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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.

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.

Supply Chain Visibility Is Becoming a National Security Issue

Perhaps no […]

By Jennifer Diaz|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

$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 Jennifer Diaz|2026-08-10T12:28:34-04:00August 10, 2026|Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP)|Comments Off

CBP Issues Two New WROs Against Jordan Garment Factories: What Importers Need to Know

Why importers who diversified out of China to FTA partners are now squarely in CBP’s forced-labor crosshairs — and the five-step package you need before your first detention notice.

Short summary: CBP just issued two Withhold Release Orders against garment factories in Jordan, a U.S. free trade agreement partner. If you diversified out of China, thinking that solved your forced-labor exposure, this action is your wake-up call. Duty-free status is not a compliance shield. For apparel and textile importers, the window to build a defensible admissibility package is now, before a detention notice arrives.

On June 23, 2026, U.S. Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against garments produced by Needle Craft Ltd. and Casual Wear Apparel LLC — two garment-manufacturing factories in Jordan. Effective immediately, CBP will detain all garments produced by these two factories at every U.S. port of entry. These are the fifth and sixth WROs of fiscal year 2026, and they push CBP’s active enforcement docket to 58 WROs and eight Findings under 19 U.S.C. § 1307.

If you read only one sentence of this post, read this one: the country you moved your sourcing to to escape China-related forced-labor risk is not safe by virtue of being a U.S. trade-preference partner. Jordan Apparel enters the United States duty-free under the U.S.–Jordan Free Trade Agreement and […]

By Jennifer Diaz|2026-06-23T12:22:55-04:00June 23, 2026|Forced Labor|Comments Off

Forced Labor Enforcement Just Crossed a Border: What CBP’s Serbia Copper WRO Means for Your Supply Chain

Key Takeaways

CBP continues to chase the company, not just the country. Zijin’s parent was already on the UFLPA Entity List for forced labor in China; this Withhold Release Order (WRO) hits its Serbian copper operation on a separate evidentiary basis. Moving production to a “friendly” country does not move you out of CBP’s reach.
Copper just joined the enforcement map. Forced-labor detentions are no longer concentrated in apparel, solar, and cotton. If you import copper—or anything containing it—your supply chain is now in scope, and most copper-reliant importers have done zero forced-labor due diligence.
The burden is on you, and it lands the moment your shipment is detained. Under a WRO, there is no notice and no grace period. You either prove your goods are clean by detailed documentary evidence, or you export or destroy them.

On June 16, 2026, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order against copper and copper products manufactured in Serbia by Serbia Zijin Copper D.O.O.—the fourth WRO of Fiscal Year 2026 and the second targeting a Serbian operation in roughly six months. Effective immediately, CBP personnel at every U.S. port of entry will detain shipments of copper and copper products from this company.

If you read that as another distant enforcement headline, you are missing the part that should concern you. This […]

By Jennifer Diaz|2026-06-19T13:16:26-04:00June 19, 2026|Enforcement, Forced Labor, Supply Chain, U.S. Customs and Border Protection (CBP)|Comments Off

Navigating IEEPA Tariff Refunds: Legal and Compliance Considerations

Editor’s Note: The recent Supreme Court decision invalidating tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has opened the door to tariff refunds for importers. However, amid the newly implemented administrative process for refunds and heightened enforcement scrutiny, importers must do more than simply file a claim.

Importers pursuing refunds of tariffs imposed under IEEPA must navigate a developing framework that blends judicial relief with a newly established administrative process. U.S. Customs and Border Protection (CBP) has implemented the Consolidated Administration and Processing of Entries (CAPE) as the primary mechanism for submitting refund claims following the Supreme Court’s decision and subsequent orders from the U.S. Court of International Trade (CIT). While CAPE provides a pathway to recovery, it is limited in scope, phased in its application, and subject to ongoing legal and procedural uncertainty. Against this backdrop, importers must approach refund claims with a coordinated strategy that accounts for litigation posture, operational readiness, and heightened compliance expectations.

Requesting Refunds through CAPE

Following the Supreme Court decision and subsequent CIT orders, CBP developed the Consolidated Administration and Processing of Entries (CAPE) – the agency’s official process for handling IEEPA refund claims.

CBP launched Phase 1 of CAPE on April 20, 2026. The following entry types are eligible for refunds […]

By Jennifer Diaz|2026-06-17T10:43:04-04:00June 17, 2026|Bloomberg, Bloomberg Import|Comments Off

CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.

On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference.

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position.

The one-line summary every importer needs

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

By Jennifer Diaz|2026-06-17T10:00:55-04:00June 17, 2026|CTPAT, Enforcement, Forced Labor, Import, International Trade, U.S. Customs and Border Protection (CBP)|Comments Off

Three Enforcement Actions, One Message: Trade Violations Are Serious Crimes

Learn more about this topic in our upcoming webinar: From Error to Action: Filing a Prior Disclosure with CBP

As tariffs climb and global trade becomes more complex, a growing number of importers are testing the limits, or outright breaking the law, to reduce or avoid duty payments and other compliance costs. U.S. enforcement agencies, including Customs and Border Protection (CBP) and the Department of Justice (DOJ), have made it clear that customs fraud will not be tolerated and is a top enforcement priority. Three recent cases illustrate the new reality for enforcement.

1. Undervaluation and the False Claims Act: $2.1 Million Settlement

An importer of fitness equipment agreed to pay $2.1 million to resolve allegations under the False Claims Act that it knowingly undervalued imported goods.

According to the government, the company knowingly declared artificially low values on its imports in order to reduce tariff obligations. The company also failed to include the cost of computer tablets incorporated into packaged equipment.

The settlement also resolves a qui tam False Claims Act case brought by a whistleblower, Mr. Greg Dahlstrom. Dahlstrom will receive $420,000 of the proceeds from the settlement.

2. Importing Precursor Chemicals: Possible Life Sentence

On April 27, 2026, the United States Attorney for the Southern District of New York announced the unsealing of an indictment charging two Chinese nationals with importing a methamphetamine precursor chemical into the United States with the intent […]

By Jennifer Diaz|2026-05-02T10:01:13-04:00May 2, 2026|Enforcement|Comments Off

ICYMI: Electronics Company Pays $11.8M to Resolve Duty Evasion Allegations

The Department of Justice announced that Harman International Industries, Inc., an audio electronics company, agreed to pay $11.8M to settle allegations of evading duties on goods made of aluminum from China.

What Happened

For a period of over ten years, from June 2011 to March 2023, Harman knowingly imported heat sinks that contained extruded aluminum from China without paying the required antidumping and countervailing duties (AD/CVD).

The settlement also reveals that when Harman discovered its failure to pay AD/CVD, the company concealed this fact and decided not to disclose it to the U.S. government.

This case arose from a whistleblower lawsuit filed under the False Claims Act, which permits private parties to file suit on behalf of the United States for false claims and share in a portion of the government’s recovery. The whistleblower in this case will receive over $2M of the settlement proceeds.

Enforcement is a Top Priority for the U.S. Government

High tariffs in the current trade environment have created a higher incentive to cheat. The U.S. government has made clear that enforcing customs laws is a top priority.

For example, on May 12, 2025, Matthew Galeotti, the Head of the U.S. Department of Justice’s Criminal Division, sent a memo to all criminal division personnel highlighting the focus areas of the division for white-collar crime.

The memo included a […]