On October 8, 2026, the U.S. Court of International Trade (CIT) granted a broad class certification for importers subject to the International Emergency Economic Powers Act (IEEPA) tariff regime, which the Supreme Court of the United States (SCOTUS) invalidated on February 20 (see Update of February 20, 2026).

CIT Senior Judge Richard K.

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…

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…

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…

On August 21, 2026, trade negotiations between the United States and Canada faltered and the parties, for now, have ceased further negotiations. As a result, the United States has implemented 50% tariffs on a broad range of Canadian products under Section 338 of the Tariff Act of 1930. First announced on July 20, 2026 (…

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…

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. …

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…

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…

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…