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2026

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New Section 232 Action: What the June 2026 Aluminum, Steel & Copper Proclamation Means for Your Imports

Topline summary: On June 1, 2026, President Trump amended the Section 232 tariff framework for aluminum, steel, and copper. Importers of agricultural, industrial, and mobile equipment may qualify for temporarily reduced rates of 10–15%, while certain furniture parts, lithographic plates, and steel racks are newly dutiable for the first time. With a December 31, 2027, sunset on all temporary reductions, importers should audit their HTS classifications now to avoid overpaying or underpaying.

On June 1, 2026, the President issued Proclamation 11032, “Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper Into the United States,” amending the April 2026 Section 232 framework (Proclamation 11021). U.S. Customs and Border Protection (CBP) followed on June 5 with implementation guidance in CSMS #68855869. The changes take effect for goods entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 a.m. ET on June 8, 2026. 

This is not a uniform tariff cut. The proclamation does two opposite things at once. It reduces Section 232 rates on a large block of machinery and equipment, while simultaneously adding new products to the duty regime for the first time. If you import equipment, the change may help you. If you import certain furniture parts, lithographic plates, or steel racks, you may have just become newly dutiable.  

What Changed on June 8 

  1. New products […]

By |2026-06-08T17:20:18-04:00June 8, 2026|Import, International Trade, tariffs, Trade Policy, U.S. Customs and Border Protection (CBP), U.S. Department of Commerce (DOC), U.S. Office of the United States Trade Representative (USTR)|0 Comments
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A Court Just Blocked an EAPA Evasion Action Over a 519% Duty Rate

Quick Summary: On April 24, 2026, the U.S. Court of International Trade did something importers rarely see – it stepped in mid-investigation and blocked U.S. Customs and Border Protection (CBP) from enforcing interim measures in an Enforce and Protect Act (EAPA) evasion case. The measures had saddled the importer, ICON EV LLC, with a combined antidumping and countervailing duty (AD/CVD) cash-deposit rate of 519.23% and a “live entry” requirement that, on the company’s evidence, would have pushed it into bankruptcy within a month. The decision, ICON EV LLC v. United States, Slip Op. 26-42, is a meaningful crack in what has felt like an impenetrable EAPA enforcement wall, and it offers a roadmap for importers caught in the same trap. 

What is an EAPA evasion investigation? 

The Enforce and Protect Act gives CBP a fast, powerful tool to police the evasion of AD/CVD orders. When a competitor or a domestic industry coalition files a “reasonable allegation” that an importer is dodging duties through transshipment, misclassification, undervaluation, or other schemes, CBP must open an investigation within 15 business days and issue a final determination within 300 days. 

What many importers do not realize is that within 90 days of opening the investigation, CBP must impose “interim measures” if it forms a “reasonable suspicion” of evasion. Those measures can include suspending or extending liquidation of entries, requiring “live entry” (full documentation and duty payment before goods are released), and imposing AD/CVD cash-deposit rates. And critically, the statute does not require CBP to give the importer notice or a chance to respond before those interim measures […]

By |2026-06-08T19:35:02-04:00June 5, 2026|AD/CVD, Enforcement, U.S. Department of Commerce (DOC)|0 Comments
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FTC Cracks Down on False “Made in the USA” Claims 

The Federal Trade Commission (FTC) recently announced law enforcement actions involving three companies that falsely claimed that their products were made in the United States.  

Made in the USA

The “Made in the USA” labeling rules were enacted to prevent deceptive advertising and ensure customers can make informed purchasing choices. The concept of labeling products with the correct country of origin dates all the way back to the McKinley Tariff Act in 1890, and Congress and federal agencies have updated “Made in the USA” rules over the years.  

FTC Jurisdiction 

The FTC is charged with preventing deception and unfairness in the marketplace. Under the FTC Act, the Commission may bring legal action against “false or misleading claims that a product is of U.S. origin”. The agency is authorized to issue a civil penalty of up to $40,654 per violation. 

The FTC has issued guidance on complying with the “Made in the USA” standard, most recently in 2021. View the latest guidance here.

When Can I Say Made in the USA? 

For a product to be considered as “Made in the USA” without qualification, that product must be “all or virtually all” made in the U.S. How the Commission determines whether a product is “all or virtually all” made in the U.S. is by looking at whether there was “a ‘reasonable basis’ to support the claim at the time it is made”. To prove […]

By |2026-06-05T11:20:09-04:00June 5, 2026|Best Practices, Enforcement, Import, International Trade, Labeling, U.S. Federal Trade Commission (FTC)|0 Comments
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USTR Launches New Section 301 Actions: Key Developments for Importers 

The Office of the United States Trade Representative (USTR) has recently announced a series of significant Section 301 actions targeting a range of trade-related concerns, including intellectual property protection, forced labor, and alleged unfair trade practices. Collectively, these developments demonstrate the Administration’s continued willingness to utilize Section 301 as a tool to address perceived barriers to U.S. commerce and advance broader trade policy objectives. 

Vietnam

On May 29, 2026, USTR published a Federal Register Notice announcing an investigation of Vietnam under Section 301 of the Trade Act of 1974. The investigation follows identifying Vietnam as a Priority Foreign Country in the 2026 Special 301 Report, which was published on April 30, 2026. 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

Once the investigation is complete, Ambassador Greer will determine what, if any, responsive action should be taken to address them. Comments in this proceeding are due July 2, 2026. 

Brazil

On June 2, 2026, USTR published a Federal Register Notice announcing a determination under Section 301 that certain of Brazil’s acts, policies, and practices are unreasonable and burden or restrict U.S. commerce, and are thus actionable under Section 301(b) of the Trade Act. These acts, policies, and practices include: 

    […]
By |2026-06-05T11:10:41-04:00June 5, 2026|Enforcement, Enforcement, Forced Labor, International Trade, Special 301, tariffs, Trade Policy, U.S. Office of the United States Trade Representative (USTR)|0 Comments
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Breaking Trade News: Sweeping CBP Executive Order, IEEPA CIT Appeal, USTR 301 Actions

Here is a recap of the latest customs and international trade news: 

Administration 

  • On June 3, 2026, President Trump signed an Executive Order that aims to strengthen customs enforcement. The order increases bonding and data requirements for IORs, prohibits foreign importers from filing informal entries, requires additional documentation and certifications from importers, among other requirements. 
  • On June 1, 2026, President Trump issued a Proclamation providing 232 tariff reductions for agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation, and air conditioning equipment. The reductions take effect June 8, 2026.

Courts   

  • On June 2, 2026, the United States filed an appeal of the Court of International Trade’s April 17 order directing CBP to refund duties imposed under the International Emergency Economic Powers Act (IEEPA). 

Customs and Border Protection (CBP)   

  • CBP announced that it is conducting a National Customs Automation Program test of a new method of data collection for crude oil transported through pipelines to the U.S.  

United States Trade Representative (USTR) 

  • USTR published a Federal Register Notice proposing action under 301 against 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced […]
By |2026-06-12T10:13:14-04:00June 5, 2026|news, Snapshot|0 Comments
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