January 2026

FDA Takes Action to Improve Gluten Ingredient Disclosure in Foods

On January 22, 2026, the U.S. Food and Drug Administration (FDA) issued a Request for Information (RFI) regarding labeling and preventing cross-contact of gluten in packaged food.

Background

The FDA received a citizen petition requesting that the FDA act to protect consumers with celiac disease by better enabling them to identify, through labeling, whether a food includes gluten-containing grains (GCGs), and to address cross-contact with GCGs. FDA subsequently reviewed available data and reports, which indicated that serious data gaps are limiting the agency’s ability to fully evaluate the public health importance of these ingredients, including data on adverse reactions.

Request for Information

The FDA is taking this action as a first step to improve transparency in disclosures of ingredients that impact certain health conditions, such as gluten for those with celiac disease, and other established food allergens.

The agency is inviting comments concerning adverse reactions due to “ingredients of interest” ( i.e., non-wheat GCGs and oats) in the United States. The RFI also aims to collect data on labeling issues or concerns with identifying ingredients of interest on packaged food products in the United States.

The FDA is particularly interested in:

  • Data and information on IgE-mediated and non-IgE-mediated food allergies and adverse reactions to non-wheat GCGs (including prevalence, severity, and potency).
  • Data and information on gluten in oats (including frequency and amounts of gluten in oats), and the prevalence, severity, and potency of IgE-mediated and non-IgE-mediated allergy and adverse reactions to oats.
  • Data and information on undisclosed ingredients of interest (including their prevalence and usage amounts […]

Trump Imposes 25% Tariff on Some Advanced Computing Chips

On January 14, 2026, President Trump signed a proclamation imposing a 25% tariff on certain semiconductors, semiconductor manufacturing equipment, and their derivatives. This tariff applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. EST on January 15, 2026, and will continue indefinitely. The Administration released a fact sheet in conjunction with the proclamation, available here.

Background – 232 Investigation

The proclamation follows a nine-month Section 232 investigation into the effects of imports of semiconductors on the national security of the United States. The investigation, conducted by the Department of Commerce, found that semiconductors, semiconductor manufacturing equipment, and their derivative products are being imported into the United States in such quantities and under such circumstances as to threaten to impair the national security of the United States.

The action is part of a broader Administration effort to create incentives for chipmakers to produce more semiconductors in the U.S. and decrease reliance on foreign chip manufacturers. The proclamation noted that the U.S. only manufactures 10% of the chips it requires and that reliance on foreign manufacturers poses a “significant economic and national ‌security risk.”

Scope – What’s Covered

“Semiconductor articles” covered by the proclamation are defined as imported products meeting certain technical parameters and that are classifiable under HTSUS 8471.50, 8471.80, or 8473.30. To be included within the definition of semiconductor articles, the imported products must be a logic integrated circuit, or an article that contains a logic integrated circuit, that meets certain technical parameters. Full […]

By |2026-01-15T12:51:04-05:00January 15, 2026|tariffs|0 Comments

Breaking Trade News: New 25% Tariff on Chips, Sanctions Against Iran, U.S. Trade Deficit Plummets

Here is a recap of the latest customs and international trade news:  

Administration 

  • President Trump issued a proclamation and fact sheet announcing a 25% tariff on certain semiconductors, semiconductor manufacturing equipment, and their derivatives. 
  • President Trump said in a Truth Social post that he will immediately impose a 25% tariff on any Country doing business with Iran. The White House has not yet issued an executive order or proclamation imposing the tariffs. 

Supreme Court 

  • The Supreme Court scheduled an opinion release date on January 14, but did not release its ruling on the highly anticipated IEEPA tariffs case. The Court has not yet announced when the next opinion release date will be. 
  • The Respondent merit briefs were filed in Montgomery v. Caribe Transport II, LLC, a case before the Supreme Court that will determine whether freight brokers may be held liable under varying state laws for accidents involving federally licensed motor carriers. Oral arguments will be held on March 4, 2026. 

Customs and Border Protection (CBP) 

  • CBP modified the Withhold Release Order on FGV Holdings Berhad in Malaysia. As of Jan. 15, 2026, the U.S. will no longer […]
By |2026-01-15T18:23:21-05:00January 15, 2026|news, Snapshot|0 Comments

Breaking Trade News: Furniture & Cabinet Tariff Delay, No IEEPA Decision from SCOTUS

Here is a recap of the latest customs and international trade news:    

Administration

  • The Trump Administration announced the postponement of the scheduled January 1st increase in the upholstered furniture, kitchen cabinets, and vanities 232 tariffs. They will remain at 25% (instead of 30% on furniture and 50% on kitchen cabinets and vanities) for an additional year.
  • The White House published a proclamation extending duty-free treatment of some agricultural products under quota from Israel through December 31, 2026. 

Supreme Court

  • The Supreme Court did not release its much-anticipated decision on the fate of IEEPA tariffs on its opinion day, January 9. The Court said it may release additional opinions on January 14.

Industry News

  • The United States filed a customs penalty lawsuit against two importers and their owner, alleging that the defendants undervalued their entries to avoid hundreds of thousands of dollars in duties. The government is seeking a penalty of over $3.4 million.

Customs and Border Protection (CBP)

  • CBP published an Interim Final Rule regarding electronic refunds. Effective February 6, 2026, CBP will process all refunds electronically. The agency will not issue any refunds by check unless a waiver has been approved.
  • CBP will be […]
By |2026-01-12T11:02:11-05:00January 12, 2026|news, Snapshot|0 Comments

IEEPA May Be on the Chopping Block, But Your Duty Exposure Isn’t

On November 5, 2025, the Supreme Court of the United States (SCOTUS) held oral arguments for Trump v. V.O.S. Selections, Inc., regarding the legality of the International Emergency Economic Powers Act (IEEPA). The case will ultimately decide whether the Trump Administration has the authority to impose tariffs under IEEPA. Importers and trade professionals are watching the case closely, but even if the IEEPA tariffs are thrown out, the new administration has made clear that it will pivot and use other legal avenues to impose tariffs.  Since oral argument, multiple discussions have been held with the Department of Justice and the plaintiffs regarding any refund possibilities. Based on these discussions, it appears that the United States is anticipating losing this matter at the Supreme Court but wants to put barriers to recovery. The United States has also clearly stated that they intend to find other ways to impose similar duties.

The message is clear: even if the Supreme Court strikes down IEEPA tariffs, tariff exposure is here to stay. NOW is the time for importers to revisit their valuation practices, explore duty minimization strategies, and ensure they are taking every lawful step to minimize duty impact going forward.

Why Tariffs Will Stay Even if IEEPA Dies

Since the earliest days of the Trump Administration, the White House has made tariffs a cornerstone of their trade and “America First” policy. The President and Administration officials have repeatedly touted tariffs as one of the best tools available to level the international trade playing field, […]

By |2026-01-09T17:08:04-05:00January 9, 2026|tariffs|0 Comments
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