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Tariffs, Customs, and Import Compliance

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  • Strategic Advisors on Tariffs and Customs Compliance

    Wilson Sonsini's Tariffs, Customs, and Import Compliance practice provides strategic guidance to companies across industries, ranging from multinational corporations to emerging enterprises. We help clients navigate the complexities of international trade laws and regulations, offering counsel on U.S. Customs compliance, Harmonized Tariff Schedule classification, customs valuation, country of origin determinations, and the development of effective import compliance strategies and policies.

  • A Team with Diverse Experience and Perspectives

    Our international trade team brings decades of collective experience across law firms and in-house compliance departments. It includes attorneys with Court of International Trade experience and licensed customs broker expertise, as well as recognized industry leaders in trade compliance. Our attorneys leverage their unique insights to offer business-oriented solutions to complex international trade and tariff matters.

Practice Summary

Wilson Sonsini’s Tariffs, Customs, and Import Compliance practice assists clients in navigating complex and evolving international trade laws and regulations, managing customs compliance obligations, minimizing international trade risks, and optimizing tariff mitigation strategies. Amidst a background of increasingly turbulent tariff and trade policies, we can provide sound counsel and advice to businesses regarding a wide array of tariff, customs, and import matters.

Our attorneys work with clients to evaluate, design, and implement effective trade compliance policies; assess supply chains and international operations for potential tariff and trade compliance impacts; advise on tariff classification, country of origin, marking/labeling, and duty preference program eligibility; and assist with preparing responses to Customs and Border Protection inquiries and enforcement actions.

Our Team

Our attorneys are seasoned compliance professionals, including Chambers-ranked international trade lawyers, former in-house professionals, and experienced regulatory advisors. Our team’s broad expertise includes experience at the U.S. Court of International Trade and licensed customs broker credentials, resulting in a deep understanding of the legal and operational complexities of trade compliance.

Wilson Sonsini’s international trade attorneys include highly qualified import, export, and sanctions professionals with a transatlantic presence, ensuring comprehensive coverage for the full spectrum of international trade compliance needs across the U.S. and UK.

Our Experience

Wilson Sonsini’s Tariffs, Customs, and Import Compliance practice is uniquely positioned to help clients navigate the intricate and ever-evolving landscape of international trade laws and regulations. Our team combines legal and industry expertise with strong relationships across U.S. regulatory agencies, ensuring that our clients receive strategic, informed, and practical guidance in all aspects of international trade compliance. We guide clients on matters such as compliance with U.S. Customs regulations, Harmonized Tariff Schedule classification, customs valuation, country of origin determination, and development of import compliance strategies and policies.

Our team’s extensive experience allows us to provide practical, business-oriented solutions to address the unique compliance challenges of companies across industries. Our comprehensive understanding of regulations, the customs ruling process, and government guidance allows us to tailor advice to the needs of each client. We help clients—from start-ups launching import compliance programs to Fortune 100 companies evaluating multibillion-dollar supply chains—navigate regulatory risks, optimize tariff mitigation strategies, and ensure operational efficiency while maintaining their international trade compliance posture.

Our strategic, results-driven approach enables clients to proactively manage trade compliance risks while unlocking opportunities for cost savings and operational efficiencies. We have successfully assisted clients with a variety of trade compliance matters, including:

  • Advising clients on free trade agreements and duty preference program (e.g., USMCA, CAA, GSP) qualifications to limit tariff impacts;
  • Responding to customs inquiries and enforcement actions;
  • Drafting customs protests to challenge the classification and duty assessment for electronics, infrastructure, and surveillance industry companies;
  • Evaluating tariff impacts for international manufacturing, sourcing, and assembly proposals for electronics, semiconductor, and automotive industry companies;
  • Assisting clients with the assessment, development, and implementation of import compliance programs tailored to individual businesses, enhancing the ability to integrate disparate business teams and branches under unified policies and procedures;
  • Submitting customs classification requests on behalf of clients to obtain favorable binding rulings on HTS classification of input, products, components, and accessories;
  • Conducting country of origin determination analyses for assessment of free trade agreement qualification, compliance with Trade Agreements Act provisions for U.S. government sourcing, and marking requirements;
  • Evaluating a food and beverage distributor’s duty drawback strategy for compliance with applicable customs rules and regulations;
  • Assessing compliance with country of origin marking requirements for a consumer products company;
  • Reviewing clients’ customs brokerage and third-party logistics provider legal agreements; and
  • Advising on customs bond matters for clients navigating disputes with CBP regarding duty payment amounts.
Overview

Practice Summary

Wilson Sonsini’s Tariffs, Customs, and Import Compliance practice assists clients in navigating complex and evolving international trade laws and regulations, managing customs compliance obligations, minimizing international trade risks, and optimizing tariff mitigation strategies. Amidst a background of increasingly turbulent tariff and trade policies, we can provide sound counsel and advice to businesses regarding a wide array of tariff, customs, and import matters.

Our attorneys work with clients to evaluate, design, and implement effective trade compliance policies; assess supply chains and international operations for potential tariff and trade compliance impacts; advise on tariff classification, country of origin, marking/labeling, and duty preference program eligibility; and assist with preparing responses to Customs and Border Protection inquiries and enforcement actions.

Our Team

Our attorneys are seasoned compliance professionals, including Chambers-ranked international trade lawyers, former in-house professionals, and experienced regulatory advisors. Our team’s broad expertise includes experience at the U.S. Court of International Trade and licensed customs broker credentials, resulting in a deep understanding of the legal and operational complexities of trade compliance.

Wilson Sonsini’s international trade attorneys include highly qualified import, export, and sanctions professionals with a transatlantic presence, ensuring comprehensive coverage for the full spectrum of international trade compliance needs across the U.S. and UK.

Our Experience

Wilson Sonsini’s Tariffs, Customs, and Import Compliance practice is uniquely positioned to help clients navigate the intricate and ever-evolving landscape of international trade laws and regulations. Our team combines legal and industry expertise with strong relationships across U.S. regulatory agencies, ensuring that our clients receive strategic, informed, and practical guidance in all aspects of international trade compliance. We guide clients on matters such as compliance with U.S. Customs regulations, Harmonized Tariff Schedule classification, customs valuation, country of origin determination, and development of import compliance strategies and policies.

Our team’s extensive experience allows us to provide practical, business-oriented solutions to address the unique compliance challenges of companies across industries. Our comprehensive understanding of regulations, the customs ruling process, and government guidance allows us to tailor advice to the needs of each client. We help clients—from start-ups launching import compliance programs to Fortune 100 companies evaluating multibillion-dollar supply chains—navigate regulatory risks, optimize tariff mitigation strategies, and ensure operational efficiency while maintaining their international trade compliance posture.

Our strategic, results-driven approach enables clients to proactively manage trade compliance risks while unlocking opportunities for cost savings and operational efficiencies. We have successfully assisted clients with a variety of trade compliance matters, including:

  • Advising clients on free trade agreements and duty preference program (e.g., USMCA, CAA, GSP) qualifications to limit tariff impacts;
  • Responding to customs inquiries and enforcement actions;
  • Drafting customs protests to challenge the classification and duty assessment for electronics, infrastructure, and surveillance industry companies;
  • Evaluating tariff impacts for international manufacturing, sourcing, and assembly proposals for electronics, semiconductor, and automotive industry companies;
  • Assisting clients with the assessment, development, and implementation of import compliance programs tailored to individual businesses, enhancing the ability to integrate disparate business teams and branches under unified policies and procedures;
  • Submitting customs classification requests on behalf of clients to obtain favorable binding rulings on HTS classification of input, products, components, and accessories;
  • Conducting country of origin determination analyses for assessment of free trade agreement qualification, compliance with Trade Agreements Act provisions for U.S. government sourcing, and marking requirements;
  • Evaluating a food and beverage distributor’s duty drawback strategy for compliance with applicable customs rules and regulations;
  • Assessing compliance with country of origin marking requirements for a consumer products company;
  • Reviewing clients’ customs brokerage and third-party logistics provider legal agreements; and
  • Advising on customs bond matters for clients navigating disputes with CBP regarding duty payment amounts.
Alerts
Key U.S. Import Developments, June 2026
With new and novel tariffs yielding to court decisions rendering those tariffs unlawful (only to be replaced with newer tariffs—and more litigation about the newer tariffs), and with the Section 122 temporary import surcharge of 10 percent nearing expiration in a matter of weeks, businesses have faced extraordinary uncertainty in navigating trade policy.
Alerts
Double Dose of New Tariffs: President Prescribes New Pharmaceuticals and Metals Tariffs
On April 2, 2026, President Trump issued two presidential proclamations: a proclamation imposing Section 232 tariffs on certain branded pharmaceutical products and associated active pharmaceutical ingredients (APIs) (the Pharmaceuticals Proclamation), and a proclamation modifying the Section 232 steel, aluminum, and copper tariffs (the Metals Proclamation).
Alerts
U.S. Supreme Court Shakes Up Trump Tariff Tactics
On February 20, 2026, the U.S. Supreme Court issued its much-anticipated ruling in the Learning Resources case, concluding that the tariffs imposed by the Trump administration since February 2025 under the International Emergency Economic Powers Act (IEEPA) were unauthorized. The Court’s landmark 6-3 decision produced seven separate opinions with Chief Justice John Roberts and Justices Sonia Sotomayor, Elena Kagan, Neil Gorsuch, Amy Coney Barrett, and Ketanji Brown Jackson in the majority, holding that “the power to unilaterally impose tariffs of unlimited amount, duration, and scope” required “clear congressional authorization.” This decision affirmed earlier Federal Circuit and Court of International Trade (CIT) rulings rejecting the President’s authority to impose both the “fentanyl-related” (or “trafficking”) tariffs applied to products of China, Canada, and Mexico and the “reciprocal” tariffs applied to products of U.S. trading partners since “Liberation Day” back in April 2025. Notably, the Court’s opinion did not address the availability of or timing for any refunds owed to importers who have already paid the fentanyl-related and reciprocal tariffs.
Alerts
A Mixed Bag of Chips: Significant New Import and Export Changes for Advanced Semiconductors
The U.S. Department of Commerce issued a rule newly permitting certain advanced, H200/MI325X-grade computing chips classified under Export Control Classification Number (ECCN) 3A090 to be eligible for export to China, subject to a case-by-case licensing policy instead of a policy of denial.
Alerts
Federal Circuit Affirms Tariff Illegality but Defers Action to Remove Tariffs Pending Appeal
On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (the Court of Appeals) affirmed in a 7-4 ruling that although the International Emergency Economic Powers Act (IEEPA) could give President Trump the authority in some cases to impose tariffs, it did not give the administration the authority to impose the reciprocal and fentanyl-related tariffs that have been in place since earlier this year. In a separate Order, the Court of Appeals withheld issuance of its mandate to allow for further appeal to the U.S. Supreme Court, which the administration has already petitioned to take the case, requested to expedite, and received the acquiescence of the private plaintiffs and the state plaintiffs to do so. A ruling on the petition for certiorari is expected soon. Thus, importers will continue to be required to pay these tariffs until the Supreme Court directs otherwise.
Alerts
Deal or No Deal: The Return of the Reciprocal Tariffs
More than four months after the initial introduction of the “Liberation Day” tariffs in early April 2025, which lasted only a day before being rolled back in favor of a 10 percent baseline tariff, the reciprocal tariffs returned on August 7, 2025, with revised country-specific tariff rates. These new tariffs, which continue to exempt various items that have been carved out from these reciprocal levies, also reflect the terms of trade deals reached with U.S. trading partners throughout the summer. Meanwhile, new “secondary” tariffs on goods from countries purchasing crude oil from Russia and a new Section 301 tariff on Brazil have already been imposed, and increasingly specific comments regarding current Section 232 reviews on pharmaceuticals, semiconductors, and chips indicate that additional tariffs on those products are imminently forthcoming. We explore each of these topics in further detail below.
View All
Insights
Alerts
Key U.S. Import Developments, June 2026
With new and novel tariffs yielding to court decisions rendering those tariffs unlawful (only to be replaced with newer tariffs—and more litigation about the newer tariffs), and with the Section 122 temporary import surcharge of 10 percent nearing expiration in a matter of weeks, businesses have faced extraordinary uncertainty in navigating trade policy.
Alerts
Double Dose of New Tariffs: President Prescribes New Pharmaceuticals and Metals Tariffs
On April 2, 2026, President Trump issued two presidential proclamations: a proclamation imposing Section 232 tariffs on certain branded pharmaceutical products and associated active pharmaceutical ingredients (APIs) (the Pharmaceuticals Proclamation), and a proclamation modifying the Section 232 steel, aluminum, and copper tariffs (the Metals Proclamation).
Alerts
U.S. Supreme Court Shakes Up Trump Tariff Tactics
On February 20, 2026, the U.S. Supreme Court issued its much-anticipated ruling in the Learning Resources case, concluding that the tariffs imposed by the Trump administration since February 2025 under the International Emergency Economic Powers Act (IEEPA) were unauthorized. The Court’s landmark 6-3 decision produced seven separate opinions with Chief Justice John Roberts and Justices Sonia Sotomayor, Elena Kagan, Neil Gorsuch, Amy Coney Barrett, and Ketanji Brown Jackson in the majority, holding that “the power to unilaterally impose tariffs of unlimited amount, duration, and scope” required “clear congressional authorization.” This decision affirmed earlier Federal Circuit and Court of International Trade (CIT) rulings rejecting the President’s authority to impose both the “fentanyl-related” (or “trafficking”) tariffs applied to products of China, Canada, and Mexico and the “reciprocal” tariffs applied to products of U.S. trading partners since “Liberation Day” back in April 2025. Notably, the Court’s opinion did not address the availability of or timing for any refunds owed to importers who have already paid the fentanyl-related and reciprocal tariffs.
Alerts
A Mixed Bag of Chips: Significant New Import and Export Changes for Advanced Semiconductors
The U.S. Department of Commerce issued a rule newly permitting certain advanced, H200/MI325X-grade computing chips classified under Export Control Classification Number (ECCN) 3A090 to be eligible for export to China, subject to a case-by-case licensing policy instead of a policy of denial.
Alerts
Federal Circuit Affirms Tariff Illegality but Defers Action to Remove Tariffs Pending Appeal
On August 29, 2025, the U.S. Court of Appeals for the Federal Circuit (the Court of Appeals) affirmed in a 7-4 ruling that although the International Emergency Economic Powers Act (IEEPA) could give President Trump the authority in some cases to impose tariffs, it did not give the administration the authority to impose the reciprocal and fentanyl-related tariffs that have been in place since earlier this year. In a separate Order, the Court of Appeals withheld issuance of its mandate to allow for further appeal to the U.S. Supreme Court, which the administration has already petitioned to take the case, requested to expedite, and received the acquiescence of the private plaintiffs and the state plaintiffs to do so. A ruling on the petition for certiorari is expected soon. Thus, importers will continue to be required to pay these tariffs until the Supreme Court directs otherwise.
Alerts
Deal or No Deal: The Return of the Reciprocal Tariffs
More than four months after the initial introduction of the “Liberation Day” tariffs in early April 2025, which lasted only a day before being rolled back in favor of a 10 percent baseline tariff, the reciprocal tariffs returned on August 7, 2025, with revised country-specific tariff rates. These new tariffs, which continue to exempt various items that have been carved out from these reciprocal levies, also reflect the terms of trade deals reached with U.S. trading partners throughout the summer. Meanwhile, new “secondary” tariffs on goods from countries purchasing crude oil from Russia and a new Section 301 tariff on Brazil have already been imposed, and increasingly specific comments regarding current Section 232 reviews on pharmaceuticals, semiconductors, and chips indicate that additional tariffs on those products are imminently forthcoming. We explore each of these topics in further detail below.
View All
Affiliated Programs
European Forum on Global Economic Sanctions
As sanctions regimes continue to evolve in scope, speed, and enforcement, compliance and legal leaders face increasing pressure to anticipate risk and respond with precision. This year’s European Forum on Global Economic Sanctions delivers timely regulatory insights, real-world enforcement perspectives, and forward-looking strategies from senior government officials, regulators, and industry leaders. Through industry-led discussions and high-value peer exchange, attendees will gain practical tools to strengthen compliance frameworks, manage exposure, and stay ahead of emerging global risks.
Events
Affiliated Programs
European Forum on Global Economic Sanctions
As sanctions regimes continue to evolve in scope, speed, and enforcement, compliance and legal leaders face increasing pressure to anticipate risk and respond with precision. This year’s European Forum on Global Economic Sanctions delivers timely regulatory insights, real-world enforcement perspectives, and forward-looking strategies from senior government officials, regulators, and industry leaders. Through industry-led discussions and high-value peer exchange, attendees will gain practical tools to strengthen compliance frameworks, manage exposure, and stay ahead of emerging global risks.
Josephine Aiello LeBeau
Partner
Washington, D.C.
Josephine focuses on matters related to compliance and enforcement of U.S. export control and sanctions.
  • National Security and Trade
View Profile
Jahna Hartwig
Partner
Washington, D.C.
Jahna Hartwig is a partner at Wilson Sonsini Goodrich & Rosati, where she advises domestic and foreign companies on compliance with international trade laws.
  • Regulatory
View Profile
Anne E. Seymour
Of Counsel
Washington, D.C.
Anne Seymour is Of Counsel in Wilson Sonsini Goodrich & Rosati's Washington, D.C., office, where she focuses on issues related to compliance and enforcement of U.S. export control regulations and economic sanctions and U.S. import regulations.
  • National Security and Trade
View Profile
Bryan Poellot
Associate
Washington, D.C.
Bryan Poellot is an associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati where he specializes in national security, international trade, and foreign investment law. He advises clients on matters pertaining to the Committee on Foreign Investment in the United States (CFIUS), export controls promulgated by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), economic sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), tariff policies directed by the Office of the U.S. Trade Representative (USTR), and import rules and regulations under the purview of U.S. Customs and Border Protection (CBP).
  • National Security and Trade
View Profile
Jocelyn Chow
Partner
Hong Kong
Jocelyn Chow is a regulatory and compliance partner in the Hong Kong office of Wilson Sonsini Goodrich & Rosati. With a focus on antitrust, national security, and international trade matters, Jocelyn advises multinational corporations on all aspects of antitrust law, global economic and trade sanctions, export controls, import controls, rules of origin, and foreign investment controls. She works with companies operating across numerous industrial sectors, including defense, bioscience, advanced engineering and technology, aviation, telecommunications and broadcasting, and financial services.
  • Regulatory
View Profile
People
Josephine Aiello LeBeau
Partner
Washington, D.C.
Josephine focuses on matters related to compliance and enforcement of U.S. export control and sanctions.
  • National Security and Trade
View Profile
Jahna Hartwig
Partner
Washington, D.C.
Jahna Hartwig is a partner at Wilson Sonsini Goodrich & Rosati, where she advises domestic and foreign companies on compliance with international trade laws.
  • Regulatory
View Profile
Anne E. Seymour
Of Counsel
Washington, D.C.
Anne Seymour is Of Counsel in Wilson Sonsini Goodrich & Rosati's Washington, D.C., office, where she focuses on issues related to compliance and enforcement of U.S. export control regulations and economic sanctions and U.S. import regulations.
  • National Security and Trade
View Profile
Bryan Poellot
Associate
Washington, D.C.
Bryan Poellot is an associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati where he specializes in national security, international trade, and foreign investment law. He advises clients on matters pertaining to the Committee on Foreign Investment in the United States (CFIUS), export controls promulgated by the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), economic sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), tariff policies directed by the Office of the U.S. Trade Representative (USTR), and import rules and regulations under the purview of U.S. Customs and Border Protection (CBP).
  • National Security and Trade
View Profile
Jocelyn Chow
Partner
Hong Kong
Jocelyn Chow is a regulatory and compliance partner in the Hong Kong office of Wilson Sonsini Goodrich & Rosati. With a focus on antitrust, national security, and international trade matters, Jocelyn advises multinational corporations on all aspects of antitrust law, global economic and trade sanctions, export controls, import controls, rules of origin, and foreign investment controls. She works with companies operating across numerous industrial sectors, including defense, bioscience, advanced engineering and technology, aviation, telecommunications and broadcasting, and financial services.
  • Regulatory
View Profile
Related Practices
  • Committee on Foreign Investment in the United States (CFIUS)
  • Export Control and Sanctions
  • Foreign Ownership, Control, or Influence (FOCI)
  • Government Investigations
  • National Security and Trade
Recent Insights
Alerts
Key U.S. Import Developments, June 2026
With new and novel tariffs yielding to court decisions rendering those tariffs unlawful (only to be replaced with newer tariffs—and more litigation about the newer tariffs), and with the Section 122 temporary import surcharge of 10 percent nearing expiration in a matter of weeks, businesses have faced extraordinary uncertainty in navigating trade policy.
Learn More
Alerts
Double Dose of New Tariffs: President Prescribes New Pharmaceuticals and Metals Tariffs
On April 2, 2026, President Trump issued two presidential proclamations: a proclamation imposing Section 232 tariffs on certain branded pharmaceutical products and associated active pharmaceutical ingredients (APIs) (the Pharmaceuticals Proclamation), and a proclamation modifying the Section 232 steel, aluminum, and copper tariffs (the Metals Proclamation).
Learn More
View All
Recent Events
Affiliated Programs
European Forum on Global Economic Sanctions
As sanctions regimes continue to evolve in scope, speed, and enforcement, compliance and legal leaders face increasing pressure to anticipate risk and respond with precision. This year’s European Forum on Global Economic Sanctions delivers timely regulatory insights, real-world enforcement perspectives, and forward-looking strategies from senior government officials, regulators, and industry leaders. Through industry-led discussions and high-value peer exchange, attendees will gain practical tools to strengthen compliance frameworks, manage exposure, and stay ahead of emerging global risks.
Learn More
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