On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced in a Notice of Action its final action in the Section 301 investigation of 60 economies for “their failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor.” Under Section 301 of the Tariff Act
Aaron C. Mandelbaum
Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.
USTR Directs ITC to Launch Section 201 Investigation into Lamb Meat Imports
The Office of the U.S. Trade Representative (“USTR”) asked the U.S. International Trade Commission (“ITC”) on July 13, 2026, to launch a Section 201 global safeguard investigation into lamb meat imports after domestic sheep producers filed a petition last year with the USTR.
In his letter to the ITC, USTR Jamieson Greer called on the…
President Trump Announces Initiation of Recission of Syria’s Designation as a State Sponsor of Terrorism
On July 8, 2026, on the sidelines of the NATO summit, President Donald Trump announced his intention to remove Syria from the State Sponsor of Terrorism list, a significant move that would assist Syria’s efforts to re-engage in the global political and financial systems and rebuild the country after more than a decade of civil…
OFAC Reinstates U.S. Sanctions Related to Sales of Iranian Oil
On July 7, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked Iran-related General License X and issued Iran-related General License X1, for the “Revocation and Wind Down of June 21, 2026 Authorization for the Production, Delivery and Sale of Crude Oil, Petrochemical Products, and Petroleum Products of Iranian Origin.”…
CIT Issues Order Addressing China Section 301 Cases in Light of Supreme Court Denial of Certiorari
On July 6, 2026, the U.S. Court of International Trade (CIT) issued an Order announcing resolution of all pending but stayed China Section 301 cases because of the June 15, 2026 U.S. Supreme Court decision denying the petition for a writ of certiorari in HMTX Industries LLC v. United States. To facilitate resolution of…
CBP Issues Interim Final Rules Indefinitely Suspending the De Minimis Exemption for Imports
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
UPDATE: On July 7, 2026, this Iran-related General License X was revoked by OFAC and any activities under this general license must be wound down no later than July 17, 20026. See Thompson Hine Update of July 8, 2026 for additional details.
On June 22, 2026, the Department of the Treasury’s Office of Foreign Assets…
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…
