Customs/CBP

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On January 2, 2026, U.S. Customs and Border Protection (“CBP”), an agency within the U.S. Department of Homeland Security, published an interim final rule announcing it will move to an all-electronic refund system beginning February 6, 2026.  As a result, the agency will no longer issue paper checks for refunds—including tariff refunds—absent a waiver approved…

  • Hundreds of new cases have been filed at the U.S. Court of International Trade (“CIT”) since the November 5, 2025 oral arguments at the U.S. Supreme Court (“SCOTUS”) in the appeal challenging the legality of the International Emergency Economic Powers Act (“IEEPA”) as the statutory authority to impose tariffs and seeking to preserve
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On November 18, 2025, U.S. Customs and Border Protection (CBP) announced the issuance of a Withhold Release Order (WRO) against garments, apparel, and textiles manufactured in Mauritius by Firemount Group Ltd. The WRO follows an investigation into the company where CBP discovered several indicators of forced labor use, including abuse of vulnerability, debt bondage, deception…

Key Notes

  • Tariff undervaluation may result in criminal charges.
  • False country of origin may result in government procurement-related fraud charges, not only tariff-related fraud charges.

The Department of Justice (DOJ) in September announced the unsealing of an indictment charging two Colorado companies and three executives with a multiyear scheme to sell Chinese made forklifts to…

Following the October 31, 2025 meeting between President Donald Trump and Chinese President Xi Jinping, President Trump on November 4, 2025, issued two Executive Orders related to and reducing certain tariffs on China.

In the first Executive Order, President Trump modified duties on imports from China. In February and March 2025, in response to…

As of October 1, 2025, federal funding lapsed for numerous U.S. government agencies, including those engaged in sanctions, export control, and customs compliance and enforcement. Due to the lack of funding, export licensing functions have been significantly curtailed. Below is an overview of the status of key operations at OFAC, DDTC, BIS, and CBP.

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On September 24, 2025, U.S. Customs and Border Protection (CBP) issued a Withhold Release Order (WRO) against bicycles, bicycle parts, and bicycle accessories produced by Giant Manufacturing Co. Ltd. in Taiwan. The WRO follows an investigation into the company where CBP discovered several International Labour Organization (ILO) forced labor indicators, including abusive working and living…

On September 24, 2025, the U.S. Department of Commerce announced tariff exemptions for certain goods imported from the EU. The notice modified additional duty rates applicable to certain imported products of EU member countries.

On August 21, 2025, the United States and the EU announced an agreement that adjusted tariffs on certain EU products, including…

On September 16, 2025, the Department of Commerce’s International Trade Administration (ITA) released a Federal Register notice announcing changes to the Harmonized Tariff Schedule of the United States (HTSUS) as to general tariffs on imports of Japanese goods in order to implement the United States-Japan Agreement (see Executive Order 14345).  Under the original framework…

On July 31, 2025, President Donald Trump issued an Executive Order announcing that he was modifying and implementing the reciprocal tariff first announced on April 2, 2025, to rectify trade practices that his administration has determined contribute to “large and persistent annual United States goods trade deficits.”  Effective August 7, 2025, reciprocal tariffs ranging from…