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
In the latest development in United States-Canada trade relations, 50% additional duties, announced in three separate proclamations issued on July 20, 2026, took effect as of 12:01 a.m. eastern time on August 22, 2026. President Donald Trump imposed the additional duties pursuant to Section 338 of the Tariff Act of 1930, which empowers the President to impose additional duties (not exceeding 50%) on imports from a foreign country to offset the burden or disadvantage caused by that country’s unequal imposition on or discrimination against U.S. commerce.
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 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.
On June 23, 2026, CBP via CSMS 69035485 issued guidance explaining which reconciliation-flagged entries will be eligible for the next phase of the Consolidated Administration and Processing of Entries (CAPE) tariff refund tool, launching June 29, 2026.
USTR Proposes Section 301 Tariffs on Brazil
On June 1, 2026, the United States Trade Representative (“USTR”) proposed under Section 301 of the Trade Act of 1974 (“Section 301”) to impose tariffs on imports of goods from Brazil due to Brazil’s practices involving digital trade and electronic payment services, unfair and preferential tariffs, anti-corruption enforcement, intellectual property protection, ethanol market access, and illegal deforestation.
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.
IEEPA Refund Updates: CBP Targets May 11 for First IEEPA Duty Refunds
On April 28, 2026, Judge Richard K. Eaton of the U.S. Court of International Trade issued an Order in Euro-Notions Florida, Inc. v. United States, et al. (Court No. 25-00595) addressing early implementation progress for CBP’s new Automated Commercial Environment (“ACE”) functionality designed to refund International Emergency Economic Powers Act (“IEEPA”) duties, including interest. The order follows CBP’s rollout of Phase 1 of its Consolidated Administration and Processing of Entries (“CAPE”) tool on April 20, 2026, and reflects issues raised during a closed conference held on April 28 regarding access, usability, and the treatment of certain categories of entries.
On April 15, 2026, the U.S. Court of International Trade (“CIT”) ordered U.S. Customs and Border Protection (“CBP”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) to sit for depositions in a case filed by an importer seeking refunds of tariffs imposed under Section 232 of the Trade Expansion Act of 1962 (“Section 232”).
[UPDATED: This post has been updated to incorporate CBP’s April 13, 2026 CSMS #68340863] U.S. Customs and Border Protection (“CBP”) issued guidance today explaining importers must utilize the Automated Commercial Environment (“ACE”) portal to request consolidated refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”) which were found to be