Customs & International Trade Law Blog

14 08, 2026

Breaking Trade News: New 232 Tariffs on UAS, DOJ Seeks to Vacate IEEPA Refund Injunctions

By Jennifer Diaz|2026-08-14T12:06:29-04:00August 14, 2026|news, Snapshot|0 Comments

This week’s recap of the latest customs and international trade news:

Customs and Border Protection (CBP)

In accordance with President Trump’s quartz proclamation from July 31, 2026, CBP updated its quota bulletin for quartz surface products. The opening date is August 17, 2026.
CBP extended the Jones Act Waiver for 90 days – to November 15, 2026. CBP also implemented a new requirement that companies considering transportation on a foreign-flagged vessel must first send a written request to the Defense Department, the Maritime Administration, and CBP.
CBP’s Office of Field Operations (OFO) released its 2026-2030 Strategy, outlining what transformations are required to advance OFO’s four Core Mission Areas: Secure Lawful Travel, National Security and Contingency Operations, Secure and Compliant Trade and Agriculture and Biological Threat Security.
CBP is extending the phased enforcement period for enhanced air cargo advance screening. The phase was set to end on Nov. 21, 2026, and will now run until May 1, 2027.
CBP announced that it will implement two-factor authentication for ACE portal logins through email or SMS notification starting in September.
CBP officers at the Port of Louisville, Kentucky intercepted

14 08, 2026

FinCEN Permanently Ends BOI Reporting for U.S. Companies and U.S. Persons Under the Corporate Transparency Act

By Jennifer Diaz|2026-08-14T11:56:45-04:00August 14, 2026|Enforcement, International Business, International Law, news|0 Comments

On August 11, 2026, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). FinCEN states that U.S. companies are now exempt from BOI reporting requirements and no longer need to file BOI reports. The final rule also relieves U.S. persons from providing BOI to reporting companies and from updating or correcting information previously submitted to obtain a FinCEN identifier. For many domestic businesses, this marks a significant compliance shift—but foreign entities registered to do business in the United States may still have BOI obligations.

What Changed?

FinCEN’s final rule makes permanent the relief first announced in the March 2025 interim final rule. Under the final rule, U.S. companies are exempt from BOI reporting requirements and therefore are no longer required to file BOI reports. Reporting companies also do not need to report BOI for U.S. person beneficial owners or U.S. person company applicants, and U.S. persons do not need to provide BOI to reporting companies.

FinCEN also announced that U.S. persons with FinCEN identifiers are not required to update or correct the information they previously submitted to FinCEN. This is important for individuals who filed BOI information before the rule changed and who otherwise may have expected ongoing update obligations.

Who Still Has BOI Reporting Obligations?

The final rule does not eliminate […]

10 08, 2026

$5.15 Million Settlement Highlights Growing Customs Enforcement Under the False Claims Act

By Jennifer Diaz|2026-08-10T12:28:34-04:00August 10, 2026|Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP)|0 Comments

Short summary: A Taiwanese manufacturer has agreed to pay $5.15 million to resolve allegations that it violated the False Claims Act by underpaying customs duties on imported goods. According to the Department of Justice, the company used improper customs practices to reduce duties owed to CBP, resulting in significant lost tariff revenue. The settlement underscores the federal government’s continued focus on customs enforcement and the growing use of the False Claims Act to pursue alleged duty evasion.

The U.S. Department of Justice recently announced that a Taiwan-led manufacturer agreed to pay $5.15 million to resolve allegations under the False Claims Act and related administrative claims involving customs duties owed on imported goods. While the company did not admit liability, the settlement serves as another reminder that customs compliance remains a significant enforcement priority for the federal government.

The Case – What Happened

According to the DOJ, the alleged conduct went well beyond a simple classification error. The government alleged that the company used multiple methods over several years to reduce the customs duties it owed on imports. Specifically:

Country of Origin Misrepresentations: From July 2018 through January 2022, Everlight allegedly knowingly misrepresented the country of origin on Chinese-manufactured LEDs. Everlight knew these products were manufactured in China, and then transshipped to Taiwan, before shipping them to the U.S. Everlight allegedly misrepresented to CBP that the products originated in Taiwan rather […]

10 08, 2026

New Section 201 Safeguard Tariffs on Quartz Surface Products

By Jennifer Diaz|2026-08-10T10:14:35-04:00August 10, 2026|Tariffs|0 Comments

Short summary: President Trump’s new Section 201 safeguard measure establishes a four-year tariff-rate quota (TRQ) on imports of quartz surface products beginning August 15, 2026. While annual quota volumes gradually increase over the life of the measure, importers may face safeguard duties of up to 50% once quarterly quota allocations are exhausted, making careful planning essential.

On July 31, 2026, President Trump issued a proclamation imposing a Section 201 safeguard measure on imports of quartz surface products (QSP). The measure takes the form of a four-year tariff-rate quota (TRQ) and applies to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on Saturday, August 15, 2026.

If you import QSP, including countertops, backsplashes, vanity tops, bar tops, work tops, tabletops, flooring, wall facing, shower surrounds, fireplace surrounds, mantels, and tiles, this measure will likely affect your imports.

How the Tariff-Rate Quota Works

A TRQ is not a flat tariff. A set volume of covered merchandise may enter each quota year at a lower in-quota rate under the new HTSUS heading 9903.45.30. Once that volume is exhausted, additional entries pay a substantially higher over-quota rate under new heading 9903.45.31.

The annual volume is divided into four equal quarterly tranches. Any unused portion of a quarterly tranche carries forward into the following quarter, and CBP is required to add the unused quantity to the next quarter’s total no later than 14 days after the prior quarter […]

7 08, 2026

Breaking Trade News: IEEPA Refunds Update, 301 Lawsuit, $5M FCA Settlement

By Jennifer Diaz|2026-08-07T10:21:37-04:00August 7, 2026|news, Snapshot|0 Comments

This week’s recap of the latest customs and international trade news:

Customs and Border Protection (CBP)

CBP filed an update with the CIT in the IEEPA refunds case, stating that nearly $130 billion in potential and certified refunds have been accepted for processing via CAPE, and over 5 million entries failed entry level validations.
CBP issued guidance via CSMS message regarding how to electronically remit payment for increases in duties, taxes and fees from a post-summary correction. Filers will not be able to pay in check or cash beginning Aug. 5.
CBP officers from the George Bush Intercontinental Airport seized nearly $4 million in counterfeit goods, including fake MLB and Nike apparel, Louis Vuitton bags, Cartier sunglasses, and Jaguar Land Rover computer systems.

Courts

A group of 25 states led by Oregon, Arizona and California filed a lawsuit at the CIT challenging the Section 301 forced labor tariffs as a violation of the Administrative Procedure Act, alleging that USTR’s investigation was rushed and failed to address comments.
Customs broker Forrest Xu filed a complaint with the CIT arguing that CBP deactivated his broker entry filer code without due process.

Department of Justice

Everlight Electronics of Taiwan agreed to pay the United States $5.15 million to resolve allegations that they violated the False Claims Act, common law, and the Tariff Act by knowingly failing to pay duties owed on LEDs imported from China.

Department of Commerce

The Commerce […]

6 08, 2026

Reminder: FDA VQIP Applications for FY2027 Close September 1

By Jennifer Diaz|2026-08-06T10:10:31-04:00August 6, 2026|U.S. Food and Drug Administration (FDA)|0 Comments

Short summary: The FDA has announced that the application window for Fiscal Year 2027 Voluntary Qualified Importer Program (VQIP) benefits closes on September 1, 2026. For companies importing FDA-regulated food products, the approaching deadline is a reminder to confirm eligibility, supplier certifications, and application readiness before time runs out.

Deadline and Program Overview

Food importers seeking faster FDA entry processing should take note: the application period for the FDA’s Voluntary Qualified Importer Program (VQIP) for Fiscal Year 2027 closes on September 1, 2026.

VQIP is a fee-based program established under the Food Safety Modernization Act (FSMA) that rewards importers with strong supply chain controls and demonstrated food safety compliance. Approved participants may benefit from expedited review and importation of eligible human and animal food products entering the United States.

Applications approved for FY2027 will provide benefits beginning October 1, 2026, provided the FDA receives both an approved application and the required user fee payment.

Eligibility Requirements

Importers should not assume they qualify automatically. One of the most common barriers to participation is the requirement that all foreign suppliers associated with VQIP-covered products maintain a valid facility certification issued by an FDA-accredited certification body under the FDA’s Accredited Third-Party Certification Program.

Importers considering VQIP participation should verify:

Foreign suppliers hold current certifications from FDA-accredited certification bodies.
Required regulatory audits have been completed.
Supply chain documentation and food safety controls meet FDA expectations.
Internal records are current and ready for submission through the VQIP portal.

Why Importers Should Consider VQIP

For qualifying importers, VQIP can provide meaningful operational advantages, including:

Expedited […]

31 07, 2026

What Happened This Month in International Trade (July 2026)

By Jennifer Diaz|2026-07-31T09:18:51-04:00July 31, 2026|news, Snapshot|Comments Off on What Happened This Month in International Trade (July 2026)

Another busy month in international trade news. Here’s the roundup:

Administration:

President Trump issued a Proclamation establishing an incentive for companies that are expanding primary aluminum production in the US, allowing them to import primary aluminum at a reduced tariff rate.
On July 20, 2026, the White House announced that the United States will impose an additional 50% tariff on many Canadian-origin products beginning 30 days after the order’s issuance.
President Trump announced via Truth Social that the Administration will initiate a 301 investigation into the European Union for excessive fines against American tech companies.
President Trump announced via Truth Social that effective August 1st, 2026, all Generic Drugs being brought into the United States will continue to have a 0% tariff for a two-year period of time, after which the tariff will be raised to 100% for one year, and 200% thereafter.

United States Trade Representative (USTR)

On July 23, 2026, the USTR announced a Section 301 action imposing new tariffs on 60 trading partners.
On July 15, 2025, the USTR announced a Section 301 action imposing a 25% tariff against some Brazilian exports.
The […]

24 07, 2026

USTR Announces Section 301 Action Imposing New Tariffs on 60 Trading Partners

By Jennifer Diaz|2026-07-24T10:11:00-04:00July 24, 2026|Forced Labor, International Trade, Tariffs, U.S. Customs and Border Protection (CBP)|Comments Off on USTR Announces Section 301 Action Imposing New Tariffs on 60 Trading Partners

The Office of the U.S. Trade Representative (USTR) has announced a new Section 301 action imposing additional tariffs of 10% to 12.5% on imports from 60 economies that fail to prohibit or effectively enforce bans on goods produced with forced labor. The action covers the top 60 U.S. trading partners, representing 99.4% of U.S. imports, and took effect July 24, 2026. U.S. Customs and Border Protection (CBP) has issued entry filing guidance in CSMS #69326983, including the applicable Chapter 99 tariff headings.

Key Takeaways

Effective July 24, 2026, USTR imposed additional Section 301 duties of 10% or 12.5% on imports from 60 economies covering 99.4% of U.S. imports, based on findings that these economies failed to adopt or effectively enforce forced labor import prohibitions.
CBP issued entry filing instructions in CSMS #69326983, including the Chapter 99 headings (9903.05.20 through 9903.06.21), reporting sequence, and Foreign Trade Zone admission requirements.
Goods entered duty free under USMCA (Canada and Mexico) are exempt, as are CAFTA-DR textiles and apparel, Section 232 articles, civil aircraft, pharmaceutical articles, informational materials, and donations. There is also a list of miscellaneous products exempt no matter what their country of origin.
An in-transit exception applies to goods loaded and in transit on the final mode before 12:01 a.m. ET on July 24, 2026, and entered before 12:01 a.m. ET on July 28, 2026.

Why USTR Took Action

22 07, 2026

CBP Protests and Post-Entry Corrections

By Jennifer Diaz|2026-07-22T17:44:25-04:00July 22, 2026|Bloomberg Import|Comments Off on CBP Protests and Post-Entry Corrections

CBP is one of the most active federal enforcement bodies in international trade. CBP has broad authority to examine, detain, seize, and penalize imported goods, and it exercises that authority through an expanding set of tools.

Enforcement Mechanisms

CBP’s core enforcement mechanisms include:

Detention and Examination – Customs laws and regulations provide US Customs officers at all 328 ports of entry the ability to stop and search persons or merchandise and make admissibility decisions. Before goods are seized by CBP, they typically go through the detention process. CBP may detain any shipment for examination when it has reason to believe the goods may violate U.S. law.
Seizure and Forfeiture – When CBP suspects that goods violate U.S. law, it can seize the merchandise. The importer then faces a choice: file a petition for relief with CBP’s Fines, Penalties and Forfeitures Office (FP&F), offer a monetary settlement in lieu of forfeiture, abandon the goods, or contest the seizure through the administrative or judicial process.
Liquidation and Reliquidation – Every entry is subject to liquidation – the final determination of duties owed. CBP may liquidate an entry at a higher duty rate than originally estimated, triggering an unexpected duty bill. Importers have limited windows, generally within 180 days of liquidation, to challenge liquidation decisions.
Penalties – CBP has the authority to issue monetary penalties for violations of customs laws. These penalties may be assessed […]

21 07, 2026

Trump Invokes Section 338 to Impose Additional Duties on Canadian Imports

By Jennifer Diaz|2026-07-21T12:54:06-04:00July 21, 2026|Canada, International Trade, Tariffs, USMCA|Comments Off on Trump Invokes Section 338 to Impose Additional Duties on Canadian Imports

Short summary: The Trump Administration has announced new tariffs on Canadian imports and issued three presidential proclamations addressing Canada’s treatment of U.S. dairy products, alcoholic beverages, and motor vehicles. The actions rely on Section 338 of the Tariff Act of 1930 – a statutory authority that has remained largely unused for decades.

On July 20, 2026, the Trump Administration published a fact sheet announcing new 50% tariffs on a broad range of Canadian imports. Simultaneously, the Administration issued three separate presidential proclamations targeting Canada’s treatment of U.S. dairy products, alcoholic beverages, and motor vehicles. According to the White House, these actions are intended to respond to what the Administration describes as Canada’s long-standing discrimination against U.S. commerce.

The New Tariffs

The White House announced that the United States will impose an additional 50% tariff on many Canadian-origin products beginning 30 days after the order’s issuance. According to the Administration, the new duties are intended to offset Canada’s alleged discriminatory treatment of American products and businesses.

Products eligible for USMCA treatment are not exempt from the new tariffs. Several categories of goods are excluded from the new tariffs, including:

Energy products
Critical minerals
Potash
Fish