2026

U.S. Customs and Border Protection (“CBP”) issued guidance on how importers need to report and classify goods subject to the revised steel, aluminum, and copper tariffs announced by the Trump Administration on April 2, 2026. We encourage importers to review the list of HTS number affected by the metal tariffs to ensure compliance with the below reporting requirements.

On April 2, 2026, the Trump Administration issued a proclamation imposing Section 232 tariffs on imports of patented pharmaceutical products and active pharmaceutical ingredients (“APIs”) pursuant to Section 232 of the Trade Expansion Act of 1962 (“Section 232”). 

On March 31, 2026, the Office of Foreign Assets Control (“OFAC”) issued an advisory (the “Advisory”) regarding sham transactions and their use in evading US sanctions. OFAC described sham transactions as occurring when “blocked persons, often operating through proxies or other intermediaries, effectuate transfers or establish arrangements that conceal–rather than genuinely extinguish–a continuing interest in property.”

On April 2, 2026, U.S. OCTG Manufacturers Association (“USOMA”), United States Steel Corporation (“U. S. Steel”), and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC (the “USW”) (collectively “Petitioners”), filed a petition for the imposition of antidumping duties on certain oil country tubular goods (“OCTG”) from Austria, Taiwan, and the United Arab Emirates (“UAE”) and countervailing duties on certain oil country tubular goods (“OCTG”) from Austria.

On March 31, 2026, Brandon Lord, the Executive Director of the U.S. Customs and Border Protection (“CBP” or “Customs”) Trade Programs Directorate, Office of Trade, filed a status update (the “Declaration”) with the Court of International Trade (“CIT”) further outlining Customs’ progress in developing the Consolidated Administration and Processing of Entries (CAPE) functionality within ACE. CAPE has four integrated components: Claim Portal, Mass Processing, Review and Liquidation/Reliquidation, and Refund.

The U.S. Supreme Court recently heard oral arguments in Flowers Foods, Inc. v. Brock, No. 24-935, a case to determine whether a last-mile delivery driver who picks up products and delivers them within the same state qualifies as a “transportation worker engaged in interstate commerce” and is exempt from the Federal Arbitration Act (FAA)

On March 19, 2026, Brandon Lord, the Executive Director of U.S. Customs and Border Protection, filed a status update with the U.S. Court of International Trade (“CIT”) outlining CBP’s progress in developing a new Automated Commercial Environment (“ACE”) functionality intended to support refunds of tariffs that were imposed under the International Emergency Economic Powers Act (“IEEPA”).

On March 18, 2026, the Trump Administration announced a 60-day waiver of the Jones Act, which requires that cargo transported between U.S. ports be carried on vessels that are U.S.-built, U.S.-flagged, and U.S.-crewed. Pursuant to Cargo Systems Messaging Service (“CSMS”) Message No. 68096516, the waiver took effect March 18, 2026, and is currently scheduled