Refunds in Limbo, Rules Tighten: 301 Tariff Moves, AD/CVD Shifts, and Compliance Alerts
NEWSLETTER | Trade Insight AI
DOJ Appeals CIT Refund Order; Importers Should File Protests, Consider Suits
STR Trade Report • June 5, 2026
The Justice Department appealed on June 2, challenging Judge Eaton’s order that CBP refund $166 billion in IEEPA tariffs and asserting CBP cannot refund finally liquidated entries without importer-specific court orders. With uncertainty over whether protests alone will secure refunds and the court scrutinizing refunds for millions of informal, finally liquidated entries (plus a June 4 class-cert motion), importers should keep filing timely protests, track CAPE eligibility, and consider filing CIT complaints under 28 U.S.C. 1581(i). A statute-of-limitations deadline is approaching in about eight months, increasing urgency to preserve refund rights.
Policy and Enforcement Overhauls at the Border
Executive Order Tightens Customs: Foreign IOR Limits, Higher Bonds, 50% Floor
STR Trade Report •June 5, 2026
President Trump’s June 3 executive order directs DHS/CBP to tighten customs enforcement via rulemaking, including higher bonds, minimum U.S. asset requirements and expanded beneficial‑ownership disclosures for importers of record, plus a new “good standing” registry with risk tiers within 180 days. Foreign IORs would be barred from informal entries and allowed formal entries only with sufficient bonding and CTPAT validation or a CTPAT‑validated broker, while CBP must within 90 days set a penalty‑mitigation floor of at least 50%, require foreign pre‑export documentation, and accelerate seizures—prioritizing forced labor, undervaluation, misclassification, and AD/CVD evasion. Though changes are not immediate and will go through notice‑and‑comment, importers should prepare for stricter vetting, recurring audits, higher bonding, and expanded data submissions this year.
Executive Order Tightens CBP Enforcement: Importer Transparency, Broker Checks, Bond Rules
CBP Media Releases •June 3, 2026
President Donald Trump signed an Executive Order strengthening customs enforcement, giving CBP expanded authorities to boost supply chain transparency, protect revenue, and penalize illicit trade. The order requires all importers—domestic and foreign—to provide more detailed ownership, operations, and supply-chain information and to maintain good standing with CBP to retain importing privileges; customs brokers must conduct greater due diligence on their clients. It also heightens restrictions on foreign importers and updates bond rules with higher minimums and risk-based sufficiency, raising compliance burdens and enforcement risk for noncompliant firms.
CBP, FMC, State Solicit Feedback on Key Cargo Data Collections
STR Trade Report •June 5, 2026
Federal agencies are inviting public comment on multiple trade-related information collections, including State’s DSP-85 for classified defense exports, the FMC’s containerized freight statistics, and a broad set of CBP cargo data requirements (ISF, ACAS, electronic export manifests, container status messages, vessel stow plans, and Forms 1302/1302A/7509/7533). Under the Paperwork Reduction Act, stakeholders can influence data elements, submission methods, and burden estimates—affecting compliance programs, carrier workflows, and manifest confidentiality practices. Trade teams should review the Federal Register notices and file timely comments to shape requirements and reduce operational risk.
Section 301 Watch: Forced Labor and Strategic Partners
USTR Seeks 10–12.5% Section 301 Tariffs on 60 Economies Over Forced Labor
USTR Press Releases •June 2, 2026
On June 2, USTR found 60 economies’ failure to impose and effectively enforce forced‑labor import bans to be actionable under Section 301 and proposed additional duties on all products from those markets, with limited exceptions per a Federal Register annex. The plan sets a 10% rate for economies with some prohibitions or commitments and 12.5% for others, plus a textile mechanism allowing limited apparel/textile volumes at reduced rates. Requests to appear are due June 22, written comments July 6, and a hearing is set for July 7; if adopted, the tariffs would materially raise landed costs and disrupt sourcing across major suppliers and allies.
USTR Seeks Input on U.S.-China Trade Board, Non-Sensitive Tariff Changes
USTR Press Releases •June 2, 2026
USTR opened a public comment period on a proposed U.S.-China Board of Trade to provide an ongoing channel to manage bilateral trade and identify non-sensitive products for potential reciprocal tariff modifications aimed at more balanced, reciprocal trade. Stakeholders can weigh in on scope, operations, and product lists by July 10, with rebuttals due July 27—an opportunity to shape targeted tariff changes while the administration maintains tariffs for economic and national security objectives.
USTR Deems Brazil’s Policies Actionable; Proposed 301 Measures Open for Comment
USTR Press Releases •June 1, 2026
USTR determined that Brazil’s policies on digital trade and e‑payments, preferential tariffs, anti‑corruption, IP enforcement, ethanol market access, and illegal deforestation are unreasonable under Section 301 and has proposed responsive action while continuing engagement with Brazil. The process now advances toward potential tariffs or other remedies by the July 15, 2026 statutory deadline; requests to appear are due June 22, written comments July 1, and a hearing is set for July 6. Companies exposed to Brazilian digital services, payments, ethanol, or IP‑intensive trade should assess risk and consider participating in the comment process.
Tariff Classifications and AD/CVD Enforcement
U.S. AD/CVD Roundup: New Margins Set, Sunset Reviews Launched
STR Trade Report •June 5, 2026
Commerce finalized or amended AD margins for multiple products: 13.53% on Oman common alloy aluminum sheet, 4.58% on Japan diffusion‑annealed nickel‑plated flat‑rolled steel, and 4.99% on South Korea utility‑scale wind towers; preliminary margins of 1.07–2.01% were set for India off‑the‑road tires. The agencies also initiated sunset reviews on CTL steel plate, melamine, methionine, PVLT tires, potassium phosphate salts, and walk‑behind lawn mowers across suppliers in China, Russia, Ukraine, France, Japan, Spain, South Korea, Taiwan, Thailand, and Vietnam—proceedings that could continue or revoke existing orders. Importers should reassess AD/CVD exposure, update compliance planning, and consider participation in the sunset reviews.
U.S. AD/CVD Update: Orders Maintained; Engines, R‑32 Margins Elevated; Xanthan Zero
STR Trade Report •June 4, 2026
U.S. trade authorities continued AD/CVD orders on citric acid from China (effective May 26) and, in sunset reviews, found that revoking orders on large vertical shaft engines and R‑32 from China would likely see dumping recur at up to 468.33% (engines; with 18.96–20.38% subsidies) and 221.06% (R‑32). They also found dumping would likely continue on preserved mushrooms from Chile (up to 148.51%), China (198.63%), India (243.87%), and Indonesia (16.24%), while amended final results for xanthan gum from China set a zero dumping margin for the July 1, 2020–June 30, 2021 review period. Importers should expect continued cash-deposit exposure across these sectors, with potential relief limited to the reviewed xanthan gum exporter(s).
CBP Tightens 9817 Rules: Mobility Ramps Lose Duty‑Free Entry
STR Trade Report •June 5, 2026
In its May 27, 2026 Customs Bulletin, U.S. Customs and Border Protection said it will modify 19 ruling letters to find certain portable or semi‑permanent rubber/aluminum mobility ramps are not eligible for duty‑free treatment under HTSUS 9817.00.96 (Nairobi Protocol) because they are not “specially designed or adapted” for persons with disabilities. Effective for entries on or after July 26, 2026, CBP cited similarities to general‑use ramps and mainstream marketing; importers should anticipate duty exposure and reassess 9817 claims and supporting design/marketing evidence.
Market Access and Regional Developments
CAFTA-DR Short Supply Petition Seeks Duty-Free Flexibility on Dobby Fabric
STR Trade Report •June 4, 2026
The Committee for the Implementation of Textile Agreements (CITA) received a request to add a polyester/nylon dobby weave fabric used in high-end sports uniforms to CAFTA-DR’s short supply list. If approved, apparel made in CAFTA-DR with this fabric would qualify for duty-free entry regardless of fabric origin, easing yarn-forward constraints. Potential regional suppliers have until June 10 to submit offers, signaling near-term sourcing and tariff planning implications for apparel brands.
Mexico shifts back to low‑value exports; EU‑U.S. deal advances; digital ATA
STR Trade Report •June 4, 2026
U.S. tariffs are pushing Mexico toward lower‑value maquiladora exports, undercutting President Sheinbaum’s value‑add agenda and heightening stakes ahead of the 2026 USMCA review. In Europe, Parliament’s trade committee approved an EU–U.S. tariff package with a 31 Dec 2029 sunset, stronger safeguard and suspension tools, and defined conditions for reductions on steel and aluminum derivatives—signaling preferences could lapse without renewal. Meanwhile, the ICC’s digital ATA Carnet is live in 30 countries, with global rollout expected by end‑2027 and full digitization by 1 Jan 2028, prompting firms handling temporary imports/exports to begin digital readiness planning.
USTR Opens Door to Select China Tariff Reductions; Comments Due July 10
STR Trade Report •June 4, 2026
USTR is seeking public comments through July 10 to identify “non-sensitive” products for potential reciprocal tariff reductions with China, including possible modifications to additional duties imposed under Sections 301 and 232 where consistent with U.S. law and security interests. The agency requests data on which Chinese goods should be treated as non-sensitive, where tariff inversions burden U.S. manufacturers, expected impacts on U.S. workers and consumers, and which U.S. exports should receive China’s MFN rates. USTR also seeks feedback on a proposed U.S.–China Board of Trade to manage these flows—meeting cadence, scope updates, and data-sharing—creating a near-term opportunity for companies to shape any relief.
Compliance and Operations Alerts
CBP Seizes $99K at Dulles, Underscoring FinCEN 105 Compliance
CBP Media Releases •June 1, 2026
Over Memorial Day weekend, CBP officers at Washington Dulles seized $99,443 in undeclared currency from two outbound traveler groups bound for Brussels after finding cash concealed in clothing and bags; both parties were released without charges. The action reinforces that carrying over $10,000 is legal but must be reported via FinCEN 105 (available online), amid a pattern of recent Dulles seizures totaling $163,181 in April and $119,178 in January. Companies with international travelers should reinforce pre-departure cash reporting to prevent seizures, flight disruptions, and potential criminal exposure.
First U.S. interception: CBP quarantines rare leafhopper in Nogales shipment
CBP Media Releases •May 29, 2026
On May 8, CBP agriculture specialists at Nogales’ Mariposa Commercial Facility intercepted and quarantined Polyamia arachnion, a leafhopper found in a commercial shipment of leafy greens. The first-in-nation commercial interception—and only the second collection in 69 years, with specimens tied to central Mexico—raises phytosanitary concerns given leafhoppers’ role as crop pests and disease vectors, signaling potential for heightened inspections and delays for produce shipments.
CBP Cincinnati Seizes 337 Hatching Eggs Misdeclared as Winter Jackets
CBP Media Releases •June 2, 2026
On May 27, CBP agriculture specialists in Cincinnati intercepted a Germany-origin shipment bound for Alaska containing 337 hatching eggs misdeclared as winter jackets and lacking required documentation. Because USDA restricts hatching eggs from countries with highly pathogenic avian influenza, the eggs were turned over to APHIS. The case underscores strict declaration and permitting requirements for live avian products and the risk of civil or criminal penalties for misdeclared agricultural goods.
Pay.gov outage to halt fee-required CIT e-filings June 6
CIT News •June 3, 2026
The U.S. Court of International Trade will conduct Pay.gov maintenance on Saturday, June 6, 2026, from 6–10 pm ET. During this window, documents requiring Pay.gov payment cannot be filed via CM/ECF; plan fee-based submissions outside the outage to avoid deadline issues.
Global Trade Forums and Inclusion Initiatives
WTO Trade and Environment Week convenes 16 sessions for action
WTO Latest News •May 31, 2026
The WTO opened its seventh Trade and Environment Week (1–5 June, Geneva and online) with a CTE meeting chaired by Nepal’s Ambassador Ram Prasad Subedi, launching 16 public sessions on climate-related trade measures, biodiversity, plastics, and environmental goods and services. Director-General Ngozi Okonjo-Iweala urged participants to convert dialogue into practical action, highlighting the forum’s role in informing policy thinking and national initiatives. For trade professionals, the agenda offers early signals on members’ priorities that could shape future work on climate tools and EGS market access; all sessions are open to the public via live webcast.
WTO opens gender equality trade prize amid IP and FTA updates
WTO Latest News •May 31, 2026
The WTO’s Informal Working Group on Trade and Gender opened applications for the third International Prize for Gender Equality in Trade, recognizing gender-responsive trade policies, and reported coordination with the MSME group. The meeting spotlighted IP as a lever for women’s market access, with Pakistan and Ukraine detailing national measures, WIPO/ITC showcasing coaching tied to the WEIDE Fund, and experts mapping AfCFTA’s new IP and Women & Youth protocols and the implementation work ahead. Members also shared outcomes and initiatives: exports by women-led Brazilian firms to Chile more than doubled to over $397m by 2024 (from $187m in 2021), Chilean women-led exporters widened coverage from 428 to 542 tariff lines, Mongolia scaled certification and export-readiness support, and Canada advanced gender-responsive standards including work on HS classification and international standards for menstrual products.
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