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April 2026

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

Breaking Trade News: IEEPA Tariff Case Update, DOL Launches Forced Labor Tools

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

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 […]
By |2026-04-10T09:46:14-04:00April 10, 2026|news, Snapshot, Uncategorized|0 Comments
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New AD Case Filed Against Polytetramethylene Ether Glycol From China, South Korea, Taiwan, and Vietnam   

A new antidumping action has been filed against Polytetramethylene Ether Glycol from China, South Korea, Taiwan, and Vietnam. The allegation is that imports from China, South Korea, Taiwan, and Vietnam are being dumped.  

Full list of exporters here. 

Import volume here.  

Background on AD Investigations 

Antidumping duty (“AD”) is 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. 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 all forms of polytetramethylene ether glycol (“PTMEG”).  

The products subject to the investigation are currently classified in the Harmonized Tariff Schedule of the United States (HTSUS) under the following subheadings: 3907.29.00 and 2932.11.00.   

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 days. 

As with any proceeding, participation is very important to protect your rights. We urge anyone who imports Polytetramethylene Ether Glycol from China, South Korea, Taiwan, or Vietnam to […]

By |2026-04-09T16:24:14-04:00April 9, 2026|AD/CVD, Import, International Trade, U.S. Department of Commerce (DOC), U.S. International Trade Commission (USITC)|0 Comments
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U.S. Department of Labor Introduces New Tools to Support Supply Chain Integrity and Address Unfair Foreign Labor Practices

On April 8, 2026, the U.S. Department of Labor (DOL) announced the launch of several tools to empower U.S. companies to strengthen their supply chains and defend against unfair competition stemming from overseas labor abuses.

Self-Assessment Tools

DOL launched four voluntary self-assessment tools that provide practical, user-friendly guidance to help companies map supply-chain risks and evaluate labor practices. The tools can also guide companies in taking steps to ensure alignment with U.S. forced labor laws and strengthen supply chains that support American workers and American industry.

The new tools are: 

  • LaborShield: A mobile app that features information on egregious labor violations in over 145 countries (formerly the Sweat and Toil app).
  • ImportWatch: A resource that brings together the department’s labor abuse research with U.S. import data from the U.S. Census Bureau to produce a red-flag list of all high-risk goods for U.S. importers.
  • SourcingStrong: A tool to help U.S. businesses build strong labor due diligence systems to identify and manage risk in their supply chains.
  • Supply Chain Traceability Portal: The portal provides visibility across supply chains and beyond the first tier to expose where exploitative labor hides.

Announcement Insights 

Diaz Trade Law was in attendance at the launch event in Washington, D.C. – hosted by the DOL and […]

By |2026-04-09T16:06:30-04:00April 9, 2026|Enforcement, Forced Labor, Import, U.S. Department of Labor (DOL)|0 Comments
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Breaking Trade News: New 232 Proclamation, CBP Update on IEEPA Refunds, OFAC Sanctions Advisory

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

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) 

By |2026-04-03T14:27:14-04:00April 3, 2026|news, Snapshot|0 Comments
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New OFAC Advisory: Signs of Sham Transactions and Sanctions Evasion

On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an important advisory addressing the growing use of sham transactions to evade U.S. sanctions. The guidance highlights how sanctioned individuals and entities often attempt to disguise their continuing interest in property through opaque legal structures, proxies, and other intermediaries. OFAC’s message is clear: transactions that merely appear to transfer ownership but do not genuinely extinguish a blocked person’s interest remain prohibited. 

What OFAC Defines as a “Sham Transaction” 

Sham transactions occur when blocked persons “give up their property on paper only,” while continuing to benefit from or control the asset. These arrangements often involve: 

  • Proxies, straw owners, or front companies acting on behalf of sanctioned individuals. 
  • Opaque legal structures, including multi‑layered LLCs, partnerships, or trusts. 
  • Transfers to family members or close associates who may serve as facilitators. 
  • Commercially unreasonable transfers, such as those lacking adequate consideration. 
  • Continued use or control of the asset by the blocked person after the purported transfer. 

Pro Tip: Look beyond legal formalities and identify the economic realities of the transaction. 

Red Flags Identified by OFAC 

The advisory outlines several indicators that a transaction may be a sham designed to evade sanctions. These include: 

By |2026-04-07T16:53:01-04:00April 3, 2026|Enforcement, International Law, International Trade, Investigation, U.S. Office of Foreign Assets Control (OFAC)|0 Comments
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