On September 15, 2026, U.S. Customs and Border Protection (“CBP”) announced in a declaration filed in the U.S. Court of International Trade (“CIT”) that Phase 3 of the Consolidated Administration and Processing of Entries (“CAPE”), the system for administering refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), will deploy on October
CBP Seeks Comments on Implementation of Executive Order 14411
On September 2, 2026, U.S. Customs and Border Protection (CBP) published a notice seeking comments by December 1, 2026, on its implementation of several provisions of Executive Order 14411 (“EO 14411”), which mandates the collection of foreign export documentation, the expansion of the requirements for the Customs Trade Partnership Against Terrorism (CTPAT) program, and the
New BIS Rule Restricts Export of Certain Critical Minerals
The Bureau of Industry and Security (“BIS”) has published a temporary final rule to restrict the export of black mass and tungsten waste and scrap without a license. The agency defines black mass as shredded lithium-ion battery scrap that contains cathode material, anode material or other “residual battery cell materials.” The BIS will restrict export
Trump Administration Imposes Section 338 Tariffs on Certain Imports from Canada
On July 20, 2026, President Donald Trump issued three Proclamations pursuant to Section 338 of the Tariff Act of 1930 imposing 50% tariffs on imports of certain Canadian goods. The Proclamations, “Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Dairy,” “Imposing Additional Duties
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
Trump Administration Appeals CIT’s IEEPA Tariff Refund Order
On June 2, 2026, the U.S. Department of Justice (“DOJ”) on behalf of the Trump administration formally appealed at the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”) the order of Senior Judge Richard Eaton of the U.S. Court of International Trade (“CIT”) compelling U.S. Customs and Border Protection (“CBP”) to refund importers
OFAC Publishes Introductory Guide
On June 1, 2026, the Office of Foreign Assets Control (OFAC), an office of the Department of Treasury, published an “Introduction to the Office of Foreign Assets Control.” OFAC administers and enforces economic sanctions against targeted foreign jurisdictions and regimes, as well as individuals and entities engaging in harmful activity, such as terrorists
CIT Panel Strikes Down Trump Administration’s Section 122 Tariffs
In a 2-1 decision on May 7, 2026, a three-judge U.S. Court of International Trade (“CIT”) panel struck down the Trump administration’s implementation of Section 122 tariffs (see Update of February 23, 2026).
The 10% tariff on a wide range of imported goods, the panel reasoned, extended beyond President Trump’s power to address
USTR Launches Section 301 Investigations into Forced Labor Practices
On March 12, 2026, the U.S. Trade Representative (USTR) announced that it was launching Section 301 investigations into 60 trade partners to determine whether they have been engaged in forced labor practices. The investigations, to be conducted pursuant to Section 301of the Trade Act of 1974, include China, the European Union, India, and Mexico. A
USTR Releases President Trump’s 2026 Trade Policy Agenda and 2025 Annual Report
On March 2, 2026, the Office of the U.S. Trade Representative (USTR) delivered President Donald Trump’s 2026 Trade Policy Agenda and 2025 Annual Report to Congress. This year’s trade agenda seeks to promote U.S. interests abroad and reduce trade deficits by pursuing trade deals with other countries and strengthening domestic manufacturing.