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CBP Proposes Bonds and Earlier Filing for Low-Value Informal Entries: Comments Due December 7 

U.S. Customs and Border Protection (CBP) has issued a Notice of Proposed Rulemaking (NPRM) for Low-Value Shipments that would change informal entry requirements for shipments valued at $2,500 or less, including shipments arriving through international mail. The proposal would add a bond requirement for informal entries, move the Type 11 filing deadline earlier, and create a new electronic Entry Type 13 for mail. Importers, e-commerce sellers, licensed customs brokers, and carriers that handle low-value shipments are affected, and comments are due December 7, 2026. 

Key Takeaways 

  • CBP proposes that all Type 11 (informal) and new Type 13 (informal mail) entry filers obtain a basic importation and entry bond, single transaction or continuous, before release. 
  • The proposed Type 11 filing deadline moves from “within 15 calendar days after landing,” to “upon or before the date of importation”, and Type 11 entries would be filed electronically. 
  • A new Entry Type 13 for international mail of $2,500 or less would be filed electronically by the owner or purchaser in ACE or by a licensed customs broker. 
  • Carriers filing inward manifests would report the mail tracking number, and unentered mail of $2,500 or less would be considered abandoned after 15 days. 
  • Comments are due December 7, 2026, under docket USCBP-2026-0298 on regulations.gov. 

Low-Value Shipments Face New Entry Requirements 

CBP […]

By |2026-10-09T11:49:46-04:00October 9, 2026|ACE, Customs Broker, Import, U.S. Customs and Border Protection (CBP)|0 Comments
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BIS Announces $2 Million Settlement with Lambda Research Corporation for 66 Export Control Violations 

On October 2, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a $2 million administrative settlement with Massachusetts-based Lambda Research Corporation involving 66 alleged violations of the Export Administration Regulations (EAR). The case involved exports of optical and illumination design software, automatic software updates, and transactions with parties on the Entity List and Unverified List. 

Key Takeaways 

  • EAR99 does not mean unrestricted. Even software classified as EAR99 may require an export license when the recipient is on the BIS Entity List. 
  • Automatic software updates can constitute exports. BIS charged Lambda with violations involving software updates transmitted to restricted parties after their addition to the Entity List. 
  • Restricted-party screening must be ongoing. A customer who was not restricted when a transaction began may become subject to licensing requirements later. 
  • Distributors do not eliminate export compliance obligations. Exporters must evaluate the actual end users of their products, including transactions conducted through intermediaries. 
  • The Unverified List creates additional compliance requirements. Certain transactions involving Unverified List parties require a UVL statement even when an export license is not otherwise required. 
  • Informal compliance efforts are insufficient. BIS cited Lambda’s lack of written export compliance procedures, employee training, and designated compliance personnel. 
  • Voluntary self-disclosure does not eliminate penalties. […]
By |2026-10-09T11:34:59-04:00October 9, 2026|EAR, Enforcement, Export, Penalty, U.S. Bureau of Industry and Security (BIS)|0 Comments
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Commerce Restricts Polysilicon Stockpiling Ahead of December 4 Section 232 Tariffs: What Importers and Customs Brokers Need to Know 

On September 24, 2026, the Bureau of Industry and Security (BIS) published a temporary final rule at 91 FR 60505 establishing how the Department of Commerce will identify and restrict importers that stockpile polysilicon and polysilicon derivatives (Polysilicon Products) before the Section 232 minimum import prices and tariffs under Proclamation 11052 take effect on December 4, 2026. The rule caps weekly import volumes for new importers of record, creates a waiver process, and reminds customs brokers of their enforcement exposure. Importers of polysilicon, the covered HTSUS 3818 products, solar cells, and solar modules, along with the customs brokers that file their entries, are affected now. 

Key Takeaways 

  • BIS published a temporary final rule at 91 FR 60505 on September 24, 2026. It is effective September 22, 2026, through December 3, 2026. 
  • Commerce is monitoring existing importers of record (IORs). An IOR that Commerce determines is importing Polysilicon Products in volumes substantially greater than its historic averages will be prohibited from making further entries of those products prior to December 4, 2026. 
  • New IORs that registered with CBP on or after August 6, 2026, are prohibited from importing above fixed weekly quantities by HTSUS subheading, absent Commerce approval. 
  • Prohibited or restricted companies may apply to Commerce for a waiver at Polysilicon232@bis.doc.gov. Commerce intends to respond within 14 days of receipt. 
By |2026-10-06T08:14:34-04:00October 6, 2026|Customs Broker, Import, Tariffs, U.S. Bureau of Industry and Security (BIS), U.S. Customs and Border Protection (CBP)|0 Comments
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CBP Issues Palm Oil WROs Against Two Indonesian Producers: What Importers Need to Know 

U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders against palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki and Hardaya Inti Plantation, directing detention of that merchandise at all U.S. ports of entry. The orders reach any importer whose palm oil or palm-derived inputs trace to either producer. Importers of food, personal care, cleanings, and industrial products should confirm whether either company sits anywhere in their supply chain. 

KEY TAKEAWAYS 

  • CBP issued two Withhold Release Orders (WROs) covering palm oil and its derivative products produced in Indonesia by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP). CBP stated that, effective immediately, personnel at all U.S. ports of entry will detain that merchandise. 
  • CBP cited nine International Labour Organization (ILO) forced labor indicators at MAR and seven at HIP. With this action, CBP stated it now oversees and enforces 60 WROs and eight Findings under 19 U.S.C. § 1307. 
  • Under 19 C.F.R. § 12.43, an importer contesting a WRO detention submits tailored certificates of origin from the foreign seller or owner and a detailed statement from the ultimate consignee within 3 months after the date the article was imported stating that no forced labor was used in making the product. DTL’s read: that record takes longer to build than the deadline allows if the work starts at detention. 

What CBP Announced

According to CBP’s […]

By |2026-10-05T08:24:41-04:00October 5, 2026|Enforcement, Forced Labor, Import, Supply Chain, U.S. Customs and Border Protection (CBP)|0 Comments
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CBP Seized My Goods: What Happens Next and What Are My Options?

Receiving notice that U.S. Customs and Border Protection (CBP) has seized your merchandise can bring an import transaction to an immediate halt. More importantly, a seizure means CBP believes there is a legal basis to take possession of the merchandise and potentially pursue forfeiture. 

A CBP seizure is not the same as a routine delay or detention at the border. Once merchandise has been seized, importers face specific procedures and deadlines for challenging the seizure or requesting relief. How you respond can affect whether the goods are released, forfeited, or become the subject of additional enforcement action. 

If CBP has seized your shipment, understanding why the goods were seized, what your Notice of Seizure says, and what options are available should be your first priorities. 

Why Does CBP Seize Imported Goods? 

CBP is responsible for enforcing hundreds of laws and regulations governing merchandise entering the United States. Merchandise may be seized when CBP determines that the goods were imported, entered, or introduced contrary to law. 

Common reasons for CBP seizures include: 

  • Counterfeit goods and intellectual property rights violations; 
  • Prohibited or restricted merchandise; 
  • Undeclared or improperly declared merchandise; 
  • False statements concerning country of origin, value, classification, or other entry information; 
  • Attempts to evade customs duties; 
  • Certain violations involving antidumping […]
By |2026-10-02T13:12:17-04:00October 2, 2026|Enforcement, Import, Penalty, U.S. Customs and Border Protection (CBP)|0 Comments
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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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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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$5.15 Million Settlement Highlights Growing Customs Enforcement Under the False Claims Act

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 […]
By |2026-08-10T12:28:34-04:00August 10, 2026|Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP)|Comments Off on $5.15 Million Settlement Highlights Growing Customs Enforcement Under the False Claims Act
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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 |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 on DOJ and DHS Publish Comprehensive Trade Fraud Enforcement Guide: What Importers Need to Know 
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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 |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 on IEEPA Tariff Refund Update: CIT Will Order Reliquidation of Some Finally Liquidated Entries 
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