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 

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 

Understanding U.S. Customs Statute of Limitations Waivers: What Importers Need to Know 

When U.S. Customs and Border Protection (CBP) seeks to collect unpaid duties, taxes, or penalties, it generally must act within a defined window of time. But that window can be extended — and often is. Understanding how CBP statute of limitations (SOL) waivers work is essential for any importer navigating a customs audit or penalty proceeding. 

The Basic Rule: A Five-Year Limitation Period 

Under 19 U.S.C. § 1621, CBP has five years from the date of a violation to bring an action to recover unpaid duties or assess a penalty. This limitation period is designed to provide finality and protect importers from indefinite exposure. Once the period lapses, CBP’s ability to collect is generally barred. 

What Is a Statute of Limitations Waiver? 

A statute of limitations waiver is a written agreement by which an importer voluntarily extends CBP’s window to assess duties or penalties beyond the standard five-year period. CBP routinely requests these waivers during the course of audits, prior disclosures, and penalty proceedings, particularly when the matter is complex, ongoing, or near the limitations deadline. Standard SOL waivers generally provide CBP with two-year extensions of the SOL. During this time, the importer agrees not to exercise a statute of limitations defense for entries covered by the SOL waiver. 

Waivers are not automatic — they require the importer’s consent. However, in practice, refusing to sign is often not consequence-free. Refusing to sign forces CBP to expedite their […]

By |2026-06-01T10:38:59-04:00June 1, 2026|Uncategorized|Comments Off on Understanding U.S. Customs Statute of Limitations Waivers: What Importers Need to Know 

Breaking Trade News: Tariff Refunds May 11, New 232 Duty-Free Code, Forced Labor Hearing

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

Customs and Border Protection (CBP)   

  • The first reciprocal tariff refunds will be issued on or around May 11, according to a summary of a closed CIT conference between CBP and Judge Eaton.  
  • CBP officers in Chicago intercepted a monkey carcass and 125 pounds of prohibited ruminant meat. 
  • CBP issued an extension of emergency import restrictions on some archaeological and ethnological material from Afghanistan, effective April 28, 2026.  

Department of Commerce 

  • Commerce published a Federal Register notice adding a duty-free code in the HTSUS to cover goods subject to the Section 232 aluminum, steel, or copper tariff regimes that do not, in fact, contain these metals.  This new provision applies retroactively to April 6, 2026, 

United States Trade Representative (USTR)   

  • USTR held a Section 301 review hearing to determine what burden on U.S. commerce resulted from other countries failing to keep goods made with forced labor out of their markets. 
  • USTR is seeking public comments on recommendations to modernize the African Growth and Opportunity Act. Recommendations will focus […]
By |2026-05-01T09:22:49-04:00May 1, 2026|news, Snapshot, Uncategorized|Comments Off on Breaking Trade News: Tariff Refunds May 11, New 232 Duty-Free Code, Forced Labor Hearing

Breaking Trade News: IEEPA Tariff Case Update, DOL Launches Forced Labor Tools

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

Administration 

  • President Trump said that he will impose 50% tariffs on any country that sells military weapons to Iran. 
  • President Trump said that the U.S. will consider tariff and sanctions relief for Iran as it negotiates an end to the war.  

Customs and Border Protection (CBP) 

  • CBP released a new Harmonized System Update containing over 500 Automated Broker Interface records and 116 Harmonized Tariff Schedule records, including updates to 232 duties on aluminum, steel, and copper imports. 
  • CBP and the Consumer Product Safety Commission (CPSC) seized nearly 350,000 batteries that did not comply with child protective packaging standards. 

Court of International Trade (CIT) 

  • The lead plaintiff in the IEEPA refund case filed a notice of dismissal in its case at the CIT on April 6. Shortly after, Judge Eaton lifted the stay on another IEEPA refund case filed by importer Euro-Notions Florida, and reissued his order requiring CBP to pay IEEPA refunds for all unliquidated, not finally liquidated, and finally liquidated entries.  

Department of Labor (DOL) 

  • DOL
By |2026-04-22T16:39:55-04:00April 10, 2026|news, Snapshot, Uncategorized|Comments Off on Breaking Trade News: IEEPA Tariff Case Update, DOL Launches Forced Labor Tools

What Happened This Month in International Trade (February 2026) 

Supreme Court  

  • On February 20, 2026, the Supreme Court issued its opinion in Learning Resources, Inc., et al. v. Trump, ruling that IEEPA does not authorize the president to impose tariffs. 

Administration 

  • In response to the Supreme Court’s IEEPA ruling, President Trump issued a Proclamation imposing a 10% tariff on all goods under Section 122 of the Trade Act. The President also announced that he will be increasing it to the lawful maximum of 15%, but the effective date has not yet been set. 
  • President Trump signed an Executive Order continuing the suspension of duty-free de minimis treatment for all countries. 
  • The U.S. and Bangladesh released a joint statement on reciprocal trade. The U.S. is lowering the tariffs on Bangladeshi exports to 19% rather than the 20%. The U.S. will also establish a mechanism for a tariff rate quota for Bangladeshi textile and apparel imports, with goods coming in under the quota entering duty-free.  
  • President Trump announced on Truth Social that the U.S.’s trade deal with Japan is moving forward and that Japan will make its first set of investments under its $550 billion dollar commitment. 
By |2026-02-26T11:40:42-05:00February 26, 2026|news, Snapshot, Uncategorized|Comments Off on What Happened This Month in International Trade (February 2026) 

Breaking Trade News: Bangladesh Trade Deal, New 232 Guidance, UFLPA Dashboard Update

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

Administration  

  • Via a post on X, President Trump threatened to block the opening of a second bridge between Detroit and Windsor, Canada, “until the United States is fully compensated for everything we have given.”   
  • The Trump administration is reportedly considering tariff exemptions for major U.S. hyperscalers involved in construction of data centers needed for AI.
  • The U.S. and Bangladesh released a joint statement on reciprocal trade. The U.S. is lowering the tariffs on Bangladeshi exports to 19% rather than the 20%. The U.S. will also establish a mechanism for a tariff rate quota for Bangladeshi textile and apparel imports, with goods coming in under the quota entering duty-free. 

Customs and Border Protection (CBP)  

  • CBP’s base metals Center of Excellence and Expertise (CEE) released updated guidance for calculating steel, aluminum and copper content for Section 232 tariff purposes. 
  • UFLPA Enforcement Statistics Dashboard update: in the previous dashboard, a shipment was defined as an aggregate of the totality of goods subjected to UFLPA enforcement actions. Now, a shipment is now defined as an individual import transaction within a shipment entry or customs declaration. This […]
By |2026-02-12T11:46:51-05:00February 12, 2026|news, Snapshot, Uncategorized|Comments Off on Breaking Trade News: Bangladesh Trade Deal, New 232 Guidance, UFLPA Dashboard Update

Breaking Trade News: Trump Lowers India Tariffs, New UFLPA Dashboard

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

Administration 

  • Via a Truth Social Post, President Trump announced that after speaking with Indian Prime Minister Modi, the U.S. will drop reciprocal tariffs on India from 25% to 18%. 
  • During a meeting at the State Department, Vice President Vance said that the U.S. is seeking to organize a preferential trade zone for critical minerals. 

Customs and Border Protection (CBP) 

  • CBP announced a new and improved Uyghur Forced Labor Prevention Act (UFLPA) Enforcement Statistics Dashboard that provides a more detailed view of CBP’s enforcement actions.  
  • CBP issued a Withhold Release Order against coffee harvested by Finca Monte Grande, a Mexican coffee farm. Effective immediately, CBP at all U.S. ports of entry will detain coffee harvested by Finca Monte Grande. 

Department of Commerce 

  • A new antidumping and countervailing duty action has been filed against certain fatty acids from Indonesia and Malaysia. The allegation is that imports from Indonesia and Malaysia are unfairly subsidized and are being dumped. 

United States Trade Representative (USTR) 

  • U.S. Trade Representative Jamieson Greer joined Guatemala’s Minister of Economy Adriana Gabriela Garcia in signing the United States–Guatemala Agreement on […]
By |2026-02-06T15:05:58-05:00February 6, 2026|news, Snapshot, Uncategorized|Comments Off on Breaking Trade News: Trump Lowers India Tariffs, New UFLPA Dashboard

Breaking Trade News: Greenland Related Tariffs Withdrawn, CBP Rolls out Forced Labor Portal, New UFLPA Data

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

Administration 

  • President Trump withdrew his threat of tariffs on European allies over Greenland, citing a productive meeting with the Secretary General of NATO. 
  • In his speech at Davos, President Trump briefly touched on trade, mentioning the tariffs he imposed on Switzerland. 
  • In a speech at the White House, President Trump reiterated the Administration’s position that if the Supreme Court rules against them in the IEEPA case, they will use another tool to impose tariffs. The President suggested licenses as a possible alternative. 
  • Speaking to reporters, President Trump threatened a 200% tariff on French goods if French President Macron does not join Trump’s Board of Peace. The Board is expected to oversee the withdrawal of Israeli troops from Gaza. 

Customs and Border Protection (CBP) 

  • CBP released new data on UFLPA enforcement. In FY26 Q1 (Oct – Dec 2025), CBP flagged 721 shipments, valued at $69.16 million, for potential violations. 
  • CBP launched its new Forced Labor Portal. All review requests for shipments detained or excluded for forced labor enforcement must now be submitted through […]
By |2026-01-23T08:07:46-05:00January 23, 2026|news, Snapshot, Uncategorized|Comments Off on Breaking Trade News: Greenland Related Tariffs Withdrawn, CBP Rolls out Forced Labor Portal, New UFLPA Data

Breaking Trade News: New Trade Deals Announced, Government Shutdown Ends, OFAC Advisory

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

Congress

  • After 43 days of halted operations, the United States federal government reopened on November 12, 2025. The funding bill, approved by the Senate on November 10 and by the House later that day. The bill funds most government operations through January 30, 2026.
  • U.S. House Representative Raja Krishnamoorthi, the ranking member of the House Select Committee on China, wrote a letter to Commerce Secretary Howard Lutnick asking a series of pointed questions about the Administration’s decision to resume chip exports from Nexperia’s China factory.
  • All members of Arkansas’ Congressional delegation sent a letter to U.S. Trade Representative Jamieson Greer. The letter urges the agency to delay implementation of the new U.S.-EU trade deal until the EU revises its deforestation reporting requirements, claiming the requirements would harm American timber exports.

Administration 

  • President Trump announced trade deals with El Salvador, Argentina, Ecuador, and Guatemala. As part of the deal, the U.S. is eliminating 15% tariffs on Ecuadoran bananas and cocoa, and 10% tariffs on Guatemalan coffee and Argentinian beef.
  • In an interview with Fox News, President Trump said that there will be upcoming “surgical” reductions to reciprocal tariffs. When […]
By |2025-11-14T08:28:07-05:00November 14, 2025|news, Snapshot, Uncategorized|Comments Off on Breaking Trade News: New Trade Deals Announced, Government Shutdown Ends, OFAC Advisory
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