biden administration. This IFR had imposed new export licensing requirements on civilian firearms and related ammunition and components. press release, BIS stated that the previous administration’s actions are “onerous.” The IFR had also been a target of numerous complaints during the public comment period from U.S. gun manufacturers and distributors. The final rule essentially restores the controls that applied to most firearms under the first Trump administration.

Click here to continue reading the full version of this article.

For more information, contact: Chandler Leonard, Nate Young

Breaking Down the European Commission’s New Steel Import Tariffs and Quotas Proposal

On October 7, 2025, the European Commission published a Proposal for a Regulation that imposes further trade restrictions on imports of steel products from non-EU countries. This Proposal is part of the implementation of the Commission’s Steel and Metals Action Plan unveiled in March 2025 and aims to address the concerns of the EU steel manufacturing industry as the existing EU steel safeguards expire in June 2026.

Click here to continue reading the full version of this article.

For more information, contact: Vassilis Akritidis, Dan Cannistra, Jean-Baptiste Blancardi

BIS Issues “Affiliates Rule” To Dramatically Expand Applicability of Entity and Military End-User Lists

In issuing the Affiliates Rule with immediate effect, the U.S. Department of Commerce Bureau of Industry and Security (BIS) drastically expanded the number of entities subject to the BIS’ most restrictive export tools by applying the same trade prohibitions to any entities that are owned, directly or indirectly, 50 percent or more, by one or more entities listed on BIS’ Entity List, Military End-User (MEU) List, or certain SDN entities.

Click here to continue reading the full version of this article.

For more information, contact: Scott Wise, Jeremy Iloulian, Chandler Leonard, Jackie Schaeffer, Rachel Bogin, Dmitry Bergoltsev

CBP Issues Withhold Release Order on Giant Manufacturing Co. LTD

On September 24, 2025, U.S. Customs and Border Protection issued a Withhold Release Order under Section 307 of the Tariff Act of 1930 (19 U.S.C. §1307) against Giant Manufacturing Co LTD for any bicycles, parts, or accessories manufactured in Taiwan based on reasonable indication of forced labor.

Click here to continue reading the full version of this article.

For more information, contact: Simeon Yerokun, Brett Everett

Crowell Welcomes

Kathryn Barbella is an associate based in our New York office. She earned her J.D. from University of Virginia School of Law and graduated from University of Maryland, College Park with a B.A. in economics, government, and politics. During law school, Kathryn was a legal intern at the Southern Africa Litigation Centre, the symposium co-director for the John Bassett Moore Society of International Law, and a member of the editorial board for the Journal of Law & Politics.

Mirenda Gwin is an associate based in our New York office. She earned her J.D. from the University of California, Berkeley School of Law and graduated from the University of Virginia with a B.A. in history and media studies. During law school, Mirenda was a graduate fellow at the Columbia University Center for Public Research and Leadership and a  legal extern for the Department of Education, Office for Civil Rights. Mirenda was also the recent developments and commentary editor for the Berkeley Journal of Gender, Law, and Justice, and the Berkeley Law chapter co-director for the International Refugee Assistance Project.

Nate Young is an international trade analyst in our Washington, D.C. office. Nate joins Crowell from Guidehouse, a professional services firm headquartered in McLean, Virginia, where he was a senior consultant. Prior to that, he worked as a senior consultant at Janes Group U.S. He also spent two years as a senior systems engineer/team leader at the Office of the Undersecretary of Defense for Research and Engineering. From 2005 to 2019, Nate worked at the U.S. Department of State in a variety of roles, including senior defense analyst and training/outreach coordinator at the Directorate of Defense Trade Controls (DDTC). He was also a political officer at the U.S. Embassies in Moscow and Manila. Nate will be supporting the Export Controls and Sanctions sub-practices.

Crowell Speaks

“Risk Management: Key Components to Strengthen Your Security Posture and Reduce Risk for Digital Assets,” ACI’s Fourth Forum on Digital Assets: Compliance, Enforcement & Regulatory Oversight Conference, New York, NY (November 19, 2025). Speaker: Anand Sithian

"The Trump Administration and the Global Business Landscape," Toronto, ON (November 3, 2025). Speakers: Caroline Brown, Michael Guiffre, Ian Laird, Sadina Montani, Erik Woodhouse

What Shippers Need To Know About Potential Tariff Refunds
October 23, 2025 – Supply Chain Dive
Related Professional: Alex Schaefer

To Move Or Not To Move? Manufacturers Hesitant To Nearshore Before USMCA Review
October 16, 2025 – MedTech Dive
Related Professional: Dan Cannistra

What Tools Does Trump Have To Impose Tariffs?
October 16, 2025 – Supply Chain Dive
Related Professional: Alex Schaefer

Manufacturers Focus On Supply Chain Costs, Look To AI Amid Uncertainty
October 10, 2025 – Manufacturing Dive
Related Professional: Dan Cannistra

“The Cross-Industry Aftermath of the de minimis Changes: How Companies Are Transitioning E-Commerce Fulfillment to Maintain Efficiency and Cost Control,” ACI’s 14thAdvanced Forum on U.S. Customs Compliance and Enforcement, Arlington, VA (October 8, 2025). Speaker: John Brew

 

Contacts

Insights

Client Alert | 3 min read | 11.06.25

Executive Branch Focus on Federally Funded Inventions

In recent months the executive branch has indicated a willingness to assert control over intellectual property funded by federal research dollars in novel ways. This could potentially include leveraging its march-in rights under the Bayh-Dole Act....

View All Insights