Matthew J. Thomas, Keith B. Letourneau, Douglas J. Shoemaker, and Holli B. Packer ● President Donald Trump issued an Executive Order (“EO”) on April 2, 2025, titled Regulating Imports with a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits. This EO introduces significant changes to the tariff
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USTR Seeks Public Comment on Proposed Action in Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors
The Office of the United States Trade Representative announced its proposed actions under Section 301 of the Trade Act of 1974, in connection with its Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance on February 21, 2025.
The post USTR Seeks Public Comment on Proposed Action in Section 301 Investigation…
Cybersecurity in the Marine Transportation System: What You Need to Know About the Coast Guard’s Final Rule
Dana S. Merkel, Vanessa C. DiDomenico, and Holli B. Packer ● The U.S. Coast Guard (“USCG”) published a final rule on January 17, 2025, addressing Cybersecurity in the Marine Transportation System (the “Final Rule”), which seeks to minimize cybersecurity related transportation security incidents (“TSIs”) within the maritime transportation system (“MTS”) by establishing requirements to enhance the detection,…
Hurricanes and Their Cost on the Maritime Industry
Keith B. Letourneau ● Aside from the destruction that flows from it, how does a hurricane along the Gulf Coast affect the maritime industry that operates hundreds of terminals and moves thousands of ocean-going ships and inland tows along its waterways? With the approach of a hurricane, the U.S. Coast Guard Captain of the Port…
Risk Management Tools for Maritime Companies
COMPLIANCE AUDIT PROGRAM Blank Rome Maritime has developed a flexible, fixed-fee Compliance Audit Program to help maritime companies mitigate the escalating risks in the maritime regulatory environment. The program provides concrete, practical guidance tailored to your operations to strengthen your regulatory compliance systems and minimize the risk of your company becoming an enforcement statistic. To…
EPA Signs Final Vessel Incidental Discharge National Standards of Performance Rule
Jeanne M. Grasso and Holli B. Packer ● On September 20, 2024, the Environmental Protection Agency (“EPA”) signed a highly anticipated final rule establishing national standards for incidental discharges from vessels into waters of the United States, albeit nearly four years after its statutory deadline. However, existing requirements included in the 2013 Vessel General Permit…
The Arctic Shipping Frontier: Regulatory and Operational Challenges to Consider
Vanessa C. DiDomenico ● Heavy fuel oil (“HFO”), commonly known as bunker fuel or residual fuel oil, has been widely used by vessels for decades due to its low cost and ready availability. However, due to its high sulfur and heavy metal content, the International Maritime Organization (“IMO”) has steadily enacted regulations to limit the sulfur…
U.S. Department of Commerce Proposes Expanded Export Controls Targeting Military, Intelligence, and Law Enforcement End Users in China and Elsewhere
Anthony Rapa, Alan G. Kashdan, and Brendan S. Saslow ● Overview On July 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued proposed rules that would significantly expand controls under the Export Administration Regulations (“EAR”) regarding exports for certain end uses, certain end users, and U.S. person activities. At a…
USCG Considers Organism Viability Testing Methods to Achieve Type Approval of Ballast Water Management Systems
Jeanne M. Grasso and Holli B. Packer ● On August 21, 2024, the U.S. Coast Guard (“USCG”) outlined its intent to prepare the “Viability Testing Method Consideration for Acceptance Programmatic Environmental Impact Statement (“PEIS”)” in the Federal Register (89 Fed. Reg. 67646), which will be used to evaluate, and potentially adopt, organism viability testing methods…
Chevron Deference Tossed Overboard—What Does It Really Mean?
Jonathan K. Waldron, Dana S. Merkel, and Holli B. Packer ● The Supreme Court of the United States’ June 28, 2024, decision in Loper Bright Enterprises v. Raimondo, 144 S. Ct. 2244 (2024), dealt a blow to the “Chevron deference.” Loper Bright eliminated the judicial mandate that courts defer to an agency’s interpretation of ambiguous language in statutes…