On October 28, 2026, President Trump issued a proclamation titled “Adjusting Imports of Robotics, Industrial Machinery, and Their Parts and Components into the United States,” directing the Secretary of Commerce and the United States Trade Representative (USTR) to jointly pursue negotiations with trading partners to address the national security threat posed by these imports. Rather
DHS Updates UFLPA Entity List with Three Companies Engaged in Genetics Testing
On October 28, 2026, the Department of Homeland Security (DHS) announced the addition of three Chinese companies to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List. Effective October 29, 2026, U.S. Customs and Border Protection (CBP) will apply a rebuttable presumption that goods produced in whole or part by these three companies are made
Treasury Issues Notice of Proposed Rulemaking to Expand Outbound Investment Security Program
On October 26, 2026, the Department of the Treasury (“Treasury”) issued a Notice of Proposed Rulemaking (“NPR”) that would implement Subtitle C of the Comprehensive Outbound Investment National Security Act (“COINS Act”) to expand the coverage of the existing Outbound Investment Security Program (“OISP”) (see Update of October 8, 2026).
The OISP came
President Trump Opts for Negotiations, Not Tariffs, in Section 232 Wind Turbine Investigation
On October 22, 2026, President Donald Trump issued a Proclamation announcing that the investigation into the effects of imports of wind turbines and their parts and components on the national security of the United States under Section 232 of the Trade Expansion Act of 1962 has concluded. The investigation was initiated in August 2025 by
U.S. Importer of Canadian Products Challenges Section 338 Tariffs
On October 20, 2026, Gellert Global Group Corp. (Gellert) filed a complaint in in the U.S. Court of International Trade (CIT) challenging the 50% ad valorem tariffs placed on Canadian products by President Donald Trump under Section 338 of the Tariff Act of 1930, 19 U.S.C. § 1338. The complaint seeks class action status for
CBP Delays Implementation Date of De Minimis Exemption for Mail Shipments
On October 14, 2026, U.S. Customs and Border Protection (CBP) announced the extension of the compliance date for new informal entry procedures for international mail from October 22, 2026, to January 20, 2027. In a press release, CBP states that the 90-day extension “provides importers, brokers, and logistics providers additional time to update their
OFAC Targets Iran’s Aviation and Rail Sectors for Additional Sanctions
On October 1, 2026, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued new sectoral sanctions determinations targeting Iran’s automotive and rail sectors. These determinations authorize OFAC to sanction any entity or individual operating in these sectors. OFAC stated that Iran’s automotive sector is the country’s largest economic sector outside of oil and gas
DDTC Issues Proposed Rule to Remove Certain Items from the U.S. Munitions List
On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule in the Federal Register that would remove certain items from the U.S. Munitions List (USML). This proposed rule is in furtherance of President Donald Trump’s April 9, 2025, Executive Order 14268, “Reforming Foreign Defense Sales to
DDTC Removes Syria from ITAR Section 126.1 Policy of Denial
On September 30, 2026, the Department of State’s Directorate of Defense Trade Controls (DDTC) issued a final rule in the Federal Register that, effective October 1, 2026, revises the International Traffic in Arms Regulations (ITAR) to remove Syria from the list of countries in ITAR § 126.1 for which there is a policy of denial
CBP Issues Withhold Release Orders on Two Indonesian Palm Oil Producers
On September 29, 2026, Customs and Border Protection (CBP) issued two Withhold Release Orders (WROs) against palm oil and its derivative products produced by Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP) in Indonesia. Both WROs are the result of a CBP review that MAR and HIP use forced labor to produce palm oil