August 2025 | Customs & International Trade Law Blog

What Happened This Month in International Trade (August 2025)

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

Administration

On August 11, President Trump signed an Executive Order delaying the imposition of additional China reciprocal tariffs until November 10.
On August 6, President Trump signed an Executive Order imposing an additional 25% tariff on imports from India to take effect Aug. 27. This applies on top of the 25% reciprocal tariff.
The U.S. and EU released a joint statement announcing that the U.S. will lower tariffs on EU goods covered by the automotive Section 232 action from 25% to 15% as soon as the EU acts to eliminate its industrial tariffs.

Customs and Border Protection (CBP)

CBP released new guidance on the additional goods subject to Section 232 tariffs for steel and aluminum derivatives.
CBP published additional guidance on reciprocal tariffs. The guidance covers additional information on what goods are exempt, reiterates which goods are subject to reciprocal tariffs, and the reporting sequence for HTSUS numbers.
CBP’s CTPAT program published an alert providing guidance on how importers can be vigilant in preventing illegal transshipping.

By Jennifer Diaz|2025-09-12T09:13:33-04:00August 28, 2025|news, Snapshot, Uncategorized|Comments Off

DHS Adds Additional UFLPA High-Priority Sectors; Releases UFLPA 2025 Strategy Update

Learn more about this update and all things UFLPA at our upcoming forced labor webinar on Sept. 17, 2025. Register here.

On August 19, 2024, the U.S. Department of Homeland Security (DHS) announced that it would be adding steel, copper, lithium, caustic soda, and red dates to the list of high-priority sectors for enforcement under the Uyghur Forced Labor Prevention Act (UFLPA). DHS also announced the release of an update to the UFLPA enforcement strategy.

Addition of High-Priority Sectors

Under the UFLPA, DHS is tasked with identifying high-priority sectors for enforcement. A high-priority sector designation indicates that entities in the sector have a higher risk of forced labor or state labor transfer of Uyghurs and other ethnic minorities from Xinjiang.

In making the announcement of additional sectors, DHS cited each new addition’s connections to forced labor risks. For example, DHS stated that steel and copper have both been government-backed investment focal points in Xinjiang. Similarly, lithium is a government-identified key sector for investment and development in Xinjiang.

UFLPA Enforcement Strategy Update

DHS serves as the chair of the Forced Labor Enforcement Task Force (FLETF). Each year, the task force updates the UFLPA’s Strategy to Prevent the Importation of Goods Mined, Produced, or Manufactured with Forced Labor in the People’s Republic of China (UFLPA Strategy). The task force is statutorily required to provide annual updates […]

By Jennifer Diaz|2025-08-22T11:15:20-04:00August 22, 2025|Enforcement, Forced Labor, Import, International Trade, Supply Chain, U.S. Customs and Border Protection (CBP), U.S. Department of Homeland Security (DHS)|Comments Off

Breaking Trade News: UFLPA Strategy Update, New Steel & Aluminum Product Categories, $12M AD/CVD Fine

Here is a recap of the latest customs and international trade news:

Administration

The U.S. and EU released a joint statement announcing that the U.S. will lower tariffs on EU goods covered by the automotive Section 232 action from 25% to 15% as soon as the EU acts to eliminate its industrial tariffs.

Customs and Border Protection (CBP)

CBP released an EAPA enforcement update, revealing that from January 20 to August 8, 2025, CBP uncovered more than $400 million in unpaid trade duties through EAPA investigations.
CBP released new guidance on the additional goods subject to Section 232 tariffs for steel and aluminum derivatives.
CBP released a ruling in which the agency denied an importer’s request to use the first sale in determining transaction value. CBP determined that the importer did not provide sufficient evidence to demonstrate “bona fide sales.”
CBP released a Harmonized System Update containing 21 Harmonized Tariff Schedule records and 52 Automated Broker Interface records.
CBP officers in Indianapolis seized a shipment containing Cartier designer counterfeit watches. If the watches had been […]

By Jennifer Diaz|2025-08-22T10:52:59-04:00August 22, 2025|news, Snapshot|Comments Off

Breaking Trade News: China Tariffs Delayed, New Census In-Transit Rule

Here is a recap of the latest customs and international trade news:

Administration

On August 11, President Trump signed an Executive Order delaying the imposition of additional China reciprocal tariffs until November 10.
President Trump posted on Truth Social that gold will not be tariffed, seemingly in response to a recent “surprise” CBP ruling stating that gold bars are subject to reciprocal tariffs.

Customs and Border Protection (CBP)

Net revenue recovered from entry summaries reached $25.6 billion for the fiscal year as of June 30. In comparison, for FY 2024, the net revenue was $667.6 million.
On August 12, CBP deployed an ACE update that will automatically withhold release of de minimis shipments that are ineligible for clearance because the $800 per person/per day threshold has been met.
A recent “surprise” CBP ruling saying gold bars are subject to reciprocal tariffs led to a surge in gold futures.
CBP officers in Louisville intercepted a shipment containing more than 7,000 pairs of counterfeit earrings. If genuine, the shipment would have had a Manufacturer’s Suggested Retail Price of $30.37 million.
CBP officers […]

By Jennifer Diaz|2025-08-15T09:33:15-04:00August 15, 2025|news, Snapshot|Comments Off

Census Bureau Releases Final Rule Clarifying Filing Requirements for In-Transit Shipments

On August 14, 2025, The Census Bureau issued a final rule to clarify its regulations governing in-transit shipments from foreign countries through the United States that are subsequently exported to a foreign destination. The rule takes effect September 15, 2025.

Background

The Census Bureau is responsible for collecting, compiling, and publishing import and export trade statistics for the United States. As part of this responsibility, the Census collects Electronic Export Information (EEI) in concert with the export control and enforcement functions of U.S. Customs and Border Protection (CBP) of the Department of Homeland Security (DHS), the Bureau of Industry and Security (BIS), and the Directorate of Defense Trade Controls (DDTC).

Public Law 107-228 directed the Census to publish regulations requiring exporters to file Shippers’ Export Declarations. As a result, the bureau experienced an increase in the number of inquiries regarding in-transit movements. Accordingly, in October of 2024 the Census solicited comments on a proposed rule to clarify its regulations governing in-transit shipments. The bureau received 11 letters and emails commenting on the proposed rule.

Key Changes

In addition to making definitional, grammatical and style changes, the rule: (i) clarifies who is the USPPI; (ii) makes changes to mandatory filing requirements; (iii) makes changes to voluntary self-disclosures.

Who is the USPPI

The U.S. Principal Party in Interest (USPPI) is the person or legal entity in the United States that receives the primary benefit, […]

By Jennifer Diaz|2025-08-15T09:26:47-04:00August 15, 2025|EEI, Enforcement, Export, International Trade, Pre-compliance, U.S. Census Bureau|Comments Off

New AD/CVD Case Filed: High Purity Dissolving Pulp from Brazil and Norway

A new antidumping and countervailing duty action has been filed on high purity dissolving pulp from Brazil and Norway. The allegation is that imports from Brazil and Norway are unfairly subsidized and are being dumped.

Full list of exporters here.

Full list of importers here.

Background on AD/CVD Investigations

Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent.

Scope of the Investigation

The merchandise covered by these investigations is high purity dissolving pulp.

The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheadings 4702.00.0020 and 4702.00.0040.

Full scope here.

Next Steps

The Commerce Department will determine whether to initiate the investigations within 20 days. The USITC will reach a preliminary determination of material injury or threat of material […]

By Jennifer Diaz|2025-08-13T13:14:58-04:00August 13, 2025|AD/CVD, U.S. Department of Commerce (DOC)|Comments Off

Breaking Trade News: Reciprocal Tariffs Take Effect, Additional Tariffs on India, FDA Food Traceability Extension

Here is a recap of the latest customs and international trade news:

Administration

The Administration’s reciprocal tariffs took effect on August 7. Goods from more than 60 countries now face additional tariffs between 10% and 41%.
On August 6, President Trump signed an Executive Order imposing an additional 25% tariff on imports from India to take effect Aug. 27. This applies on top of the 25% reciprocal tariff.
President Trump told reporters that the U.S. will be imposing a tariff of “approximately 100%” on chips and semiconductors.

Customs and Border Protection (CBP)

CBP published additional guidance on reciprocal tariffs. The guidance covers additional information on what goods are exempt, reiterates which goods are subject to reciprocal tariffs, the reporting sequence for HTSUS numbers, and how CBP will process goods determined to be transshipped.
CBP released a Harmonized System Update on August 5 that contained 404 Automated Broker Interface records and 135 Harmonized Tariff Schedule records.
CBP published guidance on how brokers and importers should apply the new 40% duties on goods imported from Brazil.
CBP, in partnership with the FDA, seized 54,843 […]

By Jennifer Diaz|2025-08-08T10:42:37-04:00August 8, 2025|news, Snapshot|Comments Off

ICYMI: Technology Company Pleads Guilty to Export Control Violations, Agrees to $140M Fine

The U.S. Attorney’s Office for the Northern District of California and the Counterintelligence and Export Control Section (CES) of the Department of Justice’s (DoJ) National Security Division announced that Cadence Design Systems, Inc. of San Jose, California, agreed to plead guilty to resolve criminal violations of export controls.

As part of the plea agreement, Cadence will pay criminal penalties of nearly $118 million.

In addition to the charges, the Department of Commerce’s Bureau of Industry and Security (BIS) also announced the resolution of a civil enforcement action against the company in which Cadence agreed to pay over $95 million in civil penalties.

The DoJ and BIS have coordinated the resolution of the parallel investigation, and each agreed to a partial credit against their fine for payments made to satisfy the other agency’s fine. Under the coordinated agreement, Cadence will pay criminal and civil penalties of more than $140 million.

Cadence committed criminal violations of the export control laws by selling hardware, software, and semiconductor design intellectual property to the National University of Defense Technology (NUDT) in China. NUDT was added to the Department of Commerce’s Entity List in February 2015. The university was involved in the development of supercomputers with applications for military and nuclear explosive simulations.

Cadence and its Chinese subsidiary engaged in a conspiracy to commit export control violations by exporting this technology to NUDT without obtaining the requisite licenses from […]

By Jennifer Diaz|2025-08-07T11:02:35-04:00August 7, 2025|EAR, Enforcement, Export, International Trade, U.S. Bureau of Industry and Security (BIS), U.S. Department of Justice (DOJ)|Comments Off

Bond Insufficiency Notices Are at an All Time High – Don’t Let This Happen to You!

With rising tariffs, U.S. Customs and Border Protection (CBP) is busy sending importers bond insufficiency notices advising them that their existing customs bond no longer covers their obligations.

What is a Customs Bond

A customs bond, sometimes called a surety or import bond, is a financial guarantee that ensures importers meet CBP regulations and pay all applicable duties, taxes, fines, and penalties related to importing goods into the United States.

The most common type of bond is an import bond, which is required on all commercial shipments of goods valued over $2,500. An import bond is also required for shipments that are subject to other U.S. government agency requirements.

A single transaction bond can be used for a single entry. However, most importers utilize continuous bonds, which self-renew yearly and cover all customs transactions through any port of entry.

Insufficiency Notices on the Rise

CBP reviews the sufficiency of all active continuous import bonds on a monthly basis. If an importer’s bond has exceeded its capacity, CBP will issue a demand for a larger bond in the form of an insufficiency notice. The recent increase in tariffs means increased bond amounts, and many importers are struggling to properly calculate their bonds to keep them current. The number of bond insufficiency notices issued has quadrupled since 2017 and has accelerated recently with the volatile tariff environment. 50% of insufficient bonds are for bonds under $100k.

By Jennifer Diaz|2025-08-05T09:30:36-04:00August 5, 2025|U.S. Customs and Border Protection (CBP)|Comments Off

ICYMI: Patio Furniture Company Agrees to Pay $4.9 Million to Resolve Duty Evasion Allegations

On July 24, 2025, the Department of Justice (DoJ) announced that Grosfillex, Inc., a Pennsylvania furniture company, agreed to pay $4.9 million to resolve allegations it evaded antidumping and countervailing duties (AD/CVD).

Grosfillex submitted false forms to Customs and Border Protection (CBP) claiming that furniture parts made of extruded aluminum from China were not subject to AD/CVD. The company attempted to hide the aluminum extrusions by falsely packing them as sham “furniture kits.” Additionally, for a different subset of extrusions, the company failed to correct customs forms it had submitted previously, even after learning that the forms contained false information.

The investigation arose from a whistleblower lawsuit filed under the False Claims Act by a former employee of Grosfillex. Under the False Claims Act, private citizens can sue on behalf of the government and share in any recovery. In this case, the whistleblower will receive $962,662.74.

Duty Evasion is on the Rise

This case is just one example of the growing incentive to cheat that comes with higher tariffs. Whether it’s through misclassifying goods, undervaluing imports, or using deceptive transshipment routes, some companies think they are being creative, but, instead, are participating in outright illegal strategies to reduce their tariff liability.

Higher tariffs have even contributed to the emergence of a cottage industry of “tariff reduction” companies that suggest ways to cut import costs. However, many of these so-called strategies amount to evasion, […]

By Jennifer Diaz|2025-08-01T10:52:13-04:00August 1, 2025|AD/CVD, Enforcement, Import, International Trade, Penalty, Reasonable Care, U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ)|Comments Off