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Nithya Nagarajan

Nithya’s extensive background in U.S. trade issues spans 25 years and includes various roles in a number of federal government agencies, including the Department of Commerce Department of Justice, and the U.S. Court of International Trade. She assists clients with administrative and regulatory actions before the Department of Commerce, International Trade Commission and U.S. Customs and Border Protection (CBP) and defends clients in appeals before the Court of International Trade, Court of Appeals for the Federal Circuit, NAFTA panels and the World Trade Organization. In addition to her body of U.S. experience, Nithya is also well-versed in international trade issues in China and India.

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Close-up zoom of customs officer stamping “IMPORT TARIFF PAID” on cargo paperwork, blurred shipping containers in background, logistics port atmosphere, documentary editorial style

On September 2, 2026, U.S. Customs and Border Protection (CBP) issued an advance notice of proposed rulemaking (Notice), titled Heightened Import Disclosures for Supply Chain Visibility (Docket No. USCBP-2026-1058; RIN 1685-AA47).

The Notice, issued as part of Executive Order 14411, “Strengthening Customs Enforcement,” aims to enhance transparency across supply chains and strengthen efforts to detect and prevent illicit imports, including illegal transshipment. To achieve this, CBP is exploring significant changes to import filing and record keeping processes.

Heap of shiny metal steel pipes with selective focus effect

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.

Canadian flag push pin marking Canada on a map

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. 

Cardboard box with different medicine pills, tablets and capsules on a blue background with copy space. Buying drug delivery concept.

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.

National flags of China and the United States waving in the wind on a clear day

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 …

Weathered Wooden Fence Isolated on White Background - Rustic Stock Photo

On September 24, 2026, the American Alliance of Wooden Fence Producers, comprised of Alta Forest Products, Mendocino Forst Products, and Sierra Pacific Industries, (Petitioner) filed companion petitions requesting the imposition of antidumping and countervailing duties on imports of certain wooden fence pickets from the People’s Republic of China (China).

Round cheese pizza is resting in open corrugated box on wooden tabletop, showing charred crust

On September 9, 2026, the American Pizza Boxes Manufacturers Coalition (comprised of Smurfit Westrock plc and Pratt Industries, Inc.) and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (USW) (collectively Petitioners) filed a petition for the imposition of antidumping duties on imports of corrugated pizza boxes from the People’s Republic of China (China), Malaysia, and the Republic of Türkiye (Turkey), and countervailing duties on imports from Turkey.

On September 1, we posted on the Government Enforcement, Compliance & Investigations Report about how a Taiwan-based LED manufacturer and its U.S. subsidiary agreed to pay $5.15 million to resolve False Claims Act allegations that they evaded Section 301 tariffs by transshipping Chinese-origin LEDs through Taiwan. The settlement, announced August 5, 2026 by the U.S. Attorney’s…