Trade Remedies

The base HTS code changes once a year and is well-litigated. Chapter 99 changes on the timeline of the next proclamation, stacks three authorities that don't recognize each other's relief, and rests partly on a statute under active constitutional challenge. Part 8 of an 8-part series on Chapter 99.

Section 301, Section 232, and IEEPA duties don't offset, replace, or defer to one another — they stack, and an exclusion from one layer does nothing for the other two. Part 5 of an 8-part series on Chapter 99.

Chapters 1–97 classify products. Chapter 99 classifies policy — and it's bolted onto the HTSUS with different rules, a different update cadence, and a different failure mode. Part 1 of an 8-part series on Chapter 99.

The ITC can order AD/CVD duties on a finding of threat alone, with no current injury. Here is what the ITC decides, what Commerce decides, and why importers keep confusing the two.

IEEPA tariffs skipped the investigations behind Section 301 and 232. The Supreme Court held in 2026 that IEEPA doesn't authorize tariffs. Part 4 of 8.

Trump's 2025 Section 232 reset ended country exemptions, raised steel and aluminum tariffs, expanded derivative coverage, and made metal-content and upstream-origin data operationally critical. Part 3 of an 8-part series on Chapter 99.

Section 301 was the first Chapter 99 overlay and remains the largest single driver of Chinese-origin duty liability. The trigger is a substantial-transformation origin test, not the shipping route — and most of the recoverable money sits in an opt-in exclusion layer nobody automatically applies. Part 2 of an 8-part series on Chapter 99.