Trade Updates
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U.S. Trade-Related Agencies’ Shutdown Plans Amid Funding Lapse
The 2025 U.S. government shutdown has paused routine trade activities, but key agencies continue essential enforcement, tariff, and border functions. Shutdown plans ensure critical operations linked to national security and trade negotiations proceed despite funding interruptions. CBP remains fully operational during the shutdown, with all ports, inspections, collections, and trade functions continuing, though refund and drawback processing is temporarily paused.
New Section 301 Vessel Fees Effective October 14, 2025
New Section 301 vessel fees take effect October 14, 2025, targeting vessels linked to China. Operators must pay fees via Pay.gov before arrival to avoid delays. Fees apply under three annexes with specific exemptions for LNG tankers and others.
CBSA Working Through Backlogs to Restore Normal Service (Updated)
CBSA has restored systems following the September 28 outage, but backlogs remain, and delays are expected at all ports of entry through the weekend. Key systems affected included ACROSS, Single Window, eManifest, and Commercial Exports. Commercial carriers are advised to avoid the Peace Bridge until further notice due to congestion.
U.S. Government Shutdown Now in Effect
The U.S. government shutdown, effective October 1, 2025, is causing customs clearance delays due to reduced staffing at agencies like the FDA and EPA, despite CBP continuing operations. Importers are advised to hold non-essential shipments to avoid disruptions.
DOJ and Homeland Security Launch Cross-Agency Trade Fraud Task Force
The DOJ and Homeland Security have created a Trade Fraud Task Force to crack down on tariff evasion, smuggling, and trade violations. This effort supports fair trade and protects American industries and taxpayers.
FDA Draft Supplemental Guide Version 2.6 Now Available
The FDA released draft version 2.6 of its Supplemental Guide for imports in ACE, focusing on tobacco and electronic nicotine delivery systems. This update improves import data accuracy and compliance with new validation rules and product code clarifications.
U.S. and EU Agree on Major Trade Deal (Tariff Implementation Guidance)
U.S. CBP issued guidance on implementing the EU-U.S. trade framework shortly before the tariff modifications were officially published in the Federal Register notice. The deal removes tariffs on American industrial exports, sets a 15% tariff cap on most European imports to promote domestic production, and strengthens investment and supply chain security.
Trump Administration Submits Legal Defense of IEEPA Tariffs to Supreme Court
The Trump Administration argues in its Supreme Court brief that IEEPA authorizes the President to impose tariffs during national emergencies. The Court’s ruling will clarify presidential powers and impact U.S. trade and national security policy.
FY 2026 CBTPA Apparel Quotas and Eligible Countries
CBP has announced the FY 2026 Caribbean Basin Trade Partnership Act (CBTPA) apparel quotas. The quota period runs from October 1, 2025, through September 30, 2026, covering apparel articles and T-shirts from CBTPA beneficiary countries including Barbados, Belize, Curacao, Guyana, Haiti, Jamaica, Saint Lucia, and Trinidad and Tobago. Duty-free access begins at the quota opening on October 1, 2025.
CBP Issues Updated Entry Filing Guidance on Replacement Duties
CBP has updated entry filing guidance (CSMS #66319804) on replacement duties for certain imports from the European Union, Japan, and the United Kingdom. The update clarifies filing requirements under specific Chapter 99 HTSUS headings/provisions, confirms capped duty rates (15% for EU and Japan; 10% for UK auto parts), and reminds importers that Section 232 duties are not eligible for drawback. Importers who misreported must file post summary corrections.
CBSA Announces Preliminary Determinations on Steel Strapping Imports
The CBSA issued preliminary determinations on steel strapping imports from China, South Korea, Türkiye, and Vietnam. Provisional duties will apply on shipments released after September 16, 2025, to address dumping and subsidy concerns under SIMA.
USTR Seeks Public Comments Ahead of USMCA Joint Review 2026
USTR is seeking public input on the USMCA’s operation and the Competitiveness Committee. Comments and hearing requests are due November 3, 2025, ahead of the Joint Review on July 1, 2026, to decide the agreement’s future and whether to extend it for a new 16-year term.
U.S. Commerce Opens Process for Adding Auto Parts to Section 232 Tariffs Oct. 1
Commerce/BIS issued an interim final rule to expand Section 232 tariffs on auto parts. Starting October 1, 2025, domestic producers can request additions by submitting product details, HTSUS codes, and national security impact data. Public comments close November 3.
CBP Clarifies IEEPA Tariff Refunds Under USMCA Claims
CBP’s updated FAQ explains how importers can claim refunds for IEEPA tariffs on Canada and Mexico imports through USMCA post-importation claims, providing clear filing instructions and eligibility criteria to secure tariff refunds.
CBSA Issues Preliminary Determinations for Thermal Paper Rolls from China
The Canada Border Services Agency has announced preliminary duties on thermal paper rolls imported from China. These measures, under SIMA, aim to address dumping and subsidizing, with detailed rates set to be released soon.
CBSA Updates U.S. Surtax Orders Including Steel, Aluminum and Motor Vehicles (Updated)
As of September 4, 2025, CBSA updated five Canadian Surtax Orders, confirming only one with a value-based exemption, clarifying rules for Chapters 98 and 99, allowing corrections and refunds, and imposing a 25% surtax on U.S. vehicles.
CBSA Imposes Preliminary Anti-Dumping Duties on Carbon and Alloy Steel Wire Imports
The CBSA preliminarily determined dumping of certain carbon and alloy steel wire from 11 countries, imposing provisional duties on imports cleared from September 4, 2025. The investigation follows complaints by Canadian steel producers about unfair pricing and market harm.
New Executive Order Revises U.S. Reciprocal Tariffs, Effective Sept. 8
President Trump’s 2025 executive order modifies reciprocal tariffs to address trade deficits and national security. It updates exempted goods, creates a framework for trade agreements, and directs CBP guidance to ensure effective implementation beginning September 8, 2025.
CBP Outlines Illegal Transshipping Red Flags and Compliance Best Practices
U.S. Customs and Border Protection (CBP) warns of illegal transshipping to evade duties and tariffs. The agency outlines key red flags and recommends compliance measures, including verifying origin markings and monitoring trade patterns to protect supply chains from enforcement actions.
Section 301 Tariff Exclusions Further Extended Through November 29, 2025
The U.S. Trade Representative extended Section 301 tariff exclusions for certain Chinese goods through November 29, 2025, beyond the prior August 31 expiration. This covers 164 product exclusions and 14 exclusions for manufacturing equipment. CBP has issued guidance for claiming these exclusions.
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