July 2026 | Customs & International Trade Law Blog

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 […]

By Jennifer Diaz|2026-07-31T09:18:51-04:00July 31, 2026|news, Snapshot|Comments Off

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

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

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 […]

By Jennifer Diaz|2026-07-22T17:44:25-04:00July 22, 2026|Bloomberg Import|Comments Off

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

By Jennifer Diaz|2026-07-21T12:54:06-04:00July 21, 2026|Canada, International Trade, Tariffs, USMCA|Comments Off

DOJ and DHS Publish Comprehensive Trade Fraud Enforcement Guide: What Importers Need to Know

Short summary: The DOJ and DHS have jointly published a new Resource Guide to Trade Fraud Enforcement, highlighting the government’s coordinated approach to combating customs fraud and strengthening import compliance. The guide explains key enforcement authorities, common trade fraud schemes, and the government’s expectations for importers, customs brokers, and others participating in global supply chains.

The U.S. Department of Justice (DOJ) and Department of Homeland Security (DHS) have released a new 31-page Resource Guide to Trade Fraud Enforcement, providing one of the clearest public statements yet on how the federal government views customs fraud, enforcement priorities, and importer compliance obligations. The guide was developed by the Trade Fraud Task Force, a partnership that includes DOJ’s National Fraud Enforcement Division, Homeland Security Investigations (HSI), U.S. Customs and Border Protection (CBP), and other federal agencies.

While much of the guide summarizes existing laws and enforcement authorities, its significance lies in the government’s messaging. It makes clear that customs violations are no longer viewed as merely technical or administrative issues. Instead, DOJ and DHS repeatedly characterize trade fraud as a threat to economic security, national security, public safety, and human rights, signaling that aggressive enforcement will continue across multiple agencies.

Combatting Trade Fraud Is a Priority for the Federal Government

One of the report’s primary themes is that trade fraud extends far beyond the underpayment of duties. According to the guide, fraudulent import practices undermine domestic manufacturers, deprive the government of […]

By Jennifer Diaz|2026-07-21T12:47:51-04:00July 21, 2026|Import, U.S. Customs and Border Protection (CBP), U.S. Department of Homeland Security (DHS), U.S. Department of Justice (DOJ)|Comments Off

IEEPA Tariff Refund Update: CIT Will Order Reliquidation of Some Finally Liquidated Entries

Short summary: The U.S. Court of International Trade has announced that it plans to order U.S. Customs and Border Protection (CBP) to reliquidate certain finally liquidated entries in approximately 3,700 pending IEEPA tariff refund cases once CAPE Phase 3 launches. The court also confirmed that CBP continues to expand CAPE’s refund capabilities, including future functionality for entries with open protests, and provided an update on the billions of dollars in refunds already being processed. These developments represent another significant step toward resolving pending IEEPA tariff refund claims for importers.

The U.S. Court of International Trade (CIT) has announced another significant development in the ongoing litigation over tariffs imposed under the International Emergency Economic Powers Act (IEEPA). In a July 15, 2026, order, Judge Richard K. Eaton confirmed that the court intends to direct U.S. Customs and Border Protection (CBP) to reliquidate certain finally liquidated entries in the approximately 3,700 pending CIT IEEPA refund cases once the next phase of CBP’s Consolidated Administration and Processing of Entries (CAPE) refund system becomes operational.

While the order does not immediately authorize refunds of liquidated entries, it provides important insight into how the court and CBP plan to move thousands of pending refund claims toward resolution.

Reliquidation Order Planned for Thousands of Cases

The court stated that, in connection with the anticipated launch of CAPE Phase 3, it will issue an order directing CBP to reliquidate certain finally liquidated entries […]

By Jennifer Diaz|2026-07-16T14:00:32-04:00July 16, 2026|Import, International Trade, Tariffs, U.S. Court of International Trade, U.S. Customs and Border Protection (CBP)|Comments Off

Understanding HTSUS Classification: Why Getting It Wrong Is Expensive

Summary: HTSUS classification determines the duty rate, applicability of tariffs such as Section 301 and Section 232, trade program eligibility, and helps determine whether any AD/CVD duties apply to every imported product. Misclassification often goes undetected for months or years, and since importers tend to reuse the same code for every entry of the same product, a single error can compound into significant back duties, penalties, and prior disclosure obligations. This article breaks down how classification errors happen, what reasonable care looks like, and how a documented classification process can prevent a small mistake from becoming a costly one.

Every product entering the United States must be assigned a classification code under the Harmonized Tariff Schedule of the United States (HTSUS), and that ten-digit number determines far more than most importers realize. It sets the duty rate and tariffs owed on a shipment, flags whether a product needs additional agency review, and establishes whether it qualifies for preferential trade programs. A misclassification, even an unintentional one, can trigger back duties, penalties, and a prior disclosure process that could have been avoided entirely with the right classification from the start.

What HTSUS Classification Actually Determines

The Harmonized Tariff Schedule of the United States is the United States’ implementation of the international Harmonized System, a standardized numerical method of classifying traded products used by customs authorities around the world. Every entry filed with U.S. Customs and Border Protection (CBP) requires an HTSUS code, and […]

By Jennifer Diaz|2026-07-10T11:00:19-04:00July 10, 2026|Import, Reasonable Care, U.S. Customs and Border Protection (CBP)|Comments Off

Mandatory CPSC eFiling is Here

Key Takeaways

Starting July 8, 2026, importers of most regulated consumer products must electronically file (eFile) Certificate of Compliance data into CBP’s ACE system at the time of entry, no longer on request.
At launch, CPSC does not intend to have ACE reject entries or deny admission solely for failure to eFile, only warning messages. But CPSC will still enforce certificate requirements, seek seizure of non-compliant goods, and adjust your risk score.
A testing exemption or determination does not eliminate the certificate. You must still issue a certificate citing the rule and naming the exemption. This is a trap that catches importers who assume “exempt” means “nothing to file.”
Products entering a Foreign Trade Zone and later withdrawn for consumption or warehousing get a later effective date: January 8, 2027.
The eFiling rule changes how certificate data is filed, not which products need a certificate. Certification has been required since 2008.

A Compliance Shift Disguised as a Filing Update

Since 2008, importers and domestic manufacturers of CPSC-regulated consumer products have been required to maintain a Certificate of Compliance: a Children’s Product Certificate (CPC) for children’s products, or a General Certificate of Conformity (GCC) for regulated general-use products, and produce it on request. Under […]

By Jennifer Diaz|2026-07-08T10:11:22-04:00July 8, 2026|ACE, Import, U.S. Consumer Product Safety Commission (CPSC)|Comments Off

FDA Proposes New Rule Requiring Foreign Tobacco Manufacturers to Register with the Agency

Short summary: The FDA has proposed a new rule that would require foreign tobacco product manufacturers to register their establishments and submit product listings to the agency, aligning them with requirements already applicable to domestic manufacturers. While the rule is not yet final, it signals increased oversight of imported tobacco products and enhanced coordination between the FDA and U.S. Customs and Border Protection (CBP).

On June 26, 2026, the U.S. Food and Drug Administration (FDA) announced a proposed rule that would significantly expand its oversight of imported tobacco products. If finalized, the rule would require foreign tobacco product manufacturers to register their establishments with the FDA and submit product listings. These requirements have long applied to domestic manufacturers but not foreign producers.

The proposal is intended to close a regulatory gap, strengthen FDA enforcement, and improve the agency’s ability to identify and stop unauthorized tobacco products from entering the United States, particularly e-cigarettes and other youth-appealing products. It also represents another step toward increased scrutiny of imported tobacco products and the companies that manufacture them.

What Would Change?

Under the proposed rule, foreign establishments that manufacture, prepare, compound, or process tobacco products for sale in the United States would be required to:

Register their manufacturing establishments with the FDA;
Submit product listings identifying the tobacco products manufactured […]

By Jennifer Diaz|2026-07-07T10:27:14-04:00July 7, 2026|Import, Tobacco, U.S. Food and Drug Administration (FDA)|Comments Off

Breaking Trade News: CAPE Phase II Launches, USMCA Not Renewed

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

Administration:

President Trump signed a Proclamation temporarily removing duties on phosphate fertilizer from Morocco. The duties will be suspended for eight months.

Customs and Border Protection (CBP)

On June 29, 2026, CBP launched CAPE Phase II for IEEPA refunds. This phase covers enhanced processing for reconciliation-flagged entries, making the large majority of IEEPA duties eligible for refund.
CBP issued an interim final rule (IFR) that codifies the suspension of de minimis for international mail shipments and establishes a new postal informal entry process for certain goods entering by mail. The rule takes effect July 24, 2026.
CBP issued a Notice of Determination as to Evasion in an EAPA case, finding that a major solar-module importer evaded antidumping AD/CVD orders on crystalline silicon photovoltaic cells.
CBP published a Federal Register Notice increasing interest rates for underpayments (7% for both corporations and non-corporations) and overpayments (7% for non-corporations and 6% for corporations).
CBP seized over $120,000 in unmanifested kitchen […]

By Jennifer Diaz|2026-07-03T12:47:21-04:00July 3, 2026|news, Snapshot|Comments Off