Kevin M. O'Brien


A hallmark of the Trump Administration trade policy is imposing tariffs — duties under Section 201 (safeguards), Section 232 (national security), and Section 301 (currently against China for intellectual property practices). For many companies, an integral component of supply chain management has included securing exclusions from these tariffs to avoid crushing duties that sideline downstream projects and value chains. But what happens if an exclusion vanishes without process or fair warning? The Administration has abruptly…