The Month in International Trade – September 2025

Top Trade Developments

• BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists
• CBP Issues Withhold Release Order on Giant Manufacturing Co. Ltd.
• The EU and UK Act to Implement the Iran Sanctions “Snapback”
• CIT Vacates CBP Forced Labor Finding Against Aluminum Importer
• Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business
• Department of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR and Targeted Revisions to the U.S. Munitions List
• BIS Opens Inclusions Window for Section 232 Steel and Aluminum Tariffs
• BIS Announces Addition of 32 Entities to the Entity List, Including for Exports to Russia
• Modifications to Reciprocal Tariffs

Crowell Podcasts

Crowell Speaks

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Top Trade Developments

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.

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

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CBP Issues Withhold Release Order on Giant Manufacturing Co. Ltd.

OnSeptember 24^th, 2025 US 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.

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For more information, contact: Simeon Yerokun, Brett Everett

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The EU and UK Act to Implement the Iran Sanctions “Snapback”

The snapback of UN sanctions on Iran took effect on September 27, 2025, after the E3 (France, Germany, UK) triggered the mechanism under UN Security Council Resolution 2231 and the Security Council failed to extend sanctions relief.

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For more information, contact: Erik Woodhouse, Sophie Davis, Tim Laderach

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CIT Vacates CBP Forced Labor Finding Against Aluminum Importer

On September 23, 2025, the U.S. Court of International Trade (CIT) issued an opinion vacating and remanding U.S. Customs and Border Protection’s forced labor Finding against Kingtom Aluminio S.R.L., a Dominican Republic-based aluminum extruder. The court found that CBP’s determination, which prohibited the entry of Kingtom’s aluminum extrusions under Section 307 of the Tariff Act of 1930, was arbitrary and capricious because it lacked a satisfactory explanation and did not provide a rational connection between the facts found and the agency’s decision. The public administrative record and Federal Register notice contained only conclusory statements and failed to cite specific evidence or describe the circumstances of the investigation, distinguishing this case from prior decisions where agencies provided at least a minimal factual basis.

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For more information, contact: John Brew, Simeon Yerokun, Sibilla Grenon, Pier Natta, Andrew Schlegel

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Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business

On August 28, France, Germany, and the UK (the E3) initiated a “snapback” process that will reimpose UN sanctions on Iran on September 27 unless the Security Council acts. On September 19, a resolution to extend sanctions relief failed to receive sufficient votes at the Security Council and was not adopted. If snapback occurs, previously imposed UN sanctions on Iran will be reinstated. This includes an arms embargo on Iran, a ban on supplying nuclear-related technologies and materials, and an asset freeze on designated individuals and entities.

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For more information, contact: Erik Woodhouse, Dj Wolff, Sophie Davis, Jeremy Iloulian, Andrew Schlegel, Ivy Xun

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Department of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR and Targeted Revisions to the U.S. Munitions List

On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR”) and updating the U.S. Munitions List (“USML”). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.

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For more information, contact: Scott Wise, Chandler Leonard, Andrew Schlegel

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BIS Opens Inclusions Window for Section 232 Steel and Aluminum Tariffs

The Bureau of Industry and Security (BIS) announced via Federal Register Notice the opening of the window to submit requests to include additional derivative products under the Section 232 steel and aluminum tariffs. The window opened on September 15, 2025 and is set to close on September 29, 2025, at 11:59 PM (EST). Requests are required to include information regarding the derivative product and tariff classification for any inclusion request and are to be submitted to the Defense Industrial Base Programs inbox at DIBPrograms@bis.doc.gov.

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For more information, contact: Daniel Cannistra, Valerie Ellis, Emily Devereaux

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BIS Announces Addition of 32 Entities to the Entity List, Including for Exports to Russia

On September 12, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a final rule that announced the addition of 32 new entities to the Entity List (see BIS final rule here). 23 entities were added under the destination of China, one under India, one under Iran, one under Singapore, one under Taiwan, three under Turkey, and two under the UAE. The newly added entities include Chinese chipmakers and biotechnology companies, Turkish firms that diverted U.S. origin goods on the Common High Priority List (CHPL) to Russia, and an UAE trading company that diverted non-EAR99 items to Iran and Russia.

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For more information, contact: Scott Wise, Jeremy Iloulian, Ivy Xun

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Modifications to Reciprocal Tariffs

On Friday, September 5th, 2025, President Trump announced via Executive Order a large number of modifications to the scope of the reciprocal tariffs, which were initially announced on April 2, 2025, under the International Emergency Economic Powers Act (IEEPA).The Executive Order released on September 5^th modified the scope of the tariffs by amending Annex II to cover additional products under exclusion, as well as remove some products from exclusion. The newly-added products that are excluded from reciprocal tariffs effective September 8^th, 2025, include certain critical minerals and pharmaceutical products that are currently under Section 232 investigation, as well as precious metals such as gold and silver. Products that have been removed from Annex II and are now subject to reciprocal tariffs effective September 8^th, 2025, include certain aluminum hydroxide, resin, and silicone products.

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For more information, contact: David Stepp, Sibilla Grenon, Emily Devereaux

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Crowell Podcasts

Global Trade Talks Podcast: Frustration on the Ground

Global Trade Talks co-hosts Nicole Simonian and Dj Wolff welcome Karen Gerwitz, President of the World Trade Center Denver, as she provides insight to our listeners on how companies are managing and operating in thisuncertain trade environment where they are often waiting for the next shoe to drop. Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives.

Listen: Crowell.com | PodBean | SoundCloud | Apple Podcasts

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Crowell Speaks

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

“Fraud, Fakes, and Foreign Threats: Identity Verification and Secure Comms in the Age of DPRK Remote Worker Schemes,” Armor Text Webinar (September 25, 2025). Speakers: Caroline Brown.

“North Korean Remote Workers: Cyber, Sanctions, and Other Legal Challenges,” Cyber Defense Summit 25, Washington DC (September 22, 2025). Speakers: Caroline Brown.

“False Claims Act and Customs Enforcement—What You Need to Know,” Crowell & Moring Webinar (September 18, 2025). Speakers: Jason Crawford, Brian Tully McLaughlin, Preston Pugh, Maria Vanikiotis, Riley Delfeld, Katherine Quinn, William Tucker

What To Do If Your Company Discovers A North Korean Worker In Its Ranks
September 23, 2025 – Cyberscoop
Related Professional: Caroline Brown

“Supply Chain Mapping in the Era of National Security: Strategies for Trade Compliance, Tariff Mitigation, and Human Rights Risk,” Crowell & Moring Webinar (September 18, 2025). Speakers: Juge Gregg, Monica Gorman, David Stepp, Pierfilippo Natta

Trump administration ponders adjusting scope of auto part, steel and China tariffs
September 18, 2025 – Supply Chain Drive
Related Professional: Alex Schaefer

“The Lawyers Guide to Preparing For Financial Services in the Age of Emerging Technologies,” 2025 Fintech Conference, New York City (September 9, 2025). Speaker: Anand Sithian