Monday Morning eBriefing

Customs and Border Protection (CBP) on June 5 published detailed guidance for importers and customs brokers related to implementing the June 1 Proclamation, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” amending Proclamation 11021, adding new metals derivatives subject to Section 232 duties, and reducing the Section 232 duty rates for other derivatives. Specifically, this following guidance provides instructions for importers, customs brokers, and filers on submitting entries to CBP on certain steel, aluminum, and copper articles and their derivatives from all countries as provided in HTSUS headings 9903.82.01 to 9903.82.26.

The President issued an Executive Order on June 3, that will impact all importers and entities connected to import transactions. This Executive Order proposes a broad tightening of U.S. customs enforcement, with a strong emphasis on importer accountability and vetting, foreign importer restrictions, disclosure obligations, and higher penalties. The most immediate practical effect for clients is a likely increase in enforcement, bonding, data submissions, and compliance requirements for importers of record (IORs), especially foreign IORs. The E.O. effectively creates a Customs Modernization bill that will impact significant portions of the Customs Regulations.

The Consumer Product Safety Commission (CPSC) final eFiling webinar on June 3 features valuable insights from NCBFAA Regulatory Agencies Committee (RAC) member Courtney Peterson of Expeditors. Peterson gave first-hand pointers to customs brokers and importers on how to get started. “It’s never too late to start early,” she said.

The Environmental Protection Agency (EPA) announced a significant enforcement action on June 1, 2026, filing an administrative complaint against Wego Chemical Group for a pattern of Toxic Substances Control Act (TSCA) violations tied to its chemical import operations. The case carries potential penalties approaching $34 million.

A summary of the latest legislative and regulatory transport, logistics and trade sector updates brought to you by our NCBFAA Transportation Counsel firm Venable.

A summary of the latest customs and cross-border trade regulatory updates brought to you by our NCBFAA Customs Counsel firm Sandler, Travis & Rosenberg.

On behalf of NCBFAA's Board of Directors, Leadership and Staff, we want to take a moment to acknowledge and welcome Evolve Trade Services, Titanium Transportation Group, Thomson Reuters, and Zonos, which have recently joined our association. We're so excited to have these firms join our organization and we are happy to assist in any way we can!

NCBFAA Members are encouraged to watch this animated video, CBP Protects U.S. Businesses: EAPA Success Story, to see how Customs and Border Protection (CBP) utilized the Enforce and Protect Act (EAPA) to uncover and dismantle a sophisticated $300 million duty evasion scheme involving imported Chinese mattresses.

NCBFAA has opened registration for the 2026 Government Affairs Conference (GAC) to be held at the JW Marriott, Washington, D.C. on Sept. 27-29. We urge attendees to register now to take advantage of the special room block rate and early bird savings! By participating in the GAC, you can effectively shape and grow our industry.

The Office of the U.S. Trade Representative (USTR) on June 2 announced it has determined under Section 301 of the 1974 Trade Act that the actions, policies, and practices of 60 countries show they are trading in forced labor-made goods which if imported into the U.S. should be subject to 10-12.5% tariffs.

The Office of the U.S. Trade Representative (USTR) on June 2 announced in a Federal Register notice that it has established a public comment process to develop a U.S.-China Board of Trade—a new “government-to-government mechanism” intended to manage bilateral trade between the U.S. and China going forward.

After identifying Vietnam as a Priority Foreign Country in the 2026 Special 301 Report, which was published on April 30, U.S. Trade Representative Jamieson Greer on May 29 initiated an investigation of Vietnam under Section 301 of the 1974 Trade Act. “The investigation will seek to determine whether Vietnam’s persistent failure to resolve long-standing concerns about intellectual property (IP) protection and enforcement is unreasonable or discriminatory and burdens or restricts U.S. commerce,” the Office of the U.S. Trade Representative (USTR) said.

The Office of the U.S. Trade Representative (USTR) in a June 1 Federal Register notice said based on its investigation of Brazil’s trade practices that certain products from the country which are imported into the U.S. should be subject to a Section 301 tariff of 25%, with exemptions for those goods already subject to Section 232 tariffs and certain products listed in the Annex provided at the end of the notice.

President Trump in a proclamation on June 1 announced that his administration is adjusting certain Section 232 metal-based product tariffs which become effective at 12:01 a.m. ET on June 8. The proclamation adjusts the tariffs on agricultural equipment, such combines and harvesters, as well as certain other equipment including heating, ventilation, and air conditioning (HVAC) systems for residential use, from 25% to 15%, while it expands the existing category of industrial equipment subject to a 15% tariff to include mobile industrial equipment, like bulldozers and forklifts, when imported from trade deal countries that are entitled to such treatment.

The Department of Justice (DOJ) on May 29 filed its intent to appeal the Court of International Trade’s injunction to refund all the IEEPA tariffs, adding that the Trump Administration will "seek a stay of the injunction except as to the particular importer plaintiffs in each case in which the Court has entered the injunction.”

Deputy U.S. Trade Representative Jeff Goettman of the Office of the U.S. Trade Representative (USTR) on May 28-29 led a U.S. delegation to Mexico City for the first bilateral negotiating round related to the first Joint Review of the United States-Mexico-Canada Agreement (USMCA)with Mexico which included negotiations on economic security and rules of origin for key industrial goods.

A summary of the latest customs and cross-border trade regulatory updates brought to you by our NCBFAA Customs Counsel firm Sandler, Travis & Rosenberg.

Customs and Border Protection (CBP) on May 26 submitted its status update in Euro-Notions, the lead IEEPA refund case, to the U.S. Court of International Trade (CIT). While the update does not provide information on subsequent phases, CBP does provide that, “approximately $85 billion in both potential and certified refunds have been accepted for processing in the Consolidated Administration and Processing of Entries (CAPE).

A summary of the latest legislative and regulatory transport, logistics and trade sector updates brought to you by our NCBFAA Transportation Counsel firm Venable.

Customs and Border Protection (CBP) on May 26 updated its IEEPA FAQ page with two new responses, both addressing reconciliation. NCBFAA notes in particular the advice to hold off on filing reconciliation unless your filing deadline is within 30 days.