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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 The changes take effect for goods entered for consumption, or withdrawn from a warehouse for consumption, on or after 12:01 a.m. ET on June 8, 2026.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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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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New Executive Order on Strengthening Customs Enforcement

On June 3, 2026, President Trump signed the Executive Order “Strengthening Customs Enforcement,” directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to overhaul the rules that govern importers of record (IORs). The accompanying White House Fact Sheet frames the Order as a truly significant tightening of importer responsibilities – higher bonds, mandatory domestic assets, a new “good standing” requirement on all importers, and sharp new limits on foreign IORs. As CBP put it in its announcement, importing into the United States “has for too long been treated as a right and not a privilege.” While the Order has set aggressive deadlines for Customs reforms, it leaves most of the operational details to future rulemaking, and several of those details could reshape day-to-day compliance.  

Overview: What the Executive Order Directs 

Within 180 days, the Order requires the Secretary of Homeland Security to revise importer eligibility rules under 19 U.S.C. § 1484, § 1498, and § 1623, among other authorities. The most notable changes for IORs will be: 

  • A requirement that every IOR maintain, at all times, a minimum level of tangible domestic assets, bonding, or both — plus an increase in the minimum required bond coverage. 
  • Expanded data and identification requirements, including anticipated import volumes, year organized, ownership and beneficial ownership disclosures, business affiliations, and […]
By |2026-06-08T19:30:30-04:00June 4, 2026|Enforcement, U.S. Customs and Border Protection (CBP)|0 Comments
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FDA Announces One-Day Inspection Pilot

The U.S. Food and Drug Administration (FDA) announced that it is piloting one-day inspectional assessments. These assessments will be shorter, more focused, and will complement existing standard FDA inspections.  

Shorter Inspections, More Coverage 

Launched in April 2026, the pilot is part of a broader initiative to make the agency’s inspectional resources more targeted and efficient. The new assessments will allow for broader coverage, enabling the agency to assess more facilities without compromising regulatory rigor. 

The pilot is being conducted across multiple FDA inspectorates, including human and animal foods, biologics, medical products, and clinical research programs. Facilities are selected using risk-based criteria such as:  

  • Product type 
  • Prior inspection outcomes 
  • Operational characteristics  

As of late April 2026, the FDA has completed approximately 46 one-day assessments.  

The agency made clear that one-day inspectional assessments are not intended to replace standard FDA inspections. Instead, they are meant to provide an additional tool to the agency’s enforcement approach. The ‘one-day’ framework is also flexible – investigators retain authority to expand the scope or duration of an assessment if warranted.  

The pilot will continue through fiscal year 2026. The FDA is currently developing evaluation metrics to assess effectiveness, including inspection duration, escalation rates, and the utility of findings in informing risk-based decision-making. 

What Facility Owners and Operators Should Do 

Facility owners and operators should remain ready […]

By |2026-05-26T12:37:26-04:00May 26, 2026|Best Practices, Cosmetics, Enforcement, Food, Import, Medical Devices, U.S. Food and Drug Administration (FDA)|0 Comments
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The Largest Customs Fraud Settlement from the DOJ Trade Fraud Task Force: $549.5 Million and What This Means for Importers 

On May 12, 2026, the Department of Justice announced one of the largest customs fraud settlements in U.S. history. Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC, and four affiliated warehousing companies (“the Defendants”) agreed to pay $549.5 million to resolve False Claims Act (“FCA”) allegations that they knowingly evaded antidumping and countervailing duties on aluminum extrusions imported from China. 

The Scheme: Pallets That Weren’t Pallets 

The underlying conduct was relatively simple. According to the Settlement Agreement, between July 2011 and June 2014, the Defendants knowingly made false statements on CBP Form 7501 Entry Summaries, misrepresenting more than 2.2 million aluminum extrusions as finished merchandise not subject to antidumping and countervailing duties. The mechanism? The extrusions were spot-welded together to make them appear to be functional pallets — and there were no actual customers for these “pallets.” So, no merchandise was ever actually sold. 

Criminal Conviction Came First 

This civil settlement did not arise in a vacuum. In August 2021, a jury in the Central District of California convicted the Defendants of conspiracy to defraud the United States, wire fraud, and passing false or fraudulent documents through a customs house. Following sentencing, the defendants were ordered to pay restitution of approximately $1.83 billion to CBP. The May 2026 FCA settlement resolves the parallel civil litigation arising from the same conduct. Importantly, this civil resolution does not absolve the defendants from any criminal liability outlined in […]

By |2026-05-22T15:16:34-04:00May 22, 2026|AD/CVD, Enforcement, Import, International Trade, U.S. Customs and Border Protection (CBP), U.S. Department of Justice (DOJ), Uncategorized|0 Comments
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