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Bilal Hassan

Bilal’s practice focuses on U.S. customs and import compliance matters, complemented by broad experience in export controls. He regularly advises clients on complex regulatory issues before key U.S. administrative agencies, including U.S. Customs and Border Protection (CPB), the Department of Commerce (DOC), the Department of Homeland Security (DHS), and the Bureau of Industry and Security (BIS).

Excess Capacity

On September 30, 2026, members of the Global Forum on Steel Excess Capacity (GFSEC) adopted a Comprehensive Framework for Joint Action (the Framework) to address persistent global steel excess capacity. Representing market-based steel producing economies that account for nearly 56 percent of global steel imports, GFSEC members committed to a coordinated set of actions aimed at restoring a level playing field and protecting the long-term viability of the international steel industry.

GFSEC members include Argentina, Australia, Austria, Belgium, Brazil, Canada, the European Union, Finland, France, Germany, Greece, Hungary, Italy, Japan, the Republic of Korea, Luxembourg, Mexico, the Netherlands, Norway, Poland, the Slovak Republic, South Africa, Spain, Sweden, Switzerland, Türkiye, the United Kingdom, and the United States.

U.S. Customs and Border Protection (CBP) has issued guidance (CSMS #70050970) on Presidential Proclamations 11061 (alcohol), 11062 (dairy), and 11063 (motor vehicles), which exclude a defined list of Canadian products from importation into the United States. 

On September 28, 2026, U.S. Customs and Border Protection (CBP) issued CSMS #70054007, providing updated guidance on the implementation of the Section 232 duties on imported pharmaceuticals and pharmaceutical ingredients imposed under Presidential Proclamation 11020. The guidance also incorporates the Department of Commerce’s (DOC) September 23, 2026 Federal Register notice (91 FR 60360), which identifies products and jurisdictions eligible for certain duty-free treatment and implements several technical corrections to the pharmaceutical tariff regime.

On September 27, 2026, the White House issued a press release announcing the creation of the U.S.-China Board of Trade, a new government-to-government body tasked with managing trade between the two countries. Critically, the press release indicated that the two sides released a companion “30-for-30” framework aimed at reducing tariffs on products. 

What is the Board …

United States and Jordan Sign Reciprocal Trade Agreement

On July 21, 2026, the United States and Jordan signed a reciprocal trade agreement under which Jordan will receive a preferential 10% U.S. tariff rate, rather than the higher 12.5% rate that may apply to certain countries under the forthcoming forced labor tariff regime. Under the agreement…

The Office of the United States Trade Representative (USTR) has announced the imposition of new Section 301 tariffs under the Trade Act of 1974. Following investigations into global forced labor policies, the USTR has determined that 60 economies have failed to adequately impose or enforce prohibitions on the importation of goods produced with forced labor. The tariffs take effect at 12:01 a.m. Eastern Time beginning July 24, 2026.

On July 20, 2026, President Trump issued a new Presidential Proclamation aimed at further strengthening the U.S. aluminum industry. The latest Proclamation builds upon the existing Section 232 aluminum tariff regime by introducing a strategic investment incentive program designed to bring primary aluminum production back to the United States.

On July 20, 2026, President Trump signed a Presidential Proclamation imposing 50% tariffs on certain Canadian products, including goods that qualify for preferential treatment under the United States-Mexico-Canada Agreement (USMCA), effective 12:01 a.m. Eastern Time on August 19, 2026. 

On June 29, 2026, U.S. Customs and Border Protection (CBP) released CSMS # 69087399, providing guidance for the import adjustment offset program applicable to Section 232 duties on automobile and medium and heavy-duty vehicle (MHDV) parts. We summarize below the latest guidance from CBP and procedural steps for claiming offsets against Section 232 duties.