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Bosch Agrees to Pay $36 Million Penalty to BIS for Unauthorized Shipments to Huawei 

Robert Bosch GmbH (Bosch), the German multinational engineering and technology company, has agreed to pay a $36,184,680 penalty to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for exporting controlled items to Huawei Technologies Co. and its affiliates without the required U.S. government authorization. 

What Happened 

Between September 2020 and September 2024, Bosch exported approximately $72.4 million worth of Micro-Electro-Mechanical Systems (MEMS) sensor products and automotive software from abroad to Huawei and its affiliates. The exported items were subject to the Export Administration Regulations (EAR) under the Foreign Direct Product Rule, a rule that extends U.S. export controls to certain foreign-produced items that incorporate U.S. technology or are manufactured using U.S. equipment. Because Huawei and its affiliates are listed on BIS’s Entity List, any shipment of items subject to the EAR requires a license from BIS. No such license or authorization was obtained. 

The MEMS sensors at issue are widely used in consumer products, including smartphones, wearable technology, and automobiles. 

The Penalty 

In addition to the $36 million BIS civil penalty, Bosch separately agreed with the Department of Justice to disgorge profits from the transactions, with an actual payment of approximately $3.6 million. BIS suspended approximately $3.6 million of its penalty as credit for the disgorgement, bringing Bosch’s total financial exposure to roughly $39.8 million. 

Bosch filed a Voluntary Self-Disclosure with […]

Navigating IEEPA Tariff Refunds: Legal and Compliance Considerations

Copyright 2025 Bloomberg Industry Group, Inc. (800-372-1033) Reproduced with permission. Navigating IEEPA Tariff Refunds: Legal and Compliance Considerations.

Editor’s Note: The recent Supreme Court decision invalidating tariffs imposed under the International Emergency Economic Powers Act (IEEPA) has opened the door to tariff refunds for importers. However, amid the newly implemented administrative process for refunds and heightened enforcement scrutiny, importers must do more than simply file a claim.

Importers pursuing refunds of tariffs imposed under IEEPA must navigate a developing framework that blends judicial relief with a newly established administrative process. U.S. Customs and Border Protection (CBP) has implemented the Consolidated Administration and Processing of Entries (CAPE) as the primary mechanism for submitting refund claims following the Supreme Court’s decision and subsequent orders from the U.S. Court of International Trade (CIT). While CAPE provides a pathway to recovery, it is limited in scope, phased in its application, and subject to ongoing legal and procedural uncertainty. Against this backdrop, importers must approach refund claims with a coordinated strategy that accounts for litigation posture, operational readiness, and heightened compliance expectations.

Requesting Refunds through CAPE

Following the Supreme Court decision and subsequent CIT orders, CBP developed the Consolidated Administration and Processing of Entries (CAPE) – the agency’s official process for handling IEEPA refund claims.

CBP launched Phase 1 of CAPE on April 20, 2026. The following entry types are eligible for refunds […]

By |2026-06-17T10:43:03-04:00June 17, 2026|Bloomberg, Bloomberg Import|0 Comments

CBP Just Rewrote the Forced Labor Rulebook: What the New Operational Guidance Means for Importers

Short summary: On June 9, 2026, CBP issued new guidance supplementing its 2022 UFLPA guidance and other resources with a single document covering every forced-labor authority it enforces. The new guidance outlines CBP’s detention and exclusion processes and gives practical guidance on how to respond.


On June 9, 2026, U.S. Customs and Border Protection (CBP) published its new Forced Labor Enforcement Operational Guidance for Importers (Publication No. 5560-0526). It is not a refresh. It updates the June 13, 2022, UFLPA Operational Guidance for Importers and, for the first time, consolidates all forced-labor enforcement authorities CBP wields into a single 89-page reference. 

That consolidation is the story. Until now, importers had to stitch together separate sources to understand how the Uyghur Forced Labor Prevention Act (UFLPA), Withhold Release Orders and Findings under 19 U.S.C. § 1307, and the Countering America’s Adversaries Through Sanctions Act (CAATSA) actually differ in practice. CBP has now mapped all of them — including the exact timelines, the review paths, and the documentation bar — in one place. The practical effect: ignorance of the process is no longer a defensible position. 

The one-line summary every importer needs 

CBP detains or excludes goods it suspects were made, wholly or in part, with forced labor — and the burden is on you to prove they weren’t, on a clock that can […]

Breaking Trade News: 23 States File 122 Appeal, IEEPA Refund Update, OFAC Sanctions

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

Courts    

  • Twenty-three non-importer states filed a notice to appeal the Court of International Trade’s (CIT) May 7 ruling against Section 122 tariffs. 
  • The CIT held an IEEPA refund status hearing on June 9, during which CBP said that Phase 3 of the Consolidated Administration and Processing of Entries (CAPE) will be ready in July, but that the agency is not authorized to process any finally liquidated entries for refunds. 

Customs and Border Protection (CBP)    

  • CBP announced that it plans to revoke hundreds of customs brokers’ licenses for failure to file the triennial status report and pay applicable fees.  
  • CBP’s executive director of the trade programs directorate, Brandon Lord, filed an IEEPA refund with the CIT, stating that the Treasury Department will continue to pay refunds while the IEEPA litigation continues. 
  • CBP issued a Harmonized System Update on June 7, containing tariff adjustments for imports of aluminum, steel, and copper into the U.S. 
  • Ahead of the FIFA World Cup, CBP […]
By |2026-06-12T10:16:45-04:00June 12, 2026|news, Snapshot|0 Comments

FDA Just Added the First New Sunscreen Active Ingredient in Nearly 30 Years

Topline summary: The FDA has approved bemotrizinol as the first new active sunscreen ingredient in nearly 30 years, creating both an opportunity and a compliance obligation for OTC drug and cosmetic importers. Being permitted to use the ingredient is not the same as being compliant. Manufacturers and importers still need to confirm their reformulated product meets every condition of the updated monograph, including SPF testing, Drug Facts labeling, and valid FDA drug establishment registration and drug listing before goods ship. 

On June 9, 2026, the FDA issued a final order adding bemotrizinol to the OTC sunscreen monograph (M020)—the first new sunscreen active ingredient permitted in the United States in nearly three decades. The ingredient, submitted by DSM Nutritional Products at concentrations up to 6 percent and long marketed in Europe, is now recognized by FDA as generally recognized as safe and effective (GRASE) for adults and children six months and older.

For manufacturers and importers of sunscreens and other OTC drug and cosmetic products, this is a real opportunity—and a regulated change that touches your formulation, your labeling, your drug establishment registration, and your treatment at the U.S. border. A new permitted active ingredient is not a green light to ship. It is a trigger to confirm your pre-compliance posture before the first entry.

The Challenge: “Permitted” Is Not the Same as “Compliant”

A GRASE listing means bemotrizinol may be used in OTC sunscreens. It does not mean your reformulated product automatically conforms to monograph M020. Sunscreen is regulated by FDA as an […]

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