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
Department of Commerce Initiates Section 232 Investigation of Anthracite Coal Imports
On June 29, 2026, the Department of Commerce (Commerce) initiated an investigation under Section 232 of the Trade Expansion Act of 1962, as amended, to determine the effects on the national security of imports of anthracite coal. For the purposes of this investigation, anthracite coal encompasses products classified under Harmonized Tariff Schedule of the United…
USTR Issues Statement on Status of USMCA Review
On July 1, 2026, the U.S. Trade Representative (USTR) issued a formal statement regarding the joint review of the Agreement between the United States of America, the United Mexican States, and Canada (USMCA). The USMCA entered into force on July 1, 2020, and contains a clause requiring that the parties meet on the sixth anniversary…
Annual Blocked Property Reports Due to OFAC by September 30
All persons subject to U.S. jurisdiction holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2026. This required reporting applies to all relevant persons, not only financial institutions.
This report is pursuant to 31…
OFAC Launches New Portal for Requesting Removal from a Sanctions List
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has launched a Reconsideration Portal for the submission of requests by persons or entities seeking to be removed from an OFAC sanctions list. The portal provides an overview of the process for requesting removal from a list as well as information on OFAC’s…
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…
USTR Launches Section 301 Investigation into Germany’s Underpayment for Pharmaceutical Products
On June 18, 2026, the Office of the U.S. Trade Representative (USTR) announced that it was launching an investigation of Germany under Section 301 of the Trade Act of 1974. The investigation will seek to determine “whether persistent underpayment for innovative pharmaceutical products by Germany is unreasonable or discriminatory and burdens or restricts U.S. commerce.” …
New Executive Order Imposes Sweeping Customs Enforcement Reforms
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…
