2025 Trade Policy Calendar

2025 Trade Policy Calendar: Key Dates

Origin Advocacy Client Alert, JAN. 29, 2025

February 1, 2025	Threatened imposition of 25% tariffs on Mexico and Canada. Threatened imposition of additional tariffs on China (10%, 60%, and 100% rates floated). Threatened imposition of 100% tariffs on BRICS nations.
March 1, 2025	Deadline for USTR to submit its annual review of the U.S.’s participation in the WTO to Congress. The submission of this report in 2025 triggers a 90-day window (note: some days are not counted under the statute) for Congress to vote on a resolution disapproving the U.S.’s participation in the WTO. Deadline for submission to Congress of the U.S.’s national trade policy agenda for 2025, as required by 19 U.S.C. 2213(a).
March 17, 2025	Deadline for public comments on the Notice of Proposed Rulemaking “Entry of Low-Value Shipments” (Docket USCBP-2025-0002).
March 24, 2025	Deadline for public comments on the Notice of Proposed Rulemaking “Trade and National Security Actions for Low-Value Shipments” (Docket USCBP-2025-0003).
March 31, 2025	Expiration of the U.S.-EU agreement to replace Section 232 tariffs on European goods with tariff-rate quotas in exchange for the EU suspending its retaliatory tariffs. If the U.S. and EU do not reach a replacement agreement by this date, both Section 232 tariffs and retaliatory tariffs may go back into effect.
April 1, 2025	Deadline for the following reports to be delivered to the President, as required by the “America First Trade Policy” memorandum issued on January 20, 2025: From the Secretary of Commerce: (1) causes of the U.S.’s trade deficits in goods and recommendations to remedy such deficits, including a “supplemental global tariff;” (2) review of policies and regulations regarding AD/CVD laws, including compliance of foreign respondent; (3) an assessment of legislative proposals regarding PNTR with China; (4) the status of U.S. IP rights conferred upon Chinese nationals; (5) a full review of the U.S.’s “industrial and manufacturing base” with respect to initiating new Section 232 investigations; (6) the effectiveness of exclusions under the current Section 232 duties on steel and aluminum; (7) review of export control systems in order to “identify and eliminate loopholes,” especially with strategic goods and technology; (8) review of the ICTS rule on connected vehicles, and whether controls should be expanded to additional connected products; and (9) an assessment of unlawful migration and fentanyl flows from Canada, Mexico, and China, including “appropriate trade and national security measures to resolve that emergency.” From the Secretary of the Treasury: (1) recommendations for establishing an External Revenue Service (ERS); (2) reports on currency rate policies of U.S. trading partners (required by 19 U.S.C. 4421 and 22 U.S.C. 5305); (3) an assessment of the loss in tariff revenues and risks from importing counterfeit products and illicit drugs under the U.S.’s $800 de minimis exemption; (4) an investigation of whether any foreign country subjects U.S. persons to discriminatory or extraterritorial taxes; and (5) review of the Biden Administration’s outbound investment final rule (89 Fed. Reg. 90398). From the U.S. Trade Representative: (1) review of unfair trade practices by other countries and actions to remedy them under current legal authorities; (2) commencement of the public consultation process required in advance of the USMCA’s July 2026 review; (3) review of existing trade agreements and recommendations for revisions; (4) identification of countries with which the U.S. can negotiate bilateral or sector-specific agreements to obtain market access; (5) review of the impact of all trade agreements, including WTO commitments, on federal procurement; (6) review of China’s compliance with the “Phase One” deal reached on January 15, 2020; (7) review of USTR’s four-year review of Section 301 tariffs on China, including whether additional tariff modifications are needed “particularly with respect to industrial supply chains and circumvention through third countries;” (8) review of other Chinese practices that could merit a Section 301 investigation.
April 30, 2025	Deadline for the Director of OMB to deliver to the President a report assessing any “distorting impact” of foreign government subsidies or financial contributions on U.S. federal procurement, as required by the “America First Trade Policy” memorandum issued on January 20, 2025.
June 30, 2025	Due date of first 3 percent tax payment under Canada’s digital services tax (DST), with taxes retroactive to January 1, 2022.
July 1, 2025	Deadline for submission of the USITC’s second report on the economic impact and operation of USMCA’s automotive rules of origin (No. 332-600), as required by 19 U.S.C. 4532(g)(2).
October 4, 2025	Deadline for USTR to notice public consultations regarding the USMCA’s mandatory six-year review under Article 34.7. 19 U.S.C. 4611(b)(1).