Administration 

• President Trump said that he will impose 50% tariffs on any country that sells military weapons to Iran. 
• President Trump said that the U.S. will consider tariff and sanctions relief for Iran as it negotiates an end to the war.  

Customs and Border Protection (CBP) 

• CBP released a new Harmonized System Update containing over 500 Automated Broker Interface records and 116 Harmonized Tariff Schedule records, including updates to 232 duties on aluminum, steel, and copper imports. 
• CBP and the Consumer Product Safety Commission (CPSC) seized nearly 350,000 batteries that did not comply with child protective packaging standards. 

Court of International Trade (CIT) stayed on another IEEPA refund case filed by importer Euro-Notions Florida, and reissued its order requiring CBP to pay IEEPA refunds for all unliquidated, not finally liquidated, and finally liquidated entries.  

Department of Labor (DOL) 

• DOL introduced new tools to support supply chain integrity and address unf
• The lead plaintiff in the IEEPA refund case filed a notice of dismissal in its case at the CIT on April 6. Shortly after, Judge Eaton lifted their foreign labor practices. 

United States Trade Representative (USTR) 

• U.S. Trade Representative Jamieson Greer said that USMCA negotiations are likely to continue past the July 1 deadline, citing the Trump Administration’s dissatisfaction with a lot of the outcomes of USMCA, including a significant surge of auto imports from Mexico and steel and aluminum imports from both countries. 

U.S. Department of the Treasury 

• Treasury’s Financial Crimes Enforcement Network (FINCen) and OFAC issued a joint proposed rule to implement provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).  

Office of Foreign Assets Control (OFAC) 

• OFAC issued Russia-related General License 13Q, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024.”  
• OFAC published Spanish translations of several Venezuela General Licenses, including licenses involving Venezuelan-origin oil, petrochemical products, and diluents.   

Food and Drug Administration (FDA) 

• Importer F&D international filed a complaint against the U.S. District Court for the Middle District of North Carolina, alleging the FDA unjustifiably detained shipments of imported frozen roasted eel. 
• The FDA posted new and revised Import Alerts on several products including: raw and cooked shrimp from India, processed foods for pesticides, and new tobacco products without required marketing authorization. 

U.S. Department of Agriculture (USDA) 

• USDA’s Foreign Agricultural Service (FAS) extended the comment period for the amendments to the regulation that provides for the issuance of annual licenses to import certain dairy products under tariff rate quotas. 

Consumer Product Safety Commission (CPSC)  

• CPSC added two new frequently asked questions to its eFiling website, guiding filing requirements for noncommercial products and resold products that are meant to be distributed in commerce. 

International News 

• China published new supply-chain security and retaliation regulations establishing a formal system for investigating and responding to foreign actions deemed harmful to the country’s industrial and supply‑chain security. 

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Administration

• On April 2, 2026, the President issued a proclamation strengthening Section 232 actions to adjust imports of aluminum, steel, and copper, continuing to cite national security concerns and the need to reinforce domestic metals industries. 

Customs and Border Protection (CBP)    

• CBP filed an update on the progress of the Consolidated Administration and Processing of Entries (CAPE) system that will be used to refund the tariffs imposed under the IEEPA.   
• On April 1, CBP released a modernized ACE Secure Data Portal account application for the trade community.  
• CBP said in a notice that it is no longer actively investigating allegations that cocoa from Cote d’Ivoire is being made with forced labor. 
• CBP filed a stipulated judgment with the CIT stating that products from importer Camel Energy aren’t subject to the Uyghur Forced Labor Prevention Act (UFLPA). The judgment follows a review of Camel’s supply chain, which determined that entries of batteries did not violate the UFLPA.  

United States Trade Representative (USTR) 

• USTR released the 2026 National Trade Estimate Report on Foreign Trade Barriers (NTE). The report highlights significant foreign barriers to U.S. exports, U.S. foreign direct investment (FDI), and U.S. electronic commerce. 
• In an interview with Bloomberg, U.S. Trade Representative Jamieson Greer said plans are in the works to establish a Board of Trade to manage trade between the U.S. and China. 

Congress   

• U.S. Senators Baldwin and Moreno wrote a letter to the Commerce Department asking it to open a 232 investigation into the national security threat of imports of heavy machinery. 
• The Defending American Property Abroad passed the House of Representatives. The bill would give the president the authority to prohibit passenger and cargo ships from calling on U.S. ports if they visited the former Vulcan Materials port in Mexico. 

U.S. Department of the Treasury

• FinCEN proposed a rule to establish a whistleblower program that offers incentives and protections to encourage individuals who have information about potential violations of the Bank Secrecy Act (BSA), International Emergency Economic Powers Act (IEEPA), Trading With the Enemy Act of 1917 (TWEA), and the Foreign Narcotics Kingpin Designation Act (Kingpin Act).

World Trade Organization (WTO) 

• During the 14th Ministerial Conference (MC14), members of the WTO failed to reach an agreement on extending the moratorium on customs duties for electronic transmissions. 

Office of Foreign Assets Control (OFAC)    

• OFAC issued a sanctions advisory to highlight sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether property may be the subject of a sham transaction. 
• OFAC issued several Venezuela-related General Licenses, including gold, services for minerals operations, and certain investments in Venezuela’s minerals sector.  

Department of Commerce 

• The Department of Commerce released a Fact Sheet announcing three new energy projects under the U.S.-Japan trade deal. 
• The Department of Commerce’s National Oceanic and Atmospheric Administration (NOAA) issued over $222,000 in civil penalties against two seafood importers accused of mislabeling tuna cans as “dolphin safe.” 

Federal Drug Administration (FDA) 

• The FDA posted several new and revised Import Alerts on the detention without physical examination of, including: processed foods for pesticides, medical instruments from Pakistan, and foods containing undeclared colors. 

Federal Maritime Commission (FMC) 

• The U.S. Court of Appeals for the District of Columbia Circuit upheld the FMC’s 2022 rule defining an unreasonable refusal to deal or to negotiate with respect to vessel space. 

Environmental Protection Agency (EPA) 

• EPA officials visited the port of New York/Newark as part of inspection activities to prevent the importation of illegal toxic and polluting imports.  
• The EPA issued a proposed rule to extend the reporting deadline for the Health and Safety Data Reporting Rule by one year until May 21, 2027. Comments on the rule are due on April 29. 

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Court of International Trade (CIT) 

• On March 4, 2026, Judge Eaton issued a strong and detailed order requiring the refunds of IEEPA Tariffs. We expect the government to appeal this order. Judge Eaton issued subsequent orders: (i) suspending the previous order to allow CBP time to implement their refund process; (ii) amending the previous order to include Brazil and India IEEPA tariffs.  
• New York Attorney General Letitia James and prosecutors from 23 other states filed a lawsuit in the CIT to block President Trump’s global tariff regime under Section 122 and order refunds to states.  

Administration   

• President Trump issued a 60-day waiver to the Jones Act, temporarily allowing foreign-flagged ships carrying oil and gas to travel between US ports. 

Customs and Border Protection (CBP)    

• CBP ruled that the submission of a CBP Form 5106 on an importer’s behalf constitutes “customs business” and requires a broker license.  
• CBP’s Trade and Cargo Security Summit has been rescheduled to Sept. 8-10, from its original dates in April. CBP said this is due to the DHS lapse in appropriations. 

Congress   

• U.S. House Representative Steube introduced a bill that would ban the import of energy storage systems that include remote monitoring capabilities, if they are made by Chinese-owned firms, or made with technology licensed from Chinese firms.  
• A group of democrat U.S. House Representatives introduced a bill called the Tariff Free Farming Act to end higher tariffs on farming products, including steel, lumber, fencing, tractors, combines, replacement parts, animal feed, fertilizer, and more.  
• The Securing Accountability in Foreign Entries (SAFE) Act has been introduced in both the House and Senate. The bill would restrict who can act as an importer of record, in an attempt to limit non-resident IORs. 

Department of Commerce   

• A new antidumping and countervailing duty action has been filed against large-diameter graphite electrodes from China and India. The allegation is that imports from China and India are unfairly subsidized and are being dumped.   

Bureau of Industry and Security (BIS)  

• BIS announced an Administrative Enforcement Settlement with Teledyne FLIR LLC and its affiliates for 19 EAR violations involving the company’s export of thermal imaging cameras to China.  

United States Trade Representative (USTR)    

• Representative Greer delivered President Trump’s 2026 Trade Policy Agenda and 2025 Annual Report to Congress. The Report offers a comprehensive account of USTR’s actions to support President Trump’s trade agenda, including negotiations with key trading partners to protect U.S. jobs and expand market access for U.S. exporters.  
• USTR released the findings of its 2025 Review of Notorious Markets for Counterfeiting and Piracy (the Notorious Markets List).  The list identified 37 online markets and 32 physical markets that are reported to engage in or facilitate substantial trademark counterfeiting or copyright piracy.   
• On March 12, 2026, USTR initiated a Section 301 Investigation into the practices of various economies, including those of US allies and long-standing trade partners, for their alleged failure to prohibit the importation of goods produced with forced labor.   

Office of Foreign Assets Control (OFAC)      

• OFAC issued six new Venezuela-related Frequently Asked Questions.  
• OFAC designated four “sham” charities that directly fund Hamas’s Military Wing and its terrorist activities. Persons are blocked and must be reported to OFAC. 
• OFAC announced that TradeStation Securities, Inc. has agreed to pay $1.1M to settle its potential civil liability for 481 apparent violations of OFAC sanctions programs arising from the company’s provision of brokerage and investment services to persons in Iran, Syria, and Crimea. 

Food and Drug Administration (FDA)    

• On March 5, 2026, the FDA published a Final Rule adopting a new format for the National Drug Code (NDC). The rule takes effect on March 7, 2033.  

Consumer Product Safety Commission (CPSC)   

• A Japanese manufacturing company has agreed to pay an $11.5 million civil penalty following charges that the company knowingly failed to report to CPSC that some of its bicycle models contained a defect that could create a serious risk of injury or death to consumers.  

Federal Maritime Commission (FMC) 

• The FMC has denied requests from several ocean carriers for special permission to increase rates on containers affected by the closure of the Strait of Hormuz.

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Administration    

• President Trump issued a 60-day waiver to the Jones Act, temporarily allowing foreign-flagged ships carrying oil and gas to travel between US ports. 
• The text of the Ecuador-U.S. trade agreement was released and includes a long list of products that will receive most-favored nation tariff rate treatment in the U.S. Roughly 50% of Ecuador’s exports will see MFN treatment as a result of the deal.  

Customs and Border Protection (CBP)    

• CBP ruled that the submission of a CBP Form 5106 on an importer’s behalf constitutes “customs business” and requires a broker license. 
• CBP seized 35 e-bikes from China that violated federal motor vehicle safety standards. 
• Ahead of Passover and Easter season, CBP issued a reminder to check the latest agricultural import requirements for those traveling with fresh flowers, plants, seeds, fruits, vegetables, and decorated eggs. 
• CBP officers at the Port of Rochester and Port of Buffalo seized a variety of designer items bearing counterfeit trademarks. Had these designer items been genuine, the total manufacturer-suggested retail price (MSRP) value would be approximately $125,000.  

Congress   

• The Securing Accountability in Foreign Entries (SAFE) Act has been introduced in both the House and Senate. The bill would restrict who can act as an importer of record, in an attempt to limit non-resident IORs.  

International Trade Commission (ITC) 

• The ITC ended a countervailing duty investigation on silicon metal from Thailand, finding that there was no injury to U.S. producers because imports of the product were negligible. As a result, the Commerce Department will not issue a CVD order on silicon metal, and all duties collected during the investigations will be refunded. 

United States Trade Representative (USTR)    

• U.S. Trade Representative Jamieson Greer and Mexican Secretary of Economy Marcelo Ebrard met to kick off bilateral technical discussions in advance of the USMCA Joint Review on July 1. Technical teams were instructed to review specific options for increasing U.S. and Mexican production and manufacturing employment, while limiting non-market inputs into North American supply chains. 

Office of Foreign Assets Control (OFAC)    

• OFAC designated four “sham” charities that directly fund Hamas’s Military Wing and its terrorist activities. All property and interests in property of the designated or blocked persons that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC. 
• OFAC sanctioned six individuals and two entities for their roles in Democratic People’s Republic of Korea (DPRK) government-orchestrated information technology worker schemes that systematically defraud U.S. businesses and generate revenue to fund the DPRK’s weapons of mass destruction (WMD) programs, including nearly $800 million in 2024. 
• OFAC announced that TradeStation Securities, Inc. has agreed to pay $1.1M to settle its potential civil liability for 481 apparent violations of OFAC sanctions programs arising from the company’s provision of brokerage and investment services to persons in Iran, Syria, and Crimea. 
• OFAC issued Venezuela-related General License 52, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.” 
• OFAC issued Russia-related General License 134A, “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 12, 2026.” 

Consumer Product Safety Commission (CPSC) 

• A Japanese manufacturing company has agreed to pay an $11.5 million civil penalty following charges that the company knowingly failed to report to CPSC that some of its bicycle models contained a defect which could create a serious risk of injury or death to consumers. 

Federal Maritime Commission (FMC)  

• The FMC released a statement regarding the impact the current conflict in the Middle East is having on shipping conditions through the Strait of Hormuz. The Commission reminded the industry that it ensures that rates, charges, and rules that common carriers have implemented as a result of the threats to commercial shipping in the Strait and neighboring waters do not violate the Shipping Act. 

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Court of International Trade (CIT) 

• On March 4, 2026, Judge Eaton issued a strong and detailed order requiring the refunds for entries of every plaintiff before the CIT who has challenged these IEEPA Tariffs. It is not clear whether he is also ordering the refunds for everyone else not in court, which will unquestionably be further litigated. We continue to believe that filing litigation at the CIT is the surest bet to get refunds of IEEPA duties and to get refunds quickly. 
• New York Attorney General Letitia James and prosecutors from 23 other states filed a lawsuit in the CIT to block President Trump’s global tariff regime and order refunds to states. 

Administration   

• In an interview with CNBC, Treasury Secretary Scott Bessent said that the Section 122 tariff rate will increase from 10% to 15% “sometime this week.” 

Customs and Border Protection (CBP)   

• CBP officers in Philadelphia seized 36 copper-alloy short swords and 50 copper-alloy arrowheads that date back to the Bronze Age, almost 4,000 years ago. 

Department of Commerce 

• A new antidumping and countervailing duty action has been filed against large-diameter graphite electrodes from China and India. The allegation is that imports from China and India are unfairly subsidized and are being dumped.  

Congress  

• U.S. House Representative Steube introduced a bill that would ban the import of energy storage systems that include remote monitoring capabilities, if they are made by Chinese-owned firms, or made with technology licensed from Chinese firms. 
• A group of democrat U.S. House Representatives introduced a bill called the Tariff Free Farming Act to end higher tariffs on farming products, including steel, lumber, fencing, tractors, combines, replacement parts, animal feed, fertilizer, and more. 

Bureau of Industry and Security (BIS) 

• BIS announced an Administrative Enforcement Settlement with Teledyne FLIR LLC and its affiliates for 19 EAR violations involving the company’s export of thermal imaging cameras to China. 

United States Trade Representative (USTR)   

• Representative Greer delivered President Trump’s 2026 Trade Policy Agenda and 2025 Annual Report to Congress. The Report offers a comprehensive account of USTR’s actions to support President Trump’s trade agenda, including negotiations with key trading partners to protect U.S. jobs and expand market access for U.S. exporters. 
• USTR released the findings of its 2025 Review of Notorious Markets for Counterfeiting and Piracy (the Notorious Markets List).  The list identified 37 online markets and 32 physical markets that are reported to engage in or facilitate substantial trademark counterfeiting or copyright piracy.  
• USTR published four Federal Register notices requesting applications for four committees: the Advisory Committee for Trade Policy and Negotiations, the Intergovernmental Policy Advisory Committee on Trade, the Trade Advisory Committee on Africa, and the Trade and Environment Policy Advisory Committee. Nominations are due by March 25.  

Food and Drug Administration (FDA)   

• On March 5, 2026, the FDA published a Final Rule adopting a new format for the National Drug Code (NDC). The rule takes effect on March 7, 2033. 

Office of Foreign Assets Control (OFAC)   

• OFAC issued six new Venezuela-related Frequently Asked Questions. 

Federal Maritime Commission (FMC) 

• The FMC dismissed a claim against NVOCC Transparent International, saying claimant Persimmon August failed to show that the firm acted unreasonably when it shipped an antique grand piano from Germany to the U.S. The piano arrived in the U.S. in September 2024 but remained in a warehouse for several months after the Fish and Wildlife Service flagged the container for containing undisclosed ivory. 

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• On February 20, 2026, the Supreme Court issued its opinion in Learning Resources, Inc., et al. v. Trump, ruling that IEEPA does not authorize the president to impose tariffs. 

Administration 

• In response to the Supreme Court’s IEEPA ruling, President Trump issued a Proclamation imposing a 10% tariff on all goods under Section 122 of the Trade Act. The President also announced that he will be increasing it to the lawful maximum of 15%, but the effective date has not yet been set. 
• President Trump signed an Executive Order continuing the suspension of duty-free de minimis treatment for all countries. 
• The U.S. and Bangladesh released a joint statement on reciprocal trade. The U.S. is lowering the tariffs on Bangladeshi exports to 19% rather than the 20%. The U.S. will also establish a mechanism for a tariff rate quota for Bangladeshi textile and apparel imports, with goods coming in under the quota entering duty-free.  
• President Trump announced on Truth Social that the U.S.’s trade deal with Japan is moving forward and that Japan will make its first set of investments under its $550 billion dollar commitment. 
• The Trump Administration signed a final reciprocal trade agreement with Taiwan that will impose a 15% tariff rate for imports from Taiwan. Taiwan committed to eliminating or lowering tariffs on nearly all U.S. goods. 
• The Trump Administration released its 2026 Maritime Action Plan which proposes a universal fee on all foreign-built vessels entering U.S. ports as well as a land port maintenance tax to prevent cargo carriers from avoiding paying the Harbor Maintenance Fee. 

Customs and Border Protection (CBP)   

• CBP issued guidance on the 10% Section 122 tariff. The guidance includes a list of the tariff numbers associated with the tariff and its exemptions. 
• CBP published a CSMS message ending the collection of IEEPA tariffs on goods entered for consumption or withdrawn from warehouse on or after 2/24 at 12:01am. 
• CBP’s base metals Center of Excellence and Expertise (CEE) released updated guidance for calculating steel, aluminum and copper content for Section 232 tariff purposes.  
• UFLPA Enforcement Statistics Dashboard update: in the previous dashboard, a shipment was defined as an aggregate of the totality of goods subjected to UFLPA enforcement actions. Now, a shipment is now defined as an individual import transaction within a shipment entry or customs declaration. This modification has resulted in a significant change in the number of UFLPA enforcement actions displayed.  
• CBP released a fact sheet regarding the January 2026 Lapse in Appropriations FAQs. Most CBP employees will still be working and trade operations will continue as normal. 

Congress  

• A group of democratic U.S. House members introduced a bill that would require CBP to pay refunds for reciprocal tariffs without importers having to make protests or file an application. 
• U.S. Senators Cassidy and Whitehouse introduced the Last Sale Valuation Act, which would end the practice of first sale to reduce duty exposure.   
• The U.S. House of Representatives voted to end the Canada emergency that underlies 35% tariffs on a subset of Canadian goods that are not covered by USMCA or Section 232. The Senate will now need to vote on the measure to send it to the President’s desk.  
• The Fighting Trade Cheats Act was re-introduced by a bipartisan group of Senators. The bill would increase the penalty for trade fraud and create a right of private action to sue on customs fraud and gross negligence. 

Department of Commerce  

• A new antidumping and countervailing duty action has been filed against certain fatty acids from Indonesia and Malaysia. The allegation is that imports from Indonesia and Malaysia are unfairly subsidized and are being dumped.  
• A new antidumping and countervailing duty action has been filed against Truck Bed Covers from China. The allegation is that imports from China are unfairly subsidized and being dumped.   

International Trade Commission (ITC)  

• The ITC posted the 2026 edition of the Harmonized Tariff Schedule. The new edition includes a variety of updates impacting medicines, fruits, vegetables, and other products. Changes are effective as of February 1.  

Bureau of Industry and Security (BIS) 

• BIS announced a settlement agreement with Applied Materials Inc. of California and Applied Materials Korea, Ltd. covering illegal exports of U.S. semiconductor manufacturing equipment to China. The companies agreed to pay a penalty of approximately $252 million – the second-highest penalty ever imposed by BIS. 

U.S. Department of the Treasury 

• The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FINCEN) launched a new dedicated webpage to confidentially accept whistleblower tips on fraud, money laundering, and sanctions violations. 

Office of Foreign Assets Control (OFAC)   

• OFAC is launching a new online Voluntary Self-Disclosure Portal to provide a streamlined, secure method for submitting voluntary self-disclosures of potential violations of OFAC-administered sanctions programs.    
• OFAC announced a $1.72M settlement with IMG Academy, LLC to settle its potential civil liability for 89 apparent violations of OFAC counternarcotics sanctions.  
• OFAC announced that a U.S. person agreed to pay $3.7M to settle their potential civil liability for 20 apparent violations of OFAC sanctions on Syria. 

Consumer Product Safety Commission (CPSC)  

• The CPSC published a list of approximately 600 HTS codes for products that may require the electronic filing of import certificates once the eFiling requirement takes effect this summer.   

Industry News   

• During Ford Motor Co.’s earnings call, the company revealed that its tariff costs jumped by almost $900 million in 2025 after the Trump administration informed the company that it could only apply Section 232 tariff credits back to November, rather than to May.  
• Twenty eight industry groups signed a letter to the Bureau of Industry and Security (BIS) expressing concern with the Section 232 tariffs administrative burden and asking for additional hearings and opportunity to comment on inclusion & exclusion decisions. 

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The Court rejected the Trump Administration’s assertion that the statutory text of IEEPA delegates Congressional tariff powers to the President, finding that Congress would not have delegated “highly consequential power” through ambiguous language.

The majority wrote, “Based on two words separated by 16 others in … IEEPA, ‘regulate’ and ‘importation’–the President asserts the independent power to impose tariffs on imports from any country, of any product, at any rate, for any amount of time. Those words cannot bear such weight.”

The decision was 6-3, with Justice Thomas, Alito, and Kavanaugh dissenting.

What This Means for Importers

The Trump Administration has made clear that, regardless of the Supreme Court’s decision, tariffs will remain a cornerstone of their trade and “America First” policy. 

On January 9, 2026, National Economic Council Director Kevin Hassett said of the Supreme Court case: “Our expectation is that we’re going to win, and if we don’t win, then we know that we’ve got other tools that we can use that get us to the same place.” He also said in a Fox Business Interview that the Administration has a backup plan ready to go that would allow tariffs to be put “back into place almost immediately, should the Supreme Court rule against us.”

IEEPA is just one of the legislative avenues the Administration has to impose tariffs. Below is a summary of tariff tools available to the Administration.

The Administration will almost certainly pivot to another legal authority to maintain the current tariffs. 

Because the Supreme Court has upheld the Federal Circuit’s decision, the case is remanded to the Court of International Trade to determine whether it can issue a nationwide injunction, which we hope the Court of International Trade will resolve quickly.  

Importers who have filed suit at the Court of International Trade should be eligible to get their own injunction. Further, an individual injunction may not be required, given the Supreme Court decision. The key at this moment is how the Court of International Trade will implement the Supreme Court’s decision.  

We are confident that importers who have filed suit in the Court of International Trade should be eligible to receive refunds for the IEEPA Tariffs they paid. However, the Court of International Trade will need to provide specific instructions for issuing refunds. We are actively monitoring and will advise as soon as we have more information from the Court of International Trade.  

What Importers Should Do

Importers should view the current tariff environment as a long-term reality and proactively invest in strategies that legally minimize their duty exposure. There are several ways to LEGALLY minimize tariffs, including:

• Duty drawback
• Tariff engineering
• Country of origin change
• First sale
• Duty deferral
• Negotiate DDP Incoterms

Importers should also invest in compliance. The U.S. government has signaled that enforcement of trade law is a top priority and has levied hefty fines and even initiated criminal cases against importers evading duties.

Importers should:

• Conduct internal audits
• Refresh classification procedures
• Ensure the accuracy of valuation practices
• Revisit supplier agreements
• Tighten broker oversight
• Leverage technology
• Develop training for staff
• Strengthen recordkeeping practices
• Prepare for audits

Our office will continue to closely monitor and will keep you informed. Please review the following resources to stay informed on tariff updates and jumpstart your 2026 compliance program.

• Live Resource – Tariffs and Trade Deals
• Bloomberg Law: Tariff Classification Basics
• Bloomberg Law: Import Compliance & Training Programs
• Bloomberg Law: CBP’s Recordkeeping Requirements
• Navigating Tariff Increases: Strategies to Minimize Tariff Costs Under the Trump Administration
• Webinar: Navigating Tariff Challenges: Mitigation Tools & Tactics
• Webinar: IEEPA Tariffs, Supreme Court Developments, & Refund Implications

Diaz Trade Law can assist in auditing and/or developing importer compliance programs, setting up importer ACE accounts, and executing strategies to minimize duties. If you have questions about the IEEPA case or questions regarding any other import or export-related matter, please do not hesitate to contact our office at info@diaztradelaw.com.

Reporter Lori Ann LaRocco dives into the recent rise in customs bond insufficiency notices in her Feb. 6 article: President Trump’s tariffs fueled U.S. Customs bond market boom. Now billions hang on Supreme Court ruling.

Here are two excerpts from the piece:

“Jennifer Diaz, board-certified international attorney at Diaz Trade Law, said the number of bond insufficiency notices issued has quadrupled since 2017 and has accelerated recently due to the volatile tariff environment.”

“David Craven, counsel to Diaz Trade, said the threat of new replacement tariffs, coupled with the existing liability facing surety companies, suggests that any refunds would not be immediate. “The fact that liability has gone up, and Customs is now asking the sureties for collateral … operations are at risk, and sureties understandably don’t want to be caught holding the bag,” Craven said.”

Read the full article here.

Jennifer Diaz was also featured in a separate CNBC piece on Feb. 12: Trump tariffs leave importers with record-breaking $3.5 billion U.S. Customs bond funding shortfall.

Jen said:

“In totality, it makes sense that insufficiencies are more than double,” said Jennifer Diaz, attorney at Diaz Trade Law. “Many companies take it for granted that a $50,000 bond should be able to cover you for a one-year period,” she said. “But it might not. They are not utilizing set calculations, and don’t have anyone in their corner telling them that their bond obligation is higher.”

Read the full article here.

Administration  

• Via a post on X, President Trump threatened to block the opening of a second bridge between Detroit and Windsor, Canada, “until the United States is fully compensated for everything we have given.”   
• The Trump administration is reportedly considering tariff exemptions for major U.S. hyperscalers involved in construction of data centers needed for AI.
• The U.S. and Bangladesh released a joint statement on reciprocal trade. The U.S. is lowering the tariffs on Bangladeshi exports to 19% rather than the 20%. The U.S. will also establish a mechanism for a tariff rate quota for Bangladeshi textile and apparel imports, with goods coming in under the quota entering duty-free. 

Customs and Border Protection (CBP)  

• CBP’s base metals Center of Excellence and Expertise (CEE) released updated guidance for calculating steel, aluminum and copper content for Section 232 tariff purposes. 
• UFLPA Enforcement Statistics Dashboard update: in the previous dashboard, a shipment was defined as an aggregate of the totality of goods subjected to UFLPA enforcement actions. Now, a shipment is now defined as an individual import transaction within a shipment entry or customs declaration. This modification has resulted in a significant change in the number of UFLPA enforcement actions displayed. 
• CBP announced the agency is updating how a broker may access the importer view in the ACE Portal and that customs brokers who receive electronic refunds on behalf of their clients will need to set up the ability to view an importer’s record in the portal.  
• CBP updated its guidance on tariffs on imports from India to reflect the end of the 25% tariff imposed on India for its imports of Russian oil. 

Congress 

• U.S. Senators Cassidy and Whitehouse introduced the Last Sale Valuation Act, which would end the practice of first sale to reduce duty exposure.  
• The U.S. House of Representatives voted to end the Canada emergency that underlies 35% tariffs on a subset of Canadian goods that are not covered by USMCA or Section 232. The Senate will now need to vote on the measure to send it to the President’s desk. 
• A group of U.S. House Republicans introduced a bill that would create criminal penalties for importing pill press machines. 

United States Trade Representative (USTR)  

• Representative Greer stated in an interview with Fox Business that Indonesia will be the “next big one” for trade deals and that the deal will be finalized within the next couple of weeks.  

Food and Drug Administration (FDA)  

• New import alerts – detention without physical examination of: 
• Raw Agricultural Products for Pesticides. 
• Dried Peppers from Mexico. 

Federal Maritime Commission  

• A FMC administrative law judge dismissed a complaint that motor carrier Elite Logistics filed against ocean transportation intermediary Tanera Transport, citing a lack of jurisdiction. 

Office of Foreign Assets Control (OFAC)  

• OFAC is launching a new online Voluntary Self-Disclosure Portal to provide a streamlined, secure method for submitting voluntary self-disclosures of potential violations of OFAC-administered sanctions programs.  
• OFAC issued Venezuela General License 48 and Venezuela General License 46A, authorizing the supply of certain items and services and certain activities involving Venezuelan-origin oil. 

Consumer Product Safety Commission (CPSC)  

• The CPSC published a Federal Register Notice stating that the agency is revising its safety standard for crib mattresses to implement an update to the voluntary ASTM standard. 

Industry News  

• During Ford Motor Co.’s earnings call, the company revealed that its tariff costs jumped by almost $900 million in 2025 after the Trump administration informed the company that it could only apply Section 232 tariff credits back to November, rather than to May.
• Twenty eight industry groups signed a letter to the Bureau of Industry and Security (BIS) expressing concern with the Section 232 tariffs administrative

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Administration 

• Via a Truth Social Post, President Trump announced that after speaking with Indian Prime Minister Modi, the U.S. will drop reciprocal tariffs on India from 25% to 18%. 
• During a meeting at the State Department, Vice President Vance said that the U.S. is seeking to organize a preferential trade zone for critical minerals. 

Customs and Border Protection (CBP) 

• CBP announced a new and improved Uyghur Forced Labor Prevention Act (UFLPA) Enforcement Statistics Dashboard that provides a more detailed view of CBP’s enforcement actions.  
• CBP issued a Withhold Release Order against coffee harvested by Finca Monte Grande, a Mexican coffee farm. Effective immediately, CBP at all U.S. ports of entry will detain coffee harvested by Finca Monte Grande. 

Department of Commerce 

• A new antidumping and countervailing duty action has been filed against certain fatty acids from Indonesia and Malaysia. The allegation is that imports from Indonesia and Malaysia are unfairly subsidized and are being dumped. 

United States Trade Representative (USTR) 

• U.S. Trade Representative Jamieson Greer joined Guatemala’s Minister of Economy Adriana Gabriela Garcia in signing the United States–Guatemala Agreement on Reciprocal Trade. 
• U.S. Trade Representative Jamieson Greer announced a plan to develop a critical minerals cooperation agreement with the European Union and Japan. 

Bureau of Industry and Security (BIS) 

• Export Compliance Daily reports that BIS has stopped work with most industry advisory committees that it has used for years to seek expert feedback on export controls.   

International Trade Commission (ITC) 

• The ITC posted the 2026 edition of the Harmonized Tariff Schedule. The new edition includes a variety of updates impacting medicines, fruits, vegetables, and other products. Changes are effective as of February 1.   

World Trade Organization (WTO) 

• A WTO dispute panel found that the U.S.’s electric vehicle tax credits violate various WTO commitments. 

Food and Drug Administration (FDA) 

• The FDA published several new import alerts on seafood, including seafood products due to the presence of Salmonella and raw and cooked shrimp from India. 

Federal Maritime Commission 

• President Trump designated Laura DiBella to serve as Chairman of the Federal Maritime Commission. Her term expires June 30, 2028. 
• The Senate Commerce Committee voted 15-13 to approve President Trump’s nomination of Robert Harvey to fill a vacancy on the FMC. The nomination now heads to the full Senate for its consideration. 

Office of Foreign Assets Control (OFAC) 

• OFAC issued an amendment to the Venezuela FAQ regarding what is authorized under  Venezuela-related General License 5U. 

Consumer Product Safety Commission (CPSC) 

• The CPSC published a list of approximately 600 HTS codes for products that may require the electronic filing of import certificates once the eFiling requirement takes effect this summer.  

Congress 

• Senate Finance Committee ranking member Ron Wyden and Senator Chris Van Hollen wrote a letter to USTR and the Department of Commerce asking the administration to explain how it decided which goods would be exempt from reciprocal tariffs. 

Industry News 

A new industry study finds that 41% of counterfeit apparel, footwear, and accessory products fail to meet product safety standards.

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