The U.S.-China trade relationship reached its lowest point in decades earlier in 2025.

Following several rounds of escalating retaliatory tariffs, the U.S. imposed a 145% levy on imports from China, which responded in kind. And while the two countries have dialed back certain restrictive measures since summer highs, there remains a great deal of uncertainty in their relations.

For its part, the U.S. government is attempting to safeguard national security and reduce risks in supply chains, while reinvigorating domestic production. On the export side, the Department of Commerce’s Bureau of Industry and Security (BIS) has imposed export controls on critical and emerging technologies that have both civilian and military applications, such as the most advanced semiconductors. China, in turn, has responded by imposing export controls on certain critical minerals, and banning the use of those same semiconductors, thereby blocking out American companies from its market.

Export control restrictions and retaliation are just one part of the trade terrain. Under the Trump Administration, tariffs have played a central role in U.S. government efforts to enhance the competitiveness of domestic production capacity across a broad range of industry sectors. The President has cited multiple statutes as authority for imposing the tariffs, including section 338 of the Tariff Act of 1930, section 232 of the Trade Expansion Act of 1962, sections 201 and 301 of the Trade Act of 1974, and the International Emergency Economic Powers Act (IEEPA). 

Many U.S. manufacturers have petitioned the Department of Commerce’s International Trade Administration and International Trade Commission to investigate dumped or subsidized imports that are injuring or threatening to injure domestic industries. These cases, where successful, have resulted in the imposition of antidumping duty or countervailing duty orders that apply to imports from investigated countries.

Although the U.S. government has discretion to self-initiate these investigations, the vast majority of cases are brought by domestic producers, manufacturers, growers, industry associations or unions. Once imposed, the duties will remain in place for at least five years, and often much longer. Anti-evasion provisions under the Trade Facilitation and Trade Enforcement Act of 2015 offer continued relief against imports that are transshipped or otherwise attempt to circumvent the antidumping or countervailing duty orders.

Since March, 2025, BIS has initiated 12 investigations under section 232 of the Trade Expansion Act of 1962, examining the threat to national security posed by imports of a broad range of products, including critical minerals, copper, lumber, semiconductors and manufacturing equipment, pharmaceuticals and ingredients, medical devices and equipment, industrial machinery, trucks, commercial aircrafts and jet engines, unmanned aircraft systems and parts, polysilicon and its derivatives, wind turbines. These investigations result in the Commerce Department issuing recommendations to the President on how to address related threats to national security. Based on prior practice, the investigations have resulted in recommendations for imposition of global tariffs ranging between 25% and 50% for covered products, such as steel, aluminum and automotive parts.

In addition, BIS this year implemented a new methodology that enables domestic producers to request the inclusion of additional products to be covered by the national security tariffs. As with antidumping and countervailing duty investigations, domestic producers may request that the U.S. government undertake section 232 investigations.

There are also several lists of section 301 tariffs on products from China that cover hundreds of billions of dollars in imports. Various duties and tariffs may “stack,” resulting in a higher or aggregate tariff level that provides domestic producers with additional protection. Other tariffs, such as “reciprocal” levies under IEEPA, may stack with some tariff types but not others.

The U.S. and China have been engaged in escalating trade tensions since the first Trump Administration. Since then, the U.S. has taken a more assertive approach to managing its trade relationship with China, while facing retaliation both against sectors where the Chinese government has control over strategic supply chain nodes, and American companies operating in the Chinese market. These broader geoeconomic currents are likely to persist, given the great power competition that’s playing out over resources, influence, defense and economic spheres. 

The U.S.–China trade relationship will entail significant risk and tariff volatility for the foreseeable future. Companies seeking to navigate the resulting uncertainty can take a proactive posture to enhance the competitiveness of domestic production, including by using the range of trade relief tools that are available. Supply chain leaders must look at the full spectrum of options — onshoring, nearshoring and friend-shoring — in order to mitigate risk. 

Daniel Pickard is practice group leader, and Natan Tubman is an associate, in the International Trade & National Security practice group at Buchanan Ingersoll & Rooney.