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Tariffs. Customs. Trade Remedies

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Patrick de Lapérouse (US)

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US CBP Publishes Significant Updates to Importer of Record Rules

By and 3 Mins Read

On November 6, 2026, US Customs and Border Protection (CBP) issued an interim final rule strengthening the requirements for companies acting as importers of record (IORs), particularly foreign-owned companies and foreign IORs. The rule, which implements Executive Order 14411, “Strengthening Customs Enforcement,” will take effect January 5, 2027. Comments from stakeholders are also due January 5, 2027. Summary The interim final rule introduces significantly stricter criteria for entities to qualify as US IORs. Under the…

US Further Modifies Section 338 Tariffs on Canadian Goods as the Tariffs Face Their First Legal Challenge

By and 3 Mins Read

On October 23, 2026, President Trump issued a new proclamation — Further Modifying the Scope of Products of Canada Subject to the Additional Duties Imposed to Offset Canadian Discrimination Against the Commerce of the United States With Respect to Motor Vehicles — once again adjusting the list of Canadian-origin products subject to the 50% ad valorem duties imposed under Section 338 of the Tariff Act of 1930. The changes take effect for goods entered, or…

US President Signs Russia and Iran Sanctions Bill with New Tariff Powers

By , , and 11 Mins Read

President Trump signed the much-anticipated Russia (and Iran) sanctions bill into law on Friday, September 18, 2026. The final text of H.R. 5334 is available here. In Brief It has been a long journey since Senator Lindsey Graham introduced an earlier version of the bill in the Senate in April 2025. After Senator Graham passed away in July, a new Russia sanctions bill was introduced bearing his name, the Lindsey O. Graham Sanctioning Russia and…

United States Streamlines Drone Export Controls While Imposing New Section 232 Tariffs on Drone Imports

By , and 5 Mins Read

On August 13, 2026, the Trump Administration introduced a combination of trade measures intended to expand export opportunities for US unmanned aerial vehicle (UAV or drone) manufacturers while increasing incentives to source and produce drone technologies in the United States. The actions reflect a concerted approach to strengthen the US drone sector and address concerns about supply chain resilience and national security. Streamlined Export Controls The US Department of Commerce’s Bureau of Industry and Security…

United States Imposes Section 338 Duties on Canadian Goods

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The United States has imposed additional 50% duties on certain Canadian-origin imports pursuant to Section 338 of the Tariff Act of 1930, marking the first use of a rarely invoked authority in decades. The duties, which took effect on imported certain Canadian products entered or withdrawn from warehouse for consumption beginning at 12.01am Eastern Time on August 22, 2026 following a brief three-day suspension, target a broad range of Canadian products in response to alleged…

US: CBP Issues Implementation Guidance for Section 232 Tariffs on Patented Pharmaceuticals

By , and 3 Mins Read

On July 30, 2026, the US Customs and Border Protection (“CBP”) issued implementation guidance for Section 232 tariffs on imports of patented pharmaceutical products and pharmaceutical ingredients, providing importers with reporting and classification instructions ahead of the tariffs’ effective dates. The guidance implements Presidential Proclamation 11020, issued on April 2, 2026, which imposes additional duties on certain patented pharmaceuticals and related active pharmaceutical ingredients and key starting materials. Generic pharmaceuticals and their associated ingredients remain…

United States: New 10 to 12.5% Section 301 “Forced Labor” Tariffs on Over 60 Countries Take Effect July 24, 2026, as Section 122 Duties Expire

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On July 23, 2026, the Office of the U.S. Trade Representative (USTR) announced final and immediate new tariffs on imports from 60 economies (59 countries and the European Union), including nearly all of the United States’ largest trading partners. The duties are imposed under Section 301 of the Trade Act of 1974 and are tied to USTR’s assessment of measures these economies have taken to adopt and enforce prohibitions on the importation of goods made…

US Proposes Additional 50% Tariffs on Canadian Origin Goods, Effective August 19

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On Monday, July 20, President Trump signed three Proclamations invoking Section 338 of the Tariff Act of 1930 to impose 50% tariffs on certain Canadian origin goods (Section 338 Tariffs). These tariffs are scheduled to enter into force at 12:01 AM EST on August 19, 2026. The Proclamations cite various actions by Canada that allegedly discriminate against the commerce of the United States in three core areas related to the USMCA/CUSMA: automotive, dairy, and alcohol products.…

US: Trump Administration Appeals CIT’s IEEPA Tariff Refund Injunction

By , and 3 Mins Read

On June 2, 2026, the Trump administration appealed a US Court of International Trade (CIT) injunction directing US Customs and Border Protection (CBP) to reliquidate all entries by all importers without applying tariffs imposed under the International Emergency Economic Powers Act (IEEPA). The government appealed both the above-referenced universal IEEPA tariff refund order and a CIT order compelling CBP Commissioner Rodney Scott’s testimony. Background: In a February decision, the Supreme Court held in Learning Resources…

US: USTR Proposes Section 301 Tariffs on 60 Countries Over Forced Labor Import Practices

By , and 5 Mins Read

On June 2, 2026, the United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that 60 countries had failed to impose and effectively enforce prohibitions on the importation of goods produced with forced labor, and that the failure is unreasonable and burdens U.S. commerce. The report proposes ad valorem duties on all products of the investigated countries, with limited exceptions. The 60 countries investigated account for over 99% of…