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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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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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BIS End-Use Checks: What Happens When an Export Control Officer Calls Your Customer 

BIS has published a plain-language FAQ on its End-Use Check program, the on-site visits its Export Control Officers conduct at foreign consignees and end users of U.S.-origin items. This article explains what those visits are, what your foreign customer will be asked to produce, the statutory and regulatory authority behind the request, and the consequences when a check cannot be completed. It matters because the penalty for a failed check falls on the exporter’s ability to ship, not only on the foreign party being visited. 

Key Takeaways 

  • An End-Use Check (EUC) is BIS verifying, on site and overseas, that your foreign customer is who it says it is and used your items the way the license or the EAR required. 
  • A failed or incomplete check does not need a finding of wrongdoing to hurt you. The customer can land on the Unverified List, license exceptions disappear, and every shipment then requires a UVL statement. 
  • Since October 2022, a check that stays incomplete for 60 days after Unverified List placement, because a host government blocks it, triggers Entity List proceedings. 
  • The exporter’s exposure is set before the visit ever happens: by the accuracy of the license application, the quality of the paper trail, and whether the foreign party was told what to expect. 
  • Diaz Trade Law prepares exporters […]
By |2026-09-03T12:03:09-04:00September 3, 2026|Best Practices, EAR, Enforcement, Export, U.S. Bureau of Industry and Security (BIS)|Comments Off on BIS End-Use Checks: What Happens When an Export Control Officer Calls Your Customer 
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FTC Cracks Down on False “Made in the USA” Claims 

The Federal Trade Commission (FTC) recently announced law enforcement actions involving three companies that falsely claimed that their products were made in the United States.  

Made in the USA

The “Made in the USA” labeling rules were enacted to prevent deceptive advertising and ensure customers can make informed purchasing choices. The concept of labeling products with the correct country of origin dates all the way back to the McKinley Tariff Act in 1890, and Congress and federal agencies have updated “Made in the USA” rules over the years.  

FTC Jurisdiction 

The FTC is charged with preventing deception and unfairness in the marketplace. Under the FTC Act, the Commission may bring legal action against “false or misleading claims that a product is of U.S. origin”. The agency is authorized to issue a civil penalty of up to $40,654 per violation. 

The FTC has issued guidance on complying with the “Made in the USA” standard, most recently in 2021. View the latest guidance here.

When Can I Say Made in the USA? 

For a product to be considered as “Made in the USA” without qualification, that product must be “all or virtually all” made in the U.S. How the Commission determines whether a product is “all or virtually all” made in the U.S. is by looking at whether there was “a ‘reasonable basis’ to support the claim at the time it is made”. To prove […]

By |2026-06-05T11:20:06-04:00June 5, 2026|Best Practices, Enforcement, Import, International Trade, Labeling, U.S. Federal Trade Commission (FTC)|Comments Off on FTC Cracks Down on False “Made in the USA” Claims 
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FDA Announces One-Day Inspection Pilot

The U.S. Food and Drug Administration (FDA) announced that it is piloting one-day inspectional assessments. These assessments will be shorter, more focused, and will complement existing standard FDA inspections.  

Shorter Inspections, More Coverage 

Launched in April 2026, the pilot is part of a broader initiative to make the agency’s inspectional resources more targeted and efficient. The new assessments will allow for broader coverage, enabling the agency to assess more facilities without compromising regulatory rigor. 

The pilot is being conducted across multiple FDA inspectorates, including human and animal foods, biologics, medical products, and clinical research programs. Facilities are selected using risk-based criteria such as:  

  • Product type 
  • Prior inspection outcomes 
  • Operational characteristics  

As of late April 2026, the FDA has completed approximately 46 one-day assessments.  

The agency made clear that one-day inspectional assessments are not intended to replace standard FDA inspections. Instead, they are meant to provide an additional tool to the agency’s enforcement approach. The ‘one-day’ framework is also flexible – investigators retain authority to expand the scope or duration of an assessment if warranted.  

The pilot will continue through fiscal year 2026. The FDA is currently developing evaluation metrics to assess effectiveness, including inspection duration, escalation rates, and the utility of findings in informing risk-based decision-making. 

What Facility Owners and Operators Should Do 

Facility owners and operators should remain ready […]

By |2026-05-26T12:37:23-04:00May 26, 2026|Best Practices, Cosmetics, Enforcement, Food, Import, Medical Devices, U.S. Food and Drug Administration (FDA)|Comments Off on FDA Announces One-Day Inspection Pilot
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CBP to Implement Fully Electronic Refund Processing via ACE

Effective February 6, 2026, CBP will process all refunds electronically. The agency will not issue any refunds by check unless a waiver has been approved.

Background

Historically, the majority of CBP refunds for the overpayment of duties, taxes, and fees were transmitted via paper checks issued by the U.S. Department of the Treasury. The issuance of electronic refunds via ACH has been available for some time, but opting-in for electronic refunds has been voluntary and limited in scope. In 2024 and 2025, approximately 30% of the refunds CBP issued annually were issued electronically.

On March 25, 2025, President Trump issued an Executive Order titled “Modernizing Payments To and From America’s Bank Accounts.” The order mandates the transition from paper checks to electronic payments for all Federal disbursements and receipts.

Electronic Refunds

To implement the electronic payments Executive Order, CBP published an Interim Final Rule on January 2, 2026, announcing that the agency will issue all refunds electronically (subject to certain exceptions under 31 CFR part 208) effective February 6, 2026. This rule applies to refunds issued to all importers, brokers, filers, sureties, service providers, facility operators, foreign trade zone operators, carriers,  and any designated third parties listed on CBP Form 4811. After this date, CBP will not issue any refunds by check, unless a waiver has been approved. Comments on the Interim Final Rule are due March 3, […]

By |2026-01-06T11:42:11-05:00January 6, 2026|ACE, Best Practices, Import, news, U.S. Customs and Border Protection (CBP)|Comments Off on CBP to Implement Fully Electronic Refund Processing via ACE
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Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead

For U.S. importers, the end of the year is a critical moment to evaluate compliance, correct issues, and prepare for the year ahead. With tariff changes, supply chain uncertainty, and an increased focus on enforcement, importers who take a proactive approach now will start the new year strong. Here’s a practical checklist for your year-end review.

1. Review Import Data for Accuracy

Begin with a thorough audit of your import data. Confirm that HTS classifications are correct and current, declared values accurately reflect your transactions, and country-of-origin determinations are well documented. Small mistakes can lead to large penalties.

2. Reassess Tariffs and Duty Exposure

Year-end is the ideal time to evaluate whether you are paying unnecessary duties and explore your options for tariff mitigation strategies. Consider what exclusions have changed, whether tariff engineering may reduce costs, or whether sourcing strategies should be updated. Many importers discover duty-saving opportunities simply by reassessing their tariff positions annually.

3. Strengthen Forced Labor Compliance

With UFLPA enforcement intensifying, importers must confirm that supplier information, ownership structures, and supply chain documentation are up to date. Now is the time to verify traceability records, refresh internal training, and assess whether high-risk suppliers require additional review.

4. Update Written Compliance Procedures

If your compliance manual or SOPs haven’t been updated this year, they’re likely outdated. Written processes should reflect current regulations, product updates, tariff changes, and internal workflow adjustments. CBP expects importers to document their […]

By |2025-12-22T09:04:16-05:00December 22, 2025|Best Practices, Import, International Trade, Pre-compliance, U.S. Customs and Border Protection (CBP)|Comments Off on Importer End-of-Year Checklist: How to Strengthen Compliance and Prepare for the Year Ahead
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Five Tips for SMEs Looking to Scale Wellness Brands in the US

DTL President Jennifer Diaz was featured in Santander Navigator! Read below or on Santander here.

Pre-planning and investing in regulatory compliance measures are key to success

The US is the most lucrative wellness market in the world – and for some small and medium-sized enterprises (SMEs) that produce supplements, the potential for growth and a bigger bottom line is difficult to ignore. 

And who would blame them? The US wellness sector is valued at US$2tn and is poised to continue growing, recording an average annual growth rate of 8.3% between 2019 and 2023, according to research by the Global Wellness Institute. 

In contrast, China’s market, ranked the second-largest in the world, trails at a more modest US$870bn, followed by Germany at $310bn.

However, rushing in without being fully compliant could result in products being blacklisted or seized at the border, says Jennifer Diaz, an attorney and founding partner at Miami-based Diaz Trade Law, which specializes in customs and US Food and Drug Administration (FDA) laws and compliance.

Here, Diaz offers her top five tips for new brands to stay compliant and off the FDA’s blacklist.

1. Know the regulators

One of the first steps for SMEs planning to import supplements into the US is to register with the FDA, as they are considered a food product, Diaz says.

Companies also need to designate […]

By |2025-06-17T08:40:04-04:00June 17, 2025|Best Practices, Import, Import Alert, International Business, International Trade, Labeling, Pre-compliance|Comments Off on Five Tips for SMEs Looking to Scale Wellness Brands in the US
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Trade Policy Is Changing Rapidly—Prepare Your Business for What’s Next

Trade policies are shifting faster than ever, with new tariffs, complicated regulations, and heavy enforcement measures impacting businesses across industries. If you are an importer, staying ahead of these changes is critical to maintaining smooth operations and avoiding financial setbacks.

With trade policy in flux, now is the time to ensure you are on solid footing by auditing your compliance strategies, reassessing tariff exposure, and ensuring your business is prepared for what’s ahead.

Audit Your Business Before CBP Does

Conducting an audit of your business to check for import compliance is an essential step to avoid costly penalties, thwart supply chain disruptions, and to minimize legal risk. An audit helps identify potential compliance gaps, ensuring that your existing business practices are in compliance with all applicable regulations. It also allows businesses to proactively address issues before they escalate.

Import Report Card

Diaz Trade Law can provide a customized ACE report card to give you an overview of your import compliance. The report contains a summary of your import transactions and identifies potential issues in your business’ processes as well as substantive recommendations to ensure compliance. The report provides information like:

  • Your last 5 years of import history
  • List of HTS’s you use
  • Total amounts paid in AD/CVD
  • Manufacturer ID’s reported to Customs
  • Inconsistencies in reporting
  • Total value of imports and duties paid by year
  • Review of countries of origin of your imported merchandise
  • Use of Free Trade Agreements
  • Your surety, bond coverage, and bond type
  • And more!

Lastly, the Report Card service […]

By |2025-02-28T07:10:19-05:00February 27, 2025|ACE, Best Practices, Import, U.S. Customs and Border Protection (CBP)|Comments Off on Trade Policy Is Changing Rapidly—Prepare Your Business for What’s Next
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Upcoming Training: CBP Regulations: Essential Practices for Import Success 

Join us in person at the World Trade Center Miami or on Zoom! Eligible for 3 CCS continuing education credits. 

 Many mistake the ease of importing to mean there is no liability or obligation on the part of the importer. However, if you import merchandise into the U.S., you may not realize, but, you are the responsible party! That means you have a duty to exercise “reasonable care” when importing.  

 What is reasonable care? Importers must conduct themselves as a reasonable importer would under the circumstance with respect to importing prior to entering goods into the United States. They must:  

  • Meet the standard to enter, classify and determine the value of imported goods 
  • Provide other information necessary to aid U.S. Customs and Border Protection (CBP) in properly assessing duties and collecting accurate statistics 
  • Determining whether other applicable legal standards and requirements have been met 

Read more about reasonable care in our Bloomberg Law article here. 

All importers should have a plan in place to navigate merchandise descriptions & classification, product valuation, country of origin, intellectual property rights, forced labor, quotas, requirements of other agencies, and more. 

In this presentation, our speakers will discuss how to comply with CBP’s vast laws and regulations. By the end of […]

By |2024-05-17T09:24:50-04:00May 17, 2024|Best Practices, Import|Comments Off on Upcoming Training: CBP Regulations: Essential Practices for Import Success 
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