CBP to Verify Importer of Record Information on Form 5106
CBP announced it is executing enhanced enforcement procedures to verify the accuracy of importer of record information provided on CBP Form 5106, and importers of record or their brokers must submit complete and accurate information by September 18 to avoid consequences. The initiative follows the
President Donald Trump issued a proclamation on August 18, 2026, pushing back the effective date of 50% Section 338 tariffs on certain Canadian goods by three days, to 12:01 a.m. Eastern on August 22, 2026. The delay was announced just hours before the new Section 338 tariffs were to go into effect on August 19
U.S. Customs and Border Protection (“CBP”) issued a Federal Register notice that it is now ready to execute “executing enhanced enforcement procedures.” CBP has indicated that it will start verifying importer of record information provided by each importer on CBP Form 5106, and importers of record have until September 18, 2026, to correct any errors
On August 13, 2026, the White House Office of Trade and Manufacturing Policy released a report identifying more than 40 countries it characterizes as presenting an elevated risk of illegal transshipment of Chinese-origin goods into the United States. The report also states that an artificial-intelligence-driven enforcement tool, referred to as “Detective Border,” is under development to support U.S. Customs and Border Protection (CBP) in detecting and interdicting such shipments.
On July 15, 2026, the Office of the United States Trade Representative (USTR) concluded its Section 301 investigation into Brazil’s unreasonable acts, policies, and practices by imposing a 25% tariff on most imports from Brazil, effective July 22, 2026. The action follows more than a year of investigation, multiple rounds of negotiations with Brazilian officials, a public comment period that generated over 360 written submissions, and a two-day public hearing held on July 6–7, 2026.
On July 16, 2026, the U.S. Senate confirmed five nominees to serve as Commissioners of the U.S. International Trade Commission (USITC or Commission) by voice vote, restoring the agency to its full six-member panel for the first time in years. The Senate Finance Committee had approved all five nominations with large bipartisan support the day prior.
On July 15, 2026, U.S. Customs and Border Protection (CBP) issued CSMS #69252300, providing guidance on the new reporting requirements for the countries of smelt and cast for imports of certain copper articles under Proclamation 11021. Beginning July 30, 2026, importers of specified copper wire and cable products will be required to submit smelt and cast country information through the Automated Commercial Environment (ACE).
On June 11, 2026, the U.S. Court of Appeals for the Federal Circuit (CAFC) granted the federal government’s motion for a stay pending appeal, pausing enforcement of a U.S. Court of International Trade (CIT) injunction on the collection of Section 122 duties against the State of Washington and two private businesses – Burlap and Barrel, Inc. and Basic Fun, Inc.
The U.S. Government withdrew its petition for a writ of mandamus at the U.S. Court of Appeals for the Federal Circuit (“Federal Circuit”). On June 9, 2026, the Federal Circuit granted the Government’s request to withdraw the petition and dismissed the mandamus proceeding in In re United States, Fed. Cir. # 26-144, before Senior Judge Richard K. Eaton.
On June 2, 2026, the Office of the United States Trade Representative (“USTR”) announced a public comment period related to the development of a new government-to-government mechanism, a proposed U.S.-China “Board of Trade,” intended to provide an ongoing channel for managing aspects of bilateral trade between the United States and China.