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
The U.S. Department of Justice (DOJ) and the Department of Homeland Security (DHS) have sent a clear message that the era of treating customs fraud as a manageable cost of doing business is over, and there will be a significant escalation of U.S. trade fraud enforcement policy moving forward.
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).
Companies importing consumer products into the United States now face a significant compliance change. As our colleagues on Product Perspective explain, effective July 8, the U.S. Consumer Product Safety Commission’s (CPSC) new eFiling requirement requires importers to electronically submit product safety certificate information at the time of entry.
On June 3, 2026, President Trump issued an executive order (“EO”) directing U.S. Customs and Border Protection (“CBP”) to reform many of its enforcement provisions. Titled “Strengthening Customs Enforcement,” the EO targets preventing the importation of unlawful and dangerous goods, tightening eligibility and identification requirements for importers of record (“IORs”), and ensuring compliance with Federal laws and timely collection of duties.
On May 27, 2026, following a closed-door conference in Euro-Notions Florida v. United States (CIT # 25-00595) (“Euro-Notions”), Judge Eaton issued two (2) orders which will require U.S. Customs and Border Protection (“CBP”) to explain the Government’s position on issuing IEEPA refunds for all entries, including those that have liquidated beyond the statutory reliquidation period
This update covers three key developments this week: (1) U.S. Customs and Border Protection (“CBP”) filed its latest status update in Euro-Notions on April 14, 2025; (2) Judge Eaton thereafter issued another order; and (3) next steps / recommendations for importers.
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 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.
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”).