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September 2025

Call 305-456-3830 or email info@diaztradelaw.com.

Breaking Trade News: New CBP Forced Labor Portal, USTR Seeks Comment on USMCA & 301

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

Customs and Border Protection (CBP)

  • CBP updated its FAQ on e-Commerce, clarifying that International mail can’t benefit from exemptions from reciprocal tariffs for subheadings listed as exempt.
  • CBP announced at the September COAC meeting that the agency is planning to release a dedicated forced labor portal in FY 2026 that importers will be required to use.
  • CBP’s COAC de minimis working group offered recommendations to CBP to bolster entry processing in ACE amid the end of the de minimis exemption on Aug. 29. These recommendations include treating postal shipments similarly to how CBP handles low-value shipments via other transportation modes.
  • CBP added more parties to the list of those qualified to handle the payment of duties on international mail shipments.
  • CBP recently discovered and detained several international food shipping containers that contained radioactive isotopes. As a result of these discoveries, the FDA issued a food safety alert on certain frozen shrimp products.
  • The customs broker permit user fee will change from $180.57 to $185.38. All broker permits issued on or after October 1, 2025, […]
By |2025-09-19T09:58:02-04:00September 19, 2025|news, Snapshot, Uncategorized|0 Comments
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FDA Launches Real-Time Adverse Event Reporting Dashboard for Cosmetic Products

On September 12, 2025, the U.S. Food and Drug Administration (FDA) announced the launch of the FDA Adverse Event Reporting System (FAERS) Public Dashboard for Cosmetic Products. The system is an interactive tool designed to facilitate the public’s ability to search and find real-time adverse event data on cosmetic products. Through the tool, users can search and view reports using search terms, including the product name. Users can also download data sets and report listings. The FDA will update the tool daily to ensure it includes the most recent submissions.

The dashboard includes serious adverse event reports submitted by responsible persons for cosmetic products under requirements established by the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), as well as voluntary adverse event reports submitted to the FDA by healthcare professionals, consumers, salon professionals, cosmetologists, and others. 

This announcement follows a recent launch of real-time reporting of adverse event and medication errors data for drugs and therapeutic biologics. 

In the announcement, the FDA stated these real-time reporting tools are part of the agency’s commitment to transparency and providing greater insight into the safety and regulation of the products consumers use every day.

Note: Reports in this dashboard have not been verified by the FDA, and their publication does not indicate that the FDA has concluded the product caused the adverse event. 

By |2025-09-19T09:48:31-04:00September 19, 2025|Cosmetics, Enforcement, FDA Issues, International Trade, Pre-compliance, U.S. Food and Drug Administration (FDA)|0 Comments
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New AD/CVD Case Filed on Fresh Mushrooms from Canada 

A new antidumping and countervailing duty action has been filed on fresh mushrooms from Canada. The allegation is that imports from Canada are unfairly subsidized and are being dumped.   

Full list of exporters here. 

Full list of importers here.  

Background on AD/CVD Investigations 

 Antidumping duty (“AD”) and countervailing duty (“CVD”) investigations are brought jointly by the U.S. International Trade Commission (“USITC”) and the U.S. Department of Commerce (“Commerce”). AD investigations are triggered when a domestic industry alleges that it has been injured by competing imports of particular goods from specific countries being sold at less than a fair value. Meanwhile, CVD investigations are triggered when a domestic industry alleges that it has been injured by competing imports that are being unfairly subsidized by their governments. The domestic industry initiating the investigation is known as the petitioner while the foreign industry participating in the investigation is known as the respondent. 

Scope of the Investigation 

The merchandise covered by these investigations is fresh mushrooms of the genus Agaricus.  

The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheading 0709.51.0100. 

Full scope here.   

Next Steps 

The Commerce Department will determine whether to initiate the investigations within 20 days. The USITC will reach a preliminary determination of material injury or threat of material injury within 45 […]

By |2025-09-17T16:02:12-04:00September 17, 2025|AD/CVD, U.S. Department of Commerce (DOC)|0 Comments
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De Minimis No More: What it Means for Importers and Consumers

President Trump’s Executive Order suspending duty-free de minimis treatment of shipments entering the U.S. took effect last week. The de minimis exemption has been used by retailers around the world catering to the American shopper, and the end of the policy is causing a ripple effect around the globe.

What is De Minimis?

De minimis is a Latin term that means “of the smallest things,” “trifling,” “insignificant.” In the U.S., the de minimis rule dates back to the Tariff Act of 1930. Upon passage of the act, individuals and businesses were permitted to import shipments under $200 without paying duties and taxes. 

The intent behind the exemption was to allow CBP to focus on higher-risk and higher-revenue imports and to encourage small-scale trade. In 2016, the U.S. raised the de minimis threshold to $800 with the passage of the Trade Facilitation and Trade Enforcement Act. 

After the 2016 change, de minimis shipments surged, from 139 million in FY 2015 to 1.36 billion in FY 2024. International retailers took advantage of the new threshold, and many U.S. policymakers began referring to de minimis as a “loophole.” 

Citing safety and fairness concerns, there were dozens of unsuccessful efforts in the U.S. Congress to end de minimis. Finally, the Big Beautiful Bill of 2025

By |2025-09-15T11:19:26-04:00September 15, 2025|ACE, Enforcement, Import, International Trade, Supply Chain, tariffs, U.S. Customs and Border Protection (CBP)|0 Comments
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ICYMI: FDA Launches Nationalized Entry Review Program (NER)

FDA recently implemented the Nationalized Entry Review Program (NER), which centralizes how the agency reviews imports nationwide. The program is effective as of August 4, 2025. Key changes include: 

  • Coordinated National Response: Rather than each port conducting manual reviews of certain entries on its own, specialized teams now coordinate their efforts across the country to more quickly identify and stop dangerous products.

  • Harmonized Real-Time Alert System: If the FDA detects a high-risk product at one port, such as contaminated infant formula or counterfeit drugs, alerts are immediately shared across all ports so they can watch for the same threats.

  • Improved Efficiency: Built on a successful 2022 pilot, the NER program has sped up processing by 70% and increased detection of high-risk products by 36%.

  • Expanded Reviewer Capacity: The program allows for more FDA reviewer availability and collaboration across the national network. 

The FDA’s current evaluative standards, regulatory requirements, and admissibility thresholds remain the same. 

The FDA has also published a communications guide that includes general contact protocols, hot shipments handling, email formatting requirements, and FAQs.

Diaz Trade Law provides assistance with FDA pre-compliance as well as assistance in successfully navigating FDA enforcement actions. For assistance with NER requirements or other FDA matters, contact us […]

By |2025-09-12T09:41:36-04:00September 12, 2025|Cosmetics, Enforcement, Food, Import, International Trade, Medical Devices, Pre-compliance, U.S. Food and Drug Administration (FDA)|0 Comments
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