26-0603: Wednesday's "Export/Import Daily Bugle"

1. No relevant new items.

(Source: Federal Register)

2. Future Federal Registers (No items of interest.)

(Source: Future Federal Register, 3 Jun 2026)

Trade: Aluminum, Steel, and Copper Imports Into U.S.; Further Adjustment to Tariff Regimes (Proc. 11032). Scheduled Pub. Date: 4 Jun 2026. Permalink

3. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

4. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

5. DoD/DCSA Announcements (Nothing new.)

(Source: Defense Counterintelligence and Security Agency)

6. DoD/DSCA (Nothing new.)

(Source: Defense Security Cooperation Agency)

7. OMB/OIRA BIS and DDTC Reviews (Nothing new.)

(Source: OMB Office of Information and Regulatory Affairs)

8. State/DDTC (Nothing new.)

(Source: State/DDTC)

9. Treasury/OFAC (Nothing new.)

(Source: Treasury/OFAC) [Excerpts]

10. USTR Makes Findings and Proposes Action in 60 Section 301 Investigations Relating to Failures to Take Action on Trade in Forced Labor Goods

(Source: USTR Press Office, 2 Jun 2026)

The United States Trade Representative (USTR) has determined under Section 301 of the Trade Act of 1974 that the acts, policies, and practices of 60 economies related to the failure to impose and effectively enforce a prohibition on the importation of goods produced with forced labor is unreasonable and burdens or restricts U.S. commerce, and are thus actionable under Section 301(b) of the Trade Act.

USTR prepared a comprehensive report, Acts, Policies, and Practices of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor, that supports the findings in each investigation. . . .

Some trading partners have taken initial steps to prevent the importation of forced labor goods, including through USMCA and commitments in Agreements on Reciprocal Trade. However, each of our trading partners must do more to ensure that trade does not perversely encourage and entrench forced labor globally." As a result of these determinations in the investigations, the U.S. Trade Representative has proposed responsive action for public comment. USTR proposes additional duties on all products of the investigated economies, except as provided in Annex A to the Federal Register notice.

For economies that impose a forced labor import prohibition, that have committed to impose and enforce such a prohibition through an Agreement on Reciprocal Trade, or economies that have imposed a partial regime with the effect of preventing the importation of certain forced labor goods, the U.S. Trade Representative proposes 10% as the rate of additional duties.

For all other economies, the U.S. Trade Representative proposes 12.5% as the rate of additional duty. The U.S. Trade Representative also proposes a textile mechanism that would allow for a certain volume of apparel and textile imports from certain economies to enter the United States at a reduced Section 301 tariff rate. . . .

To be assured of consideration, interested persons should submit requests to appear at the hearings, along with a summary of testimony by June 22, 2026. Written comments are due by July 6, 2026. USTR will hold hearings about the proposed actions in these investigations on July 7, 2026. A copy of the Report is available here.

11. White House Executive Actions: "New Executive Order to Strengthen Customs Enforcement"

(Source: CBP.gov Newsroom, 3 Jun 2026)

Today, President Donald Trump signed Executive Order "Strengthening Customs Enforcement," empowering U.S. Customs and Border Protection with a comprehensive set of tools to safeguard American consumers, businesses, and revenue while increasing transparency and compliance across international supply chains. . . .

Among its key provisions, the Executive Order requires importers, whether domestic or foreign, to meet the same standards for transparency and accountability.

As directed by the Order, importers are required to provide more detailed information about their ownership, business operations, and supply chain, and must maintain good standing with CBP to continue importing. Customs brokers will also be held to higher standards and be required to conduct greater due diligence of their importers. . . .

12. BigGo Finance: "Seagate Settles Huawei Sanctions Violation Case, Agrees to $175 Million Shareholder Payout"

(Source: BigGo Finance (Tiawan), 2 Jun 2026) [Excerpts]

Hard drive giant Seagate Technology has reached a preliminary settlement with shareholders who filed a class-action lawsuit alleging the company concealed over $1.1 billion in hard drive sales to Huawei during a U.S. export ban.

Seagate agreed to pay $175 million (approximately NT$5.45 billion) to resolve the litigation, with $105 million in cash and the remainder covered by insurance. The company had previously been fined a record $300 million by the U.S. Commerce Department in 2023 for the same violations. . . .

13. ECD: "Rubio: Export Controls on Chipmaking Tools Should Continue"

(Source: Export Compliance Daily, 3 Jun 2026) [Excerpts of subscription site]

Secretary of State Marco Rubio said June 2 that he believes export controls on semiconductor manufacturing equipment (SME), especially high-end tools, remain critical to helping the U.S. maintain its technological edge over China.

He said Pax Silica, a new international initiative to strengthen supply chains and harmonize economic security tools, could play a role in aligning China-related export controls among the U.S. and its allies. . . .

Rubio's comments came in response to questioning from Sen. Pete Ricketts, R-Neb., who noted that he's introduced a bill aimed at harmonizing export controls on chipmaking tools. Ricketts said allied controls "have not been as restrictive as U.S. controls, and this has allowed certain foreign countries to backfill the Chinese market with critical dual-use tools."

Also during the hearing, Rubio said that sanctions the U.S. imposed on Iran for its nuclear weapons program could be eased if Tehran agrees to give up that program. He expects no sanctions relief to be provided just for re-opening the Strait of Hormuz, though the U.S. could end its naval blockade of Iranian ports in response. . . .

14. Expeditors News: "White House Announces New Section 232 Metals Modifications"

(Source: Expeditors News, 3 Jun 2026) [Excerpts]

In a proclamation published on June 1, 2026, the White House announce that was making modifications to certain products under Section 232 duties for aluminum, steel, and copper.

Agricultural equipment and heating, ventilation and air conditioning (HVAC) equipment will be added to Annex III and have its duty reduced to an all-in 15% Section 232 duty. Certain mobile industrial equipment and machinery will be eligible for tariff breaks if they qualify for USMCA treatment.

In addition, this proclamation adds certain steel racks and aluminum lithographic plates to the list of goods that will now be subject to 25% Section 232 tariffs. These changes will go into effect on June 8, 2026.

The "Further Adjusting the Tariff Regimes for Imports of Aluminum, Steel, and Copper into the Unites States" president proclamation and links to the updated annexes can be found HERE.

15. Shapiro: "Sweeping New Tariffs: 10-12.5% on 60 Countries"

(Source: Shap Alerts, 3 Jun 2026) [Excerpts]

The Office of the U.S. Trade Representative (USTR) has announced several significant Section 301 trade actions that may affect your supply chain. Here is a summary of the key developments.

On June 2, 2026, USTR announced a Section 301 determination that 60 countries are trading in goods made with forced labor. USTR has proposed additional duties on all products from the investigated economies at the following rates:

USTR has also proposed a textile mechanism that would allow a certain volume of apparel and textile imports from certain economies to enter the U.S. at a reduced Section 301 rate.

Key dates for this action: . . .

BRAZIL: PROPOSED 25% SECTION 301 TARIFFS:

Separately, USTR has proposed a 25% Section 301 tariff on certain imports from Brazil following an investigation into Brazil's trade practices, including concerns related to digital trade, electronic payments, preferential tariffs, anti-corruption enforcement, intellectual property, ethanol market access, and illegal deforestation.

The proposed tariffs would not apply to products already subject to Section 232 duties and would exclude certain raw materials and goods for which adequate domestic or alternative supply is unavailable.

VIETNAM: NEW SECTION 301 INVESTIGATION INITIATED: On May 29, 2026, USTR initiated a Section 301 investigation into Vietnam's intellectual property protection and enforcement practices, following Vietnam's designation as a "Priority Foreign Country" in the 2026 Special 301 Report. . . .

WHAT IMPORTERS SHOULD DO: Importers sourcing from any of the 60 investigated countries should assess their exposure to the proposed 10–12.5% duties and consider participating in the comment process before July 6. Importers with Brazil exposure should review their product classifications against the proposed 25% tariff and consider submitting comments by July 1. Importers sourcing from Vietnam should monitor developments closely as the investigation progresses. . . .

16. Sheppard Mullin: "From CAPE to Cope? - CBP Reverses Position on Universal IEEPA Duty Refunds"

(Source: Global Trade Law Blog, 1 Jun 2026) [Excerpts]

Significant new developments in federal court last week may materially affect importers' ability to obtain refunds of tariffs paid under the International Emergency Economic Powers Act ("IEEPA").

On May 29, 2026, U.S. Customs and Border Protection ("CBP") filed a motion with significant implications for all importers seeking IEEPA refunds. Most notably, for the first time since the Supreme Court struck down the IEEPA tariffs, CBP asserted that it lacks the legal authority to issue IEEPA refunds on finally liquidated entries (i.e., on entries 180 days or more past liquidation) without an importer-specific court judgment.

For importers who had been counting on the refund process to eventually cover their finally liquidated entries, CBP's new position is a significant setback: if CBP's reasoning prevails, those importers may need to file individual cases in federal court to obtain refunds. Here is what importers need to know: . . . [Full article]

17. ST&R Trade Report: "New Section 301 Tariffs Proposed Over Forced Labor Policies"

(Source: Sandler, Travis & Rosenberg Trade Report, 3 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

The Office of the U.S. Trade Representative is proposing to impose additional tariffs of 10-12.5 percent on imports from 60 economies following Section 301 investigations into the measures they have taken to prohibit imports of goods produced with forced labor.

Findings: USTR's report finds that the following 54 economies have failed to impose and effectively enforce such a prohibition: . . . The report also states that the following six economies have failed to effectively enforce such a prohibition: . . .

Proposed Tariffs: In response, USTR is proposing to impose a Section 301 tariff of 10 percent on imports from subject economies that:

The tariff rate for imports from all other subject economies would be 12.5 percent. . . . [Full article]

18. ECD: Census Offers AES Tips for Vessel Shipping Weight Errors"

(Source: Export Compliance Daily, 3 Jun 2026) [Excerpts of subscription site]

The Census Bureau emailed tips this week on how to address the most frequent error message generated this month in the Automated Export System.

Response code 821 is an error for when the mode of transportation is "vessel," but the reported shipping weight is too high for a vessel shipment. Census said that occurs when the gross shipping weight in kilograms has exceeded the amount that can be reported "based on historical statistical data and industry input."

The error code might "indicate either a keying error or an invalid mode of transportation," Census said. Filers should verify the shipping weight and mode of transport, correct the shipment and resubmit, if necessary. If the information is verified correct as reported, no action is necessary.

19. Husch Blackwell: "President Trump Reduces Section 232 Tariffs on Certain Agricultural, Mobile Industrial, and HVAC Equipment"

(Source: HB International Trade Insights, 2 Jun 2026) [Excerpts]

On June 1, 2026, President Trump issued a proclamation reducing tariff rates on certain agricultural equipment, mobile industrial equipment and machinery, and heating, ventilation and air conditioning ("HVAC") equipment under Section 232 of the Trade Expansion Act of 1962 ("Section 232").

In the same proclamation, President Trump also added aluminum lithographic plates and steel racks to the list of aluminum and steel derivative products subject to Section 232 tariffs. Both actions take effect at 12:01 a.m. Eastern Standard Time on June 8, 2026.

Agricultural and HVAC Equipment. Per the proclamation, tariffs on agricultural and HVAC equipment listed in Harmonized Tariff Schedule of the United States ("HTSUS") subheadings now added to Annex III will be reduced from 25% to 15% through December 31, 2027.

Mobile Industrial Equipment and Machinery. The proclamation also reduced tariffs on certain mobile industrial equipment and machinery that qualify for United States-Mexico-Canada Agreement ("USMCA") treatment or that are imported from countries the U.S. has reached trade deals with. . . .

For USMCA-qualifying products, a 25% tariff will apply only to the non-U.S. content of the product. However, the total tariffs applicable under Section 232 cannot be below 15%. The proclamation also indicates CBP will issue further guidance regarding how to assess "U.S. content" for purposes of this provision.

For mobile industrial equipment and machinery identified in Annex I-C and imported from Argentina, Ecuador, El Salvador, Guatemala, Japan, the Republic of Korea, Liechtenstein, Switzerland, Taiwan, the United Kingdom, or European Union, the maximum applicable tariff will not exceed 15%, inclusive of Section 232 and most-favored nation ("MFN") tariffs.

If none of the above reductions apply, . . . .

Aluminum Lithographic Plates and Steel Racks. Finally, the proclamation added aluminum lithographic plates and steel racks to the list of aluminum and steel derivative products subject to 25% Section 232 tariffs. The HTS subheadings for affected articles are identified in Annex I-B.

20. Sheppard Mullin: "New DFARS Proposed Rule: What Defense Contractors Need to Know About Foreign Ownership, Control, or Influence (FOCI) Reporting Requirements"

(Source: Global Trade Law Blog, 2 Jun 2026) [Excerpts]

On May 7, 2026, the Department of Defense ("DoD") issued a new proposed rule—Defense Federal Acquisition Regulation Supplement: Mitigating Risks Related to Foreign Ownership, Control, or Influence ("DFARS Case 2021-D011")—seeking to amend the DFARS to mitigate risks related to beneficial ownership or foreign ownership, control, or influence ("FOCI") (the "Proposed Rule").

For defense contractors and subcontractors, the Proposed Rule further implements disclosure obligations, eligibility requirements, and contract performance responsibilities relating to all manner of foreign investment.

New Requirements: The Proposed Rule introduces a series of structural changes to the DFARS regulatory framework that will directly affect "covered" contractors and subcontractors. "Covered" contractors and subcontractors are "existing or prospective contractors or subcontractors, at any tier, of the DoD with a contract or subcontract valued above $5 million."

By introducing this rule, DoD aims to amend the DFARS by creating Part 240, Information Security and Supply Chain Security, within which DoD proposes to create section 240.27X, Mitigation of Risks Related to Beneficial Ownership or Foreign Ownership, Control, or Influence. . . .

Key Takeaways for Defense Contractors: Entities that hold or intend to pursue DoD contracts valued above $5 million should begin assessing NISS eligibility status, reviewing beneficial ownership and FOCI disclosure posture, and evaluating their supply chain for subcontractor compliance obligations. . . . [Full article]

21. Volkov: "FTI Consulting's $1.05 Million OFAC Settlement: You Cannot Do Indirectly What You Cannot Do Directly"

(Source: Volkov Law, 2 Jun 2026) [Excerpts]

The Office of Foreign Assets Control delivered a pointed lesson in sanctions compliance this week with the announcement of a $1,050,000 settlement with FTI Consulting, Inc., one of the world's most prominent business advisory firms.

The enforcement action involves what might appear at first glance to be a technical violation — unpaid invoices routed through a law firm intermediary. But the compliance lessons embedded in this settlement are anything but technical, and every professional services firm, consulting organization, and law firm operating in international markets should read it carefully.

What Happened: The facts are straightforward and, frankly, cautionary in their familiarity. In late 2018, a global law firm engaged FTI to provide expert economic consulting services in support of litigation in Singapore on behalf of the law firm's client — VTB Bank, a Russian state-owned financial institution that had been placed on OFAC's Sectoral Sanctions Identification list since 2014. Under Directive 1 of Executive Order 13662, U.S. persons were prohibited from dealing in new debt of more than 14 days maturity issued to VTB.

FTI's compliance team recognized the risk from the outset. To navigate it, FTI structured the engagement so that its contractual relationship ran to the law firm — not directly to VTB. FTI would invoice the law firm; the law firm would collect from VTB; the law firm would then pay FTI. On paper, FTI had no direct relationship with VTB.

OFAC was unimpressed. Between April 2019 and May 2021, FTI issued six invoices with a total value of approximately $353,862. VTB was responsible for paying those invoices and was the ultimate beneficiary of FTI's services. When VTB failed to pay — sometimes leaving invoices outstanding for 90, 99, even 198 days — FTI continued working and continued issuing new invoices. FTI joined calls with VTB directly to discuss overdue payments.

The economic reality of the arrangement was transparent: FTI was extending credit to VTB. The law firm intermediary was a structural formality, not a meaningful insulator.

OFAC concluded that FTI had dealt in prohibited debt of VTB on six occasions in violation of the Ukraine/Russia-Related Sanctions Regulations, and assessed a settlement of $1,050,000 — double the base penalty of $525,000. . . . [Full article]

22. FD Associates Presents: "ITAR FMS Exemption" Webinar, 9 June

(Source: Jenny Hahn, [email protected])

23. Global Training Center Prepares you for the Certified ITAR Professional Certification Exam: "Building an ITAR Compliance Program" 4-Week Program Starts 3 August

(Source: Global Training Center)

24. List of Export/Import Job Openings

(Source: Editor)

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25. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

Jefferson Davis (Jefferson Finis Davis; 3 Jun 1808 – 6 Dec 1889; was an American politician who served as the president of the Confederate States from 1861 to 1865. As a member of the Democratic Party, he represented Mississippi in the United States Senate and the House of Representatives before the American Civil War.)

"Neither current events nor history show that the majority rule, or ever did rule."

Allen Ginsberg (Irwin Allen Ginsberg; 3 Jun 1926 – 5 Apr 1997; was an American poet and writer. As a student at Columbia University in the 1940s, he began friendships with William S. Burroughs and Jack Kerouac, forming the core of the Beat Generation. Ginsberg is best known for his poem "Howl" in which he denounced what he saw as the destructive forces of capitalism and conformity in the United States.)

"Whoever controls the media, the images, controls the culture."

Sydney Smith (3 Jun 1771 – 22 Feb 1845) was an English wit, writer, and Anglican cleric.)

"Find fault when you must find fault in private, and if possible, sometime after the offense, rather than at the time."

"Among the smaller duties of life I hardly know any one more important than that of not praising where praise is not due."

26. Today in History

(Source: History Channel)

27. Do You Need to Update Your Daily Bugle Profile?

(Source: Editor)

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28. Are your copies of regulations current? See latest amendments here:

(Source: Editor)

The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.) but are updated as amended in the Federal Register. The latest amendments are listed below.