Key Points President Donald Trump’s “Strengthening Customs Enforcement” executive order directs CBP to overhaul customs enforcement, raising IOR eligibility thresholds and bond requirements for all entries. The executive order draws a bright line between “U.S. IORs” and “foreign IORs,” imposing stricter eligibility, bonding, and informal entry restrictions on foreign IORs and tying benefits to CTPAT validation. CBP must implement a “good standing” regime and overhaul the IOR registry within 180 days, using compliance history and customs liability payment records...

The Trump administration has recently made several trade policy and tariff litigation announcements affecting companies importing goods into the United States and downstream buyers: (1) the Department of Justice appealed the Court of International Trade (CIT)’s “universal” IEEPA refund order and submitted a filing to the CIT announcing that only unliquidated entries and entries within 90 days post-liquidation would be processed for refunds through the Consolidated Administration and Processing of Entries (CAPE) system; (2) the U.S. Trade Representative (USTR)...

Key Points USTR has proposed additional Section 301 tariffs of 10 – 12.5% on imports from all 60 economies under investigation for failing to impose and/or enforce forced labor import bans, affecting nearly all U.S. import trade by value. Companies with global supply chains should immediately model the cost impact of these proposed tariffs across their sourcing footprint and evaluate whether their products may qualify for limited exemptions, including those for Section 232 goods, certain raw materials, and products posing economy-wide...

What happened?  President Trump issued a Proclamation on June 1 further modifying the Section 232 tariff regimes applicable to imports of aluminum, steel, copper, and certain derivative products. The Proclamation establishes a temporary tariff framework, effective June 8, 2026 through December 31, 2027, for certain products identified in Annex I-C, including a generally applicable 25% duty rate, alternative tariff treatment for products from specified trading partners, and special rules for qualifying United States–Mexico-Canada Agreement (USMCA) products. This Proclamation also lowers the threshold for...

Key Points The DOJ has appealed Judge Richard K. Eaton’s universal refund order requiring CBP to return about $166 billion in IEEPA duties. The government’s three-category framework for IEEPA refunds distinguishes unliquidated entries, finally liquidated entries with CIT suits, and finally liquidated entries without suits, with the last category driving the appeal. Judge Eaton denied the government’s attempt to substitute lower-ranking officials for CBP Commissioner Rodney S. Scott, ordering Scott to testify despite the government’s “apex doctrine” arguments. The...