White House Seeks to Secure the Critical Mineral Supply Chain: On Jan. 14, President Donald Trump issued a proclamation directing the Secretary of Commerce and U.S. Trade Representative (USTR) to negotiate with trading partners to eliminate national security risks posed by importing processed critical minerals and their derivative products (PCMDPs). In doing so, the agency heads are tasked with encouraging the adoption of price floors to secure the critical mineral supply chain. The president previously issued an executive order (EO) in April 2025, which required the Secretary of Commerce to initiate a Section 232 investigation to determine whether the importation of critical minerals, rare earth elements, and derivative products undermines national security. President Trump concurred with the Commerce Department’s findings that “the United States is too reliant on foreign sources of PCMDPs, lacks access to a sufficiently secure and reliable supply chain to PCMDPs, is experiencing unsustainable price volatility with respect to critical mineral markets, and is suffering from weakened domestic manufacturing and production capacity of PCMDPs,” necessitating the initiation of negotiations to diversify the U.S. critical mineral supply chain. The proclamation also notes that the secretary of commerce recommended that tariffs be imposed “if satisfactory agreements are not reached in a timely manner.” The secretary of commerce and USTR are ordered to update the president on the status of negotiations within 180 days, at which time the president could impose tariffs on PCMDPs or take additional action as he deems necessary.
 
Trump Administration Imposes Some Tariffs on Chips amid Nvidia H200 Deal: On Jan. 14, President Trump issued a proclamation to impose a 25% tariff on certain advanced semiconductors. The Department of Commerce initiated a Section 232 investigation into semiconductors, semiconductor manufacturing equipment (SME) and their derivative products in April 2025. The president concurred with the department’s findings that the importation of chips poses a national security threat “when such importation does not contribute to the buildout of the United States technology supply chain.” As a result, a 25% tariff will be imposed on select chips, including the Nvidia H200 and Advanced Micro Devices (AMD) Inc. MI325X chip, effective Jan. 16. However, the determination provides several tariff exemptions for chips used in U.S. data centers, research and development, and public sector applications, among other activities enhancing domestic technological capabilities. Additionally, the president directed Commerce Secretary Howard Lutnick and USTR Jamieson Greer to negotiate with trading partners to secure the U.S. semiconductor supply chain. If corresponding agreements are not reached within 180 days, the president could increase tariffs or take additional action to protect national security.
 
Alongside the tariff determination, the Bureau of Industry and Security (BIS) issued a final rule to update its license review policies for the exportation of certain semiconductors to China, including Nvidia H200 and AMD MI325X chips. The new policy will require a case-by-case review, rather than a presumption of denial. Both the imposition of a limited tariff and the relaxed export license review process are core components of the chip deal that Nvidia reached with China in December 2025.
 
Greer Expresses Confidence in Alternative Tariff Authorities amid SCOTUS IEEPA Case: On Jan. 13, U.S. Trade Representative (USTR) Jamieson Greer expressed confidence in the administration’s ability to maintain its current tariff regime through alternate authorities, should the Supreme Court rule against its usage of the International Emergency Economic Powers Act (IEEPA) to impose reciprocal tariffs. During an interview with The Economist, he explained that, in the case of an unfavorable ruling, the goal would be “as much continuity as possible” in maintaining tariffs under alternative tariff authorities. Commerce Secretary Howard Lutnick and Treasury Secretary Scott Bessent have expressed similar views, but alternate tariff authorities, such as Section 232 of the Trade Expansion Act of 1962, do not authorize the president to impose broad, sweeping tariffs as he has attempted to do under IEEPA. Greer acknowledged IEEPA’s flexibility compared to “inherently more complicated” alternative authorities.
 
President Trump Threatens Tariffs on Iranian Trading Partners: On Jan. 12, President Trump released a social media post, stating, “Effective immediately, any Country doing business with the Islamic Republic of Iran will pay a Tariff of 25% on any and all business being done with the United States of America.” The threat follows two weeks of protests against Iranian Supreme Leader Ayatollah Ali Khamenei. Although official action is yet to be taken, the threat could jeopardize trade negotiations with key nations, such as China. According to the International Monetary Fund (IMF), China is Iran’s top trading partner, with bilateral trade totaling about $17.8 billion in 2024. Additionally, India, the United Arab Emirates (UAE) and Turkey maintain a trade relationship with Iran, and importers of significant volumes of Iranian oil are at further risk of new tariff exposure. Any future tariff targeting Iranian trading partners would most likely be levied under the International Emergency Economic Powers Act (IEEPA); however, due to the ongoing Supreme Court challenge to IEEPA-based tariffs, the administration is likely to wait to impose new duties until a ruling is issued. It also remains unclear whether these tariffs would “stack” on existing duties, including those imposed under Section 301 of the Trade Act of 1974 or Section 232 of the Trade Expansion Act of 1962.
 
House Passes AGOA and HELP Extension: On Jan. 12, the House passed legislation to extend the African Growth and Opportunity Act (AGOA) and Haiti Economic Lift Program (HELP) for three years. The AGOA extension bill (H.R.6500), sponsored by Rep. Jason Smith (R-MO), passed 340-54, while the HELP extension (H.R.6504), sponsored by Rep. Greg Murphy (R-NC), passed 345-45. Both bills provide a “clean” three-year extension, which reauthorizes the existing text with no modifications, and retroactively applies preferential treatment for covered goods to September 2025, when the programs lapsed. AGOA provides duty-free market access for thousands of goods to eligible sub-Saharan African countries, while HELP provides duty-free market access for textiles and apparel produced in Haiti. Despite broad congressional support, the Trump administration remains skeptical of the programs, resulting in a “clean” extension rather than improved language. The two bills now head to the Senate for consideration.
 
Rep. Van Duyne Introduces Bill to Maintain Universal Tariffs: On Jan. 8, Rep. Beth Van Duyne (R-TX) introduced the Fair Trade Act of 2026 (H.R.6991) to maintain baseline tariffs on all nations. The bill would impose a 10% tariff on nations with which the United States has a trade surplus and a 15% tariff on nations with which the United States has a trade deficit. The baseline tariffs would apply in addition to any existing duties and remain in effect unless the president determines that the tariff should be reduced for a certain product to enhance national security. If the Supreme Court invalidates IEEPA-based tariffs, President Trump may push Congress to pass H.R.6991 or similar legislation to maintain his tariff regime.