On June 24, 2026, Customs and Border Protection (CBP) issued two Interim Final Rules indefinitely suspending the $800 de minimis duty exemption for all modes of importation of goods into the United States and establish a new informal entry and bonding process for international mail shipments. Public comments on these two interim rules are due
CBP Confirms June 29, 2026 IEEPA Tariff Refund Process Phase 2 Launch
On June 23, 2026, U.S. Customs and Border Protection (“CBP”) published Cargo Systems Messaging Service (“CSMS”) #69035485, confirming that Phase 2 of the process for refunding duties paid by importers of record under the International Emergency Economic Powers Act (“IEEPA”) will be deployed in the Automated Commercial Environment (“ACE”) Portal on June 29, 2026. …
OFAC Temporarily Lifts Certain Oil Sanctions Against Iran
On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Iran General License X, “Authorizing the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian-Origin through August 21, 2026.” This general license temporarily authorizes transactions prohibited by various listed OFAC regulations and presidential…
USTR Launches Section 301 Investigation into Germany’s Underpayment for Pharmaceutical Products
On June 18, 2026, the Office of the U.S. Trade Representative (USTR) announced that it was launching an investigation of Germany under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether persistent underpayment for innovative pharmaceutical products by Germany is unreasonable or discriminatory and burdens or restricts U.S. commerce.” …
New Executive Order Imposes Sweeping Customs Enforcement Reforms
On June 3, 2026, President Donald Trump signed an Executive Order, “Strengthening Customs Enforcement,” (Order) directing the U.S. Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to implement comprehensive reforms targeting importers of record, customs brokers, and international supply chains.
Key Provisions
Importer of Record Requirements. Within 180 days…
CBP Announces Phases 2 and 3 of the IEEPA Tariff Refund Process
At a show cause hearing before the U.S. Court of International Trade (“CIT”) on June 9, 2026, U.S. Customs and Border Protection (“CBP”) confirmed that it will roll out Phases 2 and 3 of its process for refunding duties paid by importers under the International Emergency Economic Powers Act (“IEEPA”) later this summer, with Phase…
U.S. Supreme Court Declines Review of China Section 301 Tariff Challenge
On June 15, 2026, the U.S. Supreme Court denied without comment the plaintiff group’s petition for certiorari in the test case for the China Section 301 tariff refund litigation (HMTX Industries LLC, et al. v. United States et al.). The petition sought review of the U.S. Court of Appeals for the Federal Circuit…
President Trump Modifies Section 232 Tariffs on Aluminum, Copper and Steel Imports
On June 1, 2026, President Donald Trump issued a Proclamation amending the rates, scope, and administration of the Section 232 tariff regimes for aluminum, steel, and copper and their derivative products. Section 232 of the Trade Expansion Act of 1962 authorizes the president to adjust duties on goods imported in quantities or under circumstances that…
USTR Proposes Tariffs of 10% to 12.5% in 60 Section 301 Forced Labor Investigations
On June 2, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination under Section 301 of the Trade Act of 1974 that certain acts, policies, and practices of 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor are unreasonable…
USTR in Brazil Section 301 Investigation Determination Proposes 25% Tariffs
On June 1, 2026, the Office of the U.S. Trade Representative (USTR) issued its determination that certain of Brazil’s acts, policies, and practices related to (i) digital trade and electronic payment services; (ii) unfair, preferential tariffs; (iii) anti-corruption enforcement; (iv) intellectual property protection; (v) ethanol market access; and (vi) illegal deforestation are unreasonable and burden…
