Trade Alerts

New Sec 232 Aluminum Tariff Incentive Program Announced

Admin — Tue, 21 Jul 2026 19:00:01 GMT

On July 20, 2026, President Trump signed a new proclamation modifying the Section 232 aluminum tariff program and establishing incentives for companies that invest in domestic U.S. primary aluminum production facilities.

What Changed?
The Administration determined that while existing Section 232 aluminum tariffs have helped strengthen the domestic aluminum industry, U.S. production of primary aluminum remains insufficient to meet national security and economic needs.
To address this concern, the proclamation directs the Department of Commerce to create an investment incentive program for companies that:

Additional Section 338 Tariffs Announced on Canadian Imports

Admin — Tue, 21 Jul 2026 17:30:01 GMT

On July 20, President Trump issued three separate proclamations invoking Section 338 of the Tariff Act of 1930 to impose an additional 50% ad valorem duty on certain products of Canada. The duties are scheduled to take effect at 12:01 a.m. ET on August 19, 2026.

IEEPA Tariff Refund Update

Admin — Thu, 16 Jul 2026 17:28:42 GMT

Additional Refund Processing Underway

Rebuttal Comment Period Opens for Section 301 Forced Labor Investigation and U.S.-China Trade Review

Admin — Wed, 15 Jul 2026 17:06:36 GMT

The rebuttal comment period is now officially open for both the Section 301 Forced Labor Investigation and the U.S.-China Board of Trade Review.

Section 122 Expiration Approaching

Admin — Fri, 10 Jul 2026 13:30:01 GMT

Ultimate Outcome Remains Uncertain

Protect Your IEEPA Refund

Admin — Thu, 09 Jul 2026 18:20:01 GMT

Don't Fall for Fraudulent Schemes

Positive ID Verification to Be Required for Powers of Attorney and Importers of Record

Admin — Thu, 25 Jun 2026 18:15:01 GMT

On June 3, 2026, President Trump issued the executive order “Strengthening Customs Enforcement”. In the executive order, the President has ordered Customs to take steps to revise eligibility regulations, guidance and policies with regards to those wishing to act in the capacity of an importer of record. The President stated that importers will need to “provide additional data and identification information”. Similarly, CBP’s current POA best practices document states that a customs broker should “To the greatest extent possible, have POA’s completed in person so the grantor’s unexpired government issued photo identification (driver’s license, passport, etc.) can be reviewed.”

New Executive Order Update

Admin — Wed, 10 Jun 2026 20:00:00 GMT

Analysis from the firm of Roll & Harris

New Executive Order Tightens U.S. Customs Enforcement

Admin — Thu, 04 Jun 2026 09:00:33 GMT

On June 3, President Trump issued an Executive Order, “Strengthening Customs Enforcement,” signaling a broad tightening of U.S. Customs enforcement that will impact all importers and parties involved in import transactions.

The Order emphasizes increased importer accountability, enhanced vetting, expanded disclosure requirements, and stronger enforcement, particularly affecting importers of record (IORs), with heightened implications for foreign IORs.

Although the changes are not immediate, the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) are expected to implement them through the rulemaking process, including the issuance of future Federal Register notices seeking public comment.

Key Takeaways

Heightened enforcement expected across CBP operations
Increased bonding and proof of tangible domestic assets in the U.S. for IORs
Expanded data reporting and supply chain disclosure obligations
Stricter rules and limitations on foreign IORs
Higher penalties and reduced mitigation flexibility

Importer of Record (IOR) Requirements

Within 180 days, CBP will revise IOR requirements to include:

Minimum U.S. assets and/or increased bonding thresholds
Expanded disclosures (ownership, affiliations, assets, and import volumes)
A new “good standing” requirement; noncompliant IORs may be barred from importing

Foreign IOR Restrictions

Foreign IORs will be prohibited from filing informal entries
Formal entries will be permitted only if additional requirements are met, including:
- Sufficient bonding is provided to protect revenue
- Compliance standards are met
- Participation in CTPAT (if eligible), or use of a CTPAT-validated broker
- The Order also introduces a substance-over-form test to prevent the use of shell companies or artificial structures to qualify as a U.S. IOR

Enhanced Vetting and Oversight

CBP will expand oversight of the importing community by:

Updating the IOR registry (removing inactive IORs and verifying compliance)
Creating risk-based tiers based on compliance history
Expand vetting to IORs, their affiliates, brokers, forwarders, and bonded operators

New Reporting Requirements

The Order directs CBP to implement expanded import reporting requirements, including:

Certifying compliance with critical supply chain requirements like the Countering America’s Adversaries through Sanctions Act Compliance certifications
Foreign tax and business identifiers
Detailed supply chain and product information
Within 90 days, importers may also be required to submit export-related documentation filed with foreign governments

Increased Enforcement and Penalties

CBP is directed to expand enforcement activities, including:

Increased audits and investigations
More aggressive bond enforcement and liquidated damages claims and penalties
Restrictions on in-bond shipments

Priority Enforcement Areas: forced labor, undervaluation, misclassification, transshipment, and AD/CVD evasion (EAPA).

Penalty Changes

Within 90 days, CBP will revise mitigation policies to include:

A minimum penalty floor of at least 50% of assessed penalties
Minimum liquidated damages thresholds
No mitigation for repeat offenders

Implementation Timeline for CBP

45 days: Legislative recommendations for additional Customs enforcement legislation
90 days: New reporting, penalty, and enforcement measures
Within 180 days: New IOR rules, registry updates, and vetting requirements
Within 1 year: Implementation Report to the President

This Executive Order effectively lays the groundwork for a comprehensive modernization of U.S. Customs enforcement.

Importers, particularly those using foreign IOR structures, should anticipate increased scrutiny, higher compliance costs, and more extensive reporting obligations. Begin evaluating current import practices in advance of forthcoming rulemaking.

We will continue to monitor developments and provide updates. For questions, please contact your Deringer representative or Customs Attorney.

USTR Issues Section 301 Federal Register Notice

Admin — Thu, 04 Jun 2026 08:15:23 GMT

The Office of the U.S. Trade Representative (USTR) has published a Federal Register notice seeking public comment on proposed additional tariffs under Section 301 related to forced labor concerns. The proposed action follows USTR’s investigation into 60 countries, which found that many trading partners have failed to adequately prohibit or enforce restrictions on imports of goods produced with forced labor.

As a result of these findings, USTR has proposed additional tariffs ranging from 10% to 12.5% on imports from the affected countries. These measures are not yet final and are subject to change based on public feedback.

Proposed Tariff Structure

10% Tariff would apply to countries that:
- Currently enforce forced labor import prohibitions (e.g., Canada, EU, Mexico, Indonesia, Pakistan)
- Have committed to such prohibitions under trade agreements (e.g., Bangladesh, Cambodia, Malaysia, Taiwan)
- Maintain partial regimes restricting certain forced labor goods (e.g., United Kingdom)
12.5% Tariff would apply to the remaining 44 countries that USTR determined have failed to adequately implement or enforce such prohibitions.

These duties would apply broadly to all products from the affected countries, with limited exclusions outlined in the forthcoming Federal Register notice.

Additional Considerations

Tariff stacking: These new duties would be imposed on top of existing tariffs, including most favored nation (MFN) rates, current Section 301 tariffs on China, and any other applicable trade actions.
Textile mechanism: USTR also proposed a potential quota-based mechanism allowing a limited volume of apparel and textiles from certain countries to enter at a reduced tariff rate.

Timeline

June 22: Deadline to request participation in public hearings
July 6: Written comments due
July 7: Public hearings scheduled

This timeline could allow implementation of new tariffs before the expiration of current Section 122 duties on July 24. USTR is also expected to release findings from a separate Section 301 investigation into excess manufacturing capacity involving 16 economies, including China, the EU, Vietnam, India, and Mexico.

We will continue to monitor this closely and provide updates as more information becomes available. If you have questions about how this may affect your imports, please reach out to your Deringer representative or consult your Customs Attorney.