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Breaking Trade News: COAC Meeting Recommendations, U.S.-China Trade Truce Extended 

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

Customs and Border Protection (CBP)        

  • CBP’s Commercial Customs Operations Advisory Committee (COAC) held it’s quarterly meeting on Sept. 23 and recommended that the CBP Office of Trade Relations establish a central webpage to house guidance and resources, and create a feedback mechanism for the COAC and trade community. 
  • CBP published an alert to CTPAT partners stating that pursuant to Executive Order 14411, Strengthening Customs Enforcement, Importers of Record (IORs) and licensed customs brokers acting on their behalf, are required to ensure information submitted on CBP Form 5106, Importer Identity Form, is accurate, complete, and updated as needed. 
  • CBP is automating the submission method for Organization Broker License Applications. As of September 30, 2026, organization license applicants will complete and submit all applications and associated fees through the eCBP portal. 
  • CBP announced an electronic export manifest (EEM) pilot for shipments leaving the U.S. by truck. The pilot will begin Oct. 23 and last two years. 
  • CBP issued guidance on technical corrections for certain Section 301 product exclusions. 
  • The customs broker permit user fee will […]
By |2026-09-25T11:06:25-04:00September 25, 2026|news, Snapshot|Comments Off on Breaking Trade News: COAC Meeting Recommendations, U.S.-China Trade Truce Extended 
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Breaking Trade News: CAPE Phase 3, Russia Iran Sanctions Bill Passes, USTR Seeks Comment on Trade Barriers

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

Customs and Border Protection (CBP)       

  • CBP hosted the 2026 Trade and Cargo Security Summit in Dallas, Texas Sept. 8-10. This year’s theme, “Knowing Your Supply Chain to Remain Compliant and Mitigate Risk,” emphasized the shared responsibility of government and industry to strengthen supply chain security, support lawful trade, and protect the U.S. economy. Read the full summary here. 
  • Via a declaration filed with the CIT, CBP announced that the third phase of CBP’s Consolidated Administration and Processing of Entries (CAPE) refund system will launch Oct. 6. Phase 3 will focus on finally liquidated entries who filed suit at CIT and received an order for reliquidation. 
  • CBP updated its guidance on Section 338 tariffs on Canadian goods, effective Sept. 15. Under the update, only goods subject to HTS 9903.03.13 may claim the duty-free exception under 9903.03.15 for certain products, including specified metals, vehicles and parts, semiconductors, and pharmaceuticals. 
  • During a call on Sept. 15, CBP’s Christine Hogue said that customs brokers are expected to be the importer of record for the new Entry Type 13 CBP intends to deploy for mail entries.  
  • CBP published a Federal Register Notice asking for public comments on filing requirements regarding […]
By |2026-09-18T13:29:18-04:00September 18, 2026|news, Snapshot|Comments Off on Breaking Trade News: CAPE Phase 3, Russia Iran Sanctions Bill Passes, USTR Seeks Comment on Trade Barriers
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Diaz Trade Law Of Counsel David Craven Challenges Treatment of AD/CVD Entries at the Court of International Trade 

As U.S. Customs and Border Protection (CBP) continues processing refunds of tariffs unlawfully imposed under the International Emergency Economic Powers Act (IEEPA), one category of entries presents a particularly complicated problem: imports that are also subject to antidumping and countervailing duties (AD/CVD). 

For these importers, the timing of an IEEPA refund could affect more than when they get their money back. It could potentially affect the amount of antidumping duties they ultimately owe. 

David Craven, Of Counsel to Diaz Trade Law, represents Aditya Birla Chemicals USA Inc. and Pack Perfect Inc., and is challenging that problem before the U.S. Court of International Trade (CIT) in Aditya Birla Chemicals USA Inc. and Pack Perfect Inc. v. Trump, Court No. 26-00134. 

On July 28, Craven filed a Motion to Lift Stay and for Issuance of Order Clarifying Refunds, asking the CIT to address an emerging conflict between CBP’s IEEPA refund process and the Department of Commerce’s calculation of antidumping duties. 

At the heart of the case is a procedural catch-22: Commerce is treating IEEPA duties as a cost when calculating certain antidumping margins because the duties have not yet been refunded, while CBP’s current refund process may require the affected AD/CVD entries to liquidate before those refunds can be issued. 

Why Type 03 Entries Are Different 

Aditya Birla Chemicals and Pack Perfect […]

By |2026-09-18T13:16:34-04:00September 18, 2026|AD/CVD, Tariffs, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC)|Comments Off on Diaz Trade Law Of Counsel David Craven Challenges Treatment of AD/CVD Entries at the Court of International Trade 
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2026 CBP Trade and Cargo Security Summit: Key Takeaways for Importers 

U.S. Customs and Border Protection (CBP) brought together government officials and members of the trade community in Dallas from September 8–10, 2026, for its annual Trade and Cargo Security Summit (TCSS). This year’s theme “Knowing Your Supply Chain to Remain Compliant and Mitigate Risk” was reflected throughout three days of discussions on enforcement, supply chain visibility, artificial intelligence, forced labor, transshipment, CTPAT, cybersecurity, and the future of customs compliance.  

Here are some of the most important takeaways for importers.

  1. CBP Is Entering a New Era of Customs Enforcement

A major focus of the Summit was the Administration’s June 3, 2026 “Strengthening Customs Enforcement” Executive Order and the regulatory changes expected to follow. 

The Executive Order calls for, among other things, heightened requirements for Importers of Record (IORs), expanded data and identification requirements, and increased vetting of IORs and other parties throughout the import process. CBP officials emphasized that implementation will be an agency-wide effort and that additional regulatory packages are expected.  

The shift is already visible in the government’s broader enforcement posture. Discussions at the Summit emphasized customs fraud, shell companies, identity theft, false importer information, double invoicing, and other schemes CBP is encountering in the trade environment. CBP also stressed that its focus is not on ordinary clerical mistakes, but on identifying and escalating consequences for parties intentionally exploiting the system.  

  1. Supply Chain Visibility Is Becoming a National Security Issue

Perhaps no […]

By |2026-09-18T12:55:44-04:00September 18, 2026|Best Practices, CTPAT, Enforcement, Forced Labor, Import, Supply Chain, U.S. Customs and Border Protection (CBP)|Comments Off on 2026 CBP Trade and Cargo Security Summit: Key Takeaways for Importers 
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Breaking Trade News: New Canada Tariffs, BIS Annual Report, Monthly Trade Report

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

Administration 

  • President Trump issued several proclamations imposing bans on imports of Canadian alcoholic beverages, dairy products, molasses, and non-alcoholic beer, and certain motorcycles, and added new products to the list subject to 50% Section 301 tariffs. The tariffs take effect Sept. 15, the ban takes effect Sept. 29. 

Customs and Border Protection (CBP)      

  • On Sept. 12, CBP will update ACE login security by adding SMS message as a two-factor authentication method. 
  • CBP officers in Baltimore seized a shipment of over 8,500 falcata plywood sheets that were imported using a stolen identity, were undervalued, and were clandestinely imported from China.   

Department of Justice (DOJ) 

  • Two Texas-based operators of an online animal-health products business were sentenced to three months in prison and ordered to forfeit more than $1.5M for a smuggled veterinary drug and pesticide scheme. 

International Trade Commission (ITC) 

  • The ITC is seeking public comment on how the Commission can establish practices to identify discriminatory trade actions and make recommendations to the President. Comments are due November 9, 2026.  

Bureau of Industry and Security (BIS) 

  • BIS […]
By |2026-09-11T15:15:19-04:00September 11, 2026|news, Snapshot|Comments Off on Breaking Trade News: New Canada Tariffs, BIS Annual Report, Monthly Trade Report
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BIS FY2025 Annual Report Signals Major Increase in Export Enforcement 

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released its Fiscal Year 2025 Annual Report to Congress, providing a detailed look at the agency’s export control, licensing, and enforcement activity.  

Key Takeaways 

  • BIS reports an 18-fold increase in penalties, from approximately $16 million in calendar year 2024 to approximately $324 million in 2025. 
  • BIS completed 53 administrative enforcement actions, resulting in more than $108 million in civil penalties during FY2025. 
  • BIS enforcement activity included 455 warning letters, 705 detentions, 232 seizures, and 29 denial orders. 
  • BIS investigations resulted in 65 criminal convictions of individuals and companies during FY2025. 
  • BIS completed 1,840 end-use checks across 73 countries, demonstrating the agency’s ability to scrutinize transactions even after goods leave the United States. 
  • BIS added 142 entities to the Entity List, including parties associated with advanced computing, quantum technology, hypersonic weapons programs, and Iranian drone procurement. 
  • Licensing for Entity List parties has become significantly more restrictive: BIS reports granting only 16 new licenses to Entity List companies during Q2–Q4 2025. 
  • Exporters should reassess restricted-party screening, end-user and end-use diligence, product classification, licensing procedures, recordkeeping, and escalation protocols in light of […]
By |2026-09-11T14:55:38-04:00September 11, 2026|Best Practices, EAR, Enforcement, Export, U.S. Bureau of Industry and Security (BIS)|Comments Off on BIS FY2025 Annual Report Signals Major Increase in Export Enforcement 
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China Blacklists Six U.S. Supply Chain Tracing Providers: What UFLPA Importers Need to Know

On August 5, 2026, China’s Ministry of Commerce placed six U.S. supply chain due diligence entities on its countermeasure list and prohibited organizations and individuals in China from transacting or cooperating with them. The six include the DNA tagging, isotopic testing, supply chain mapping, and labor audit providers that many importers rely on to document origin when U.S. Customs and Border Protection (CBP) detains goods under the Uyghur Forced Labor Prevention Act (UFLPA). Importers in cotton, apparel, electronics, minerals, and other UFLPA high-priority sectors should treat this as a direct hit on their evidence chain and act now. 

Key Takeaways 

  • On August 5, 2026, China’s Ministry of Commerce (MOFCOM) issued Order No. 2 of 2026 placing six U.S. entities on its countermeasure list under the Anti-Foreign Sanctions Law: Applied DNA Sciences, Inc.; Stratum Reservoir, LLC; Altana Technologies, Inc.; Responsible Business Alliance; Verite Group, Inc.; and Human Rights in China. 
  • The countermeasure prohibits organizations and individuals within China from engaging in relevant transactions, cooperation, and other activities with the six entities, effective August 5, 2026. The order imposes no asset freeze and no entry ban. 
  • MOFCOM’s spokesperson tied the package to the July 31, 2026 addition of 43 entities to the UFLPA Entity List, published in the Federal Register on August 3, 2026, which brought the list to 187 entities. 
  • The listed entities include providers of DNA tagging, […]
By |2026-09-09T12:19:28-04:00September 9, 2026|China, Forced Labor, Supply Chain, U.S. Customs and Border Protection (CBP), U.S. Department of Homeland Security (DHS)|Comments Off on China Blacklists Six U.S. Supply Chain Tracing Providers: What UFLPA Importers Need to Know
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Breaking Trade News: CBP Supply Chain ANPRM, Trade Crimes Bill Passes House

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

Customs and Border Protection (CBP)      

  • CBP published an advance notice of proposed rulemaking on September 2, 2026 that would give the agency visibility into every party in an import supply chain, from the foreign factory to the final delivery address.  
  • Via CSMS message, CBP released guidance on the implementation of Section 232 duties on imports of unmanned aircraft systems that took effect September 3, 2026.      
  • CBP will hold its quarterly Commercial Customs Operations Advisory Committee (COAC) meeting on Sept. 23, 2026. 
  • CBP said that starting September 19, 2026, ACE will reject entries on which copper smelt and cast origin aren’t reported.  

Courts 

  • Diaz Trade Law’s David Craven filed a motion with the CIT on behalf of importers Aditya Birla Chemicals and Pack Perfect requesting that the court issue an order saying that all antidumping duty and countervailing duty entries that were subject to IEEPA tariffs must ultimately be refunded. The trade court scheduled an oral argument for the case on Sept. 15. 
  • A group of 24 states filed a brief with the U.S. Court of Appeals […]
By |2026-09-04T16:17:35-04:00September 4, 2026|news, Snapshot|Comments Off on Breaking Trade News: CBP Supply Chain ANPRM, Trade Crimes Bill Passes House
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White House Releases National Security Science & Technology Strategy: What It Signals for CFIUS, Outbound Investment, and Export Controls 

As mandated by Section 10612 of the CHIPS and Science Act, the White House Office of Science and Technology Policy (OSTP) issued the National Security Science and Technology Strategy (NSSTS), which implements the S&T priorities of the 2025 National Security Strategy. While framed as a technology strategy, the NSSTS previews concrete near-term action on CFIUS, outbound investment, export controls, and federal research security — direct touchpoints for clients in cross-border investment, controlled technology, and federally funded R&D. 

Key Takeaways 

  • CFIUS’ scope is set to expand. The Administration will seek authority, in consultation with Congress, to monitor high-risk “greenfield” investments and to expand CFIUS’s critical-technology jurisdiction, while continuing to calibrate scrutiny to an investor’s “verifiable distance” from adversary-linked actors under the America First Investment Policy’s allied fast-track approach. 
  • Outbound investment restrictions will broaden. Treasury will refine and likely expand the Outbound Investment Security Program (Comprehensive Outbound Investment National Security Act of 2025) beyond its current scope – AI, quantum, semiconductors, supercomputers, and hypersonics – to reach additional sectors implicated by China’s military-civil fusion strategy. Although the current NSSTS did not reference other countries by name, the strategy will likely be implemented in a way that circumvents particular investments in Hong Kong, Macau, Cuba, Iran, Russia, Iran, and North Korea – in line with President Trump’s “America-first investment policy,” published in February 2025. 
  • Export controls: deregulation and new restrictions in parallel. BIS is streamlining select controls (e.g., a […]
By |2026-09-03T12:13:54-04:00September 3, 2026|CFIUS, EAR, Export, U.S. Bureau of Industry and Security (BIS), U.S. Department of Treasury, Uncategorized|Comments Off on White House Releases National Security Science & Technology Strategy: What It Signals for CFIUS, Outbound Investment, and Export Controls 
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Wood Packaging Material Violations: What to Do When CBP Issues an EAN 

This article explains what an importer should do in the first 24 hours after CBP issues an Emergency Action Notification (EAN) for non-compliant wood packaging material (WPM), how CBP calculates and mitigates the penalties that follow, and how the new APHIS-approved shredder-hammermill treatment can save the underlying cargo. It matters because a WPM penalty is assessed at the full domestic value of the merchandise, requires no pre-penalty notice, and can be issued even when the importer fully complies with the EAN. The decisions made before the cargo leaves the port determine how much of that exposure survives. 

KEY TAKEAWAYS 

  • An Emergency Action Notification (EAN) for non-compliant wood packaging material is not the end of the matter. It is the start of a penalty file. Call counsel the day it arrives, not the day the penalty notice arrives. 
  • CBP penalties for WPM violations are assessed at the domestic value of the merchandise under 19 U.S.C. § 1595a(b), with no pre-penalty notice required. A single violation is enough. The old five-violation threshold was eliminated in 2017. 
  • Mitigation is real but shrinks fast: 1 to 10 percent of the penalty on a first violation, 10 to 25 percent on a second, and a 25 percent floor on the third. Documented immediate remediation and cooperation are what move you toward the low end. 
  • Shredder-hammermilling is now an APHIS-approved treatment for non-compliant […]
By |2026-09-03T12:09:16-04:00September 3, 2026|Enforcement, Import, Penalty, U.S. Customs and Border Protection (CBP), U.S. Department of Agriculture (USDA), Uncategorized|Comments Off on Wood Packaging Material Violations: What to Do When CBP Issues an EAN 
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