U.S. Trade Policy and Tariff Actions
President Trump Implements Modified Scope of Section 338 Tariffs: On 23 October, President Trump modified the scope of Canadian products subject to 50% Section 338 tariffs, effective 30 October. The modification removed the following codes from the Section 338 scope, and imported goods of these codes are no longer subject to Section 338 tariffs:
- 8418.69.01- Refrigerating or freezing equipment nesoi
- 8419.89.95- Industrial machinery, plant, or equipment for the treatment of materials, by process involving a change in temperature, nesoi
- 8422.30.91- Machinery for filling, closing, sealing, capsuling or labeling bottles, cans, boxes, or other containers; machinery for aerating beverages; nesoi
- 8422.40.91- Packing or wrapping machinery, nesoi
The following tariff codes remain in scope and are subject to Section 338 50% tariffs:
- 8419.89.95 - Industrial machinery, plant, or equipment for the treatment of materials, by process involving a change in temperature, nesoi
- 8421.99.01 - Parts for filtering or purifying machinery or apparatus for liquids or gases
- 8422.90.91 – Parts of packing or wrapping machinery, nesoi
- 8438.40 – Brewery machinery, nesoi
Updated CSMS guidance has been published. PMMI members should review the updated list of products and relevant machinery tariff codes subject to the 50% Section 338 tariffs for any newly affected products.
- Presidential Proclamation issued regarding Section 232 robotics and industrial machinery investigation: On 28 October, President Trump issued a Proclamation and corresponding Fact Sheet directing the Department of Commerce (DOC) and U.S. Trade Representative (USTR) to pursue trade negotiations to address national security concerns stemming from the pending Section 232 robotics and industrial machinery investigation initiated in September 2025. Most importantly, this means the Administrations has abstained from implementing additional tariffs at this time. The proclamation does not indicate the scope of countries which the Administration will negotiate with nor the scope of products which could be hit with alternative remedies (i.e., tariffs). As such, the Administration retains the ability to implement tariffs at a later date, and it is unclear if food processing and packaging machinery could be targeted.
