26-0610: Wednesday's "Export/Import Daily Bugle"

1. DOD Designates Chinese Military Companies Subject to Procurement Restrictions

(Source: 91 FR 35189, 10 Jun 2026)

[Editor's note: DoD is prohibited from contracting directly with listed entities starting June 2026 and will be barred from procuring their products indirectly (through suppliers) starting in 2027.]

2. Executive Order: "Strengthening Customs Enforcement"

(Source: 91 FR 35125, 10 Jun 2026)

Section 1. Purpose. Customs enforcement is essential to the national security, foreign policy, and economy of the United States. Effective customs enforcement prevents the importation of unlawful and dangerous goods; ensures importers of record (IORs) are correctly identified and accountable for duties owed; and guarantees compliance with numerous Federal laws, including laws governing forced labor, rules of origin, origin marking, intellectual property, revenue collection, and product safety.

Customs reform is long overdue. Systemic inefficiencies, loopholes, insufficient enforcement mechanisms, and outdated processes have created opportunities for malign actors to evade Federal law. Examples of noncompliance include undervaluing imports, withholding critical information about IORs and the goods being imported, and avoiding payment of duties through various arrangements and schemes. These actions threaten national security, undermine foreign relations, disadvantage domestic businesses, and harm Americans.

The United States must strengthen its customs enforcement through comprehensive reform, including through agency action and legislation. Such reform should focus on protecting national security, promoting lawful trade, ensuring the timely collection of duties, modernizing systems and processes, bolstering compliance mechanisms, increasing transparency, and protecting Americans and the domestic economy.

Sec. 2. Importers of Record. (a) Within 180 days of the date of this order, the Secretary of Homeland Security (Secretary) shall, pursuant to 19 U.S.C. 66, 1484, 1498, 1623, 1624, and 4320, and any other applicable law, take steps to revise importer eligibility regulations, guidance, and policies consistent with the policy of this order. These revisions shall include: . . . [Full Executive Order.]

3. CBP Posts List of Revoked Customs Brokers' Licenses

(Source: 91 FR 35225, 10 Jun 2026)

4. Future Federal Registers

(Source: Future Federal Register)

5. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

6. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

7. DoD/DCSA Announcements (Nothing new.)

(Source: Defense Counterintelligence and Security Agency)

8. DoD/DSCA Policy Memos of Interest (Nothing new.)

(Source: Defense Security Cooperation Agency)

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

(Source: OMB Office of Information and Regulatory Affairs)

10. State/DDTC (Nothing new.)

(Source: State/DDTC)

11. Treasury/OFAC (Nothing new.)

(Source: Treasury/OFAC) [Excerpts]

12. UK Export Control Joint Unit (No relevant items)

(Source: UK ECJU) [Excerpts]

13. US Trade Representative (No new items.)

(Source: USTR Press Office)

14. White House Executive Actions (No relevant items.)

(Source: The White House)

15. Braumiller: "Trade Alert: CPSC eFiling Preparation: Guidance for Importers, Brokers, and Product Safety Teams"

(Source: Braumiller Advisories, 10 Jun 2026)

Effective July 8, 2026, the Consumer Product Safety Commission (CPSC) will require eFiling for most regulated consumer products. For regulated consumer products entered into a Foreign Trade Zone (FTZ), the eFiling requirements will take effect on January 8, 2027. CPSC's list of products likely subject to mandatory eFiling is available here.

Before the effective date, importers should meet with their trade and product safety teams to review the eFiling process, gather the requisite certificates, and consider joining the eFiling voluntary stage. Joining the voluntary stage gives importers, their brokers, and their product safety teams the opportunity to learn the eFiling system and make the appropriate adjustments before eFiling becomes mandatory. Errors during the voluntary stage will not cause shipping delays. Importers interested in self-registering for the voluntary stage can do so here.

Importers who have joined the voluntary stage should work with their brokers and product safety teams to ensure that all required information—including products' certificate data, certifier ID, product ID, and version ID—is properly entered in CPSC's registry. Teams may find it helpful to test this by taking a single product through the entry filing and certificate data components of the full eFiling process.

Importers should also test the product registry's certificate data storage functionalities during the voluntary stage. . . . [Full advisory]

16. ECD: "Report: US, Taiwan Continue Discussing Strengthening Chip Export Control Rules"

(Source: Export Compliance Daily, 10 Jun 2026) [Excerpts of subscription site.]

Taiwan is continuing to speak with the U.S. about strengthening export controls over sales of AI chips destined for China, Bloomberg reported June 9. The effort, part of ongoing trade talks with the U.S., could restrict sales of advanced chips to all customers in China, not just specific blacklisted companies, the report said. It would also allow Taiwan to criminally prosecute AI chip smuggling to China.

The report said Taipei hasn't yet decided "on how far it will go to adopt American policies," and the two sides are still negotiating before announcing a "potential deal."

The report came after a trade deal with the U.S. in February in which Taiwan agreed to bolster its chip-related export control enforcement against China and strengthen its export control cooperation with the U.S., including by increasing civil and criminal enforcement against export violators and smugglers. . . .

17. Expeditors News: "EU to Introduce New Steel Industry Safeguards"

(Source: Expeditors News, 9 Jun 2026) [Excerpts]

A new European Union (EU) Regulation will replace the current steel safeguard regime from July 1, 2026, introducing stricter measures on imports, which introduces some changes that will increase duty exposure and significantly reinforce compliance and traceability obligations for importers.

The system will include reduced tariff-free quotas and a 50% duty on out-of-quota imports for around 30 steel product categories. These measures will apply to all countries except European Economic Area (EEA) members.

The Regulation also introduces a "melt & pour" requirement requiring importers to declare the country where steel was originally produced. From October 1, 2026, additional rules will require supporting documentation to evidence melt & pour origin at import. Link to European Council press release can be found HERE. Link to the Proposal Regulation HERE.

18. ST&R Trade Report: "AD/CVD News: Aluminum Wire, Corrosion Inhibitors, Isocyanurates, Rail Couplers, Pipe"

(Source: Sandler, Travis & Rosenberg Trade Report, 10 Jun 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

The International Trade Administration and/or International Trade Commission have recently announced the following actions in antidumping and/or countervailing duty cases. For more information on AD/CVD issues, including how to mitigate liability, please contact STR.

Aluminum wire – rescission of administrative reviews of AD and CVD orders on aluminum wire and cable from China for the periods Dec. 1, 2023, through Nov. 30, 2024, and Jan. 1 through Dec. 31, 2023, respectively, and instruction to CBP to assess AD and CVD duties on entries of subject goods at the applicable cash deposit rates

Corrosion inhibitors – dumping margins of 61.51 to 86.96 percent in preliminary results of administrative review of AD order on corrosion inhibitors from China for the period March 1, 2024, through Feb. 28, 2025

Isocyanurates – dumping margin of zero in final results of administrative review of AD order on chlorinated isocyanurates from Spain for the period June 1, 2023, through May 31, 2024

Rail couplers – dumping margin of 6.5 percent in final results of administrative review of AD order on freight rail couplers and parts thereof from Mexico for the period May 3, 2023, through Oct. 31, 2024

Welded pipe – net subsidy rates of 3.37 percent in preliminary results of administrative review of CVD order on large-diameter welded pipe from Türkiye for the period Jan. 1 through Dec. 31, 2024.

19. Washington Tariff & Trade: "China Weighs Export Controls for Technologies It Now Leads"

(Source: Washington Tariff & Trade Newsletter, 8 Jun 2026) [Excerpts of paywall publication.]

China has moved to harden control over the outbound flow of capital, technology, data and personnel, issuing its first dedicated State Council regulation on outbound investment as Chinese policy researchers are urging Beijing to build a more systematic export-control regime for technologies in which China has acquired global advantages.

The new regulation, published June 1 and effective July 1, gives Beijing a unified administrative framework for supervising overseas investment by Chinese companies, organizations and individuals. . . .

The academic study and the new regulation suggest a broader shift in Chinese technology governance. Beijing is no longer treating export controls only as a defensive response to U.S.-led restrictions on semiconductors, AI, quantum and other advanced technologies. . . .

The Morgan Lewis Shanghai Office said the regulation provides "the clearest legal basis yet" for Chinese authorities to review and potentially prohibit cross-border transactions that could move critical technology, data or strategic assets beyond Chinese jurisdiction. The firm identified three categories now expressly regulated: offshore restructurings, technology transfers through licensing or personnel deployment, and disposals of existing overseas assets.

"Any asset with Chinese origins must now be assessed on whether it has been properly cleared," they note. . . .

20. Baker/McKenzie: "Spain's Export Controls Regime: Recent Developments and What Comes Next"

(Source: Global Sanctions and Export Controls Blog, 10 Jun 2026) [Excerpts]

Spain's Secretaría General de Comercio (General Secretariat for Trade) recently held an informational briefing outlining significant developments in the country's export control framework. The session addressed both recently implemented measures and upcoming regulatory changes that are expected to reshape the way companies engage with the Spanish licensing system:

This development signals a heightened enforcement posture at the EU level and underscores the importance for companies operating in Spain to maintain robust compliance frameworks covering both sanctions and export controls, particularly as the domestic penalty regime continues to evolve. [Full article]

21. Braumiller: Customs Fraud, Whistleblowers, and $1.8 Billion in Liability: Lessons for Importers

(Source: Braumiller Advisories, 10 Jun 2026)

Between July 2011 and June 2014, California-based Perfectus Aluminum Inc., Perfectus Aluminum Acquisitions LLC, and four affiliated warehousing companies imported more than 2.2 million aluminum extrusions from China.

These products were subject to significant antidumping and countervailing duties, including rates as high as 374.15%.

To avoid these duties, the companies spot-welded the extrusions together into structures resembling pallets and declared them as "pallets" rather than extrusions. Because pallets are treated as finished merchandise rather than subject goods, this misclassification enabled the companies to evade more than $3 billion in duties owed to U.S. Customs and Border Protection (CBP).

During this period, the companies had no customers or sales for these so-called "pallets," reinforcing the government's position that the classification served no legitimate commercial purpose. A criminal investigation followed, and 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 customhouse.

Reporting these items as pallets on Customs Form 7501 Entry Summaries was determined to be fraudulent. As a result, the defendants were ordered to pay more than $1.8 billion in restitution to CBP and to forfeit nearly 280,000 aluminum structures to the government.

Subsequently, three civil suits were filed and combined into a single civil settlement agreement on May 12, 2025. The defendants agreed to pay an additional $549.5 million to the United States, representing recoveries from the sale of warehouses and remaining inventory. These civil actions originated from whistleblower (qui tam) lawsuits brought under the False Claims Act, which allows private parties to share in government recoveries. In this case, relators—including the Aluminum Extruders Council—will receive 17.5% of the settlement proceeds.

The settlement did not resolve all potential liability. The government expressly reserved criminal liability, administrative enforcement rights, individual liability, and liability for conduct outside the covered period.

The outcome of this case highlights significant compliance risks for importers, particularly in the areas of classification, documentation, and internal controls. . . . [Full advisory]

22. Sidley Austin: "As the World Turns"

(Source: Author, 10 Jun 2026) [Excerpts]

The drama surrounding the IEEPA tariff refund process continues to unfold. Earlier today, Senior Judge Eaton held a hearing to discuss the government's progress in refunding IEEPA tariffs, whether he should lift the stay requiring the government to comply with his original order and the government's appeal.

To recap, Judge Eaton wants the government to refund all IEEPA tariffs to all importers – regardless of whether the importer has filed a lawsuit at the Court of International Trade or not. Based on statute, the government is willing to refund IEEPA tariffs paid on certain entries -- unliquidated entries and entries liquidated up to 90 days -- to anyone who asks (to comply with the liquidation + 90 day statutory requirement, CBP only accepts refund claims on entries liquidated up to 80 days to give itself 10 days to process).

This is CAPE Phase 1. The government is not willing to refund IEEPA tariffs paid on entries liquidated more than 90 days to anyone who has not filed a lawsuit. This is what the government's appeal is about -- whether a single CIT judge can order the government to refund IEEPA tariffs paid on entries liquidated more than 90 days to importers who have not filed lawsuits. So, if you have filed a lawsuit, you are not affected by the government's appeal; if you have not, you are impacted by the appeal (and should consider filing your own lawsuit to remedy that).

Based on today's hearing, you should be getting what you can from CAPE. CAPE Phase I has been opened since April 20, 2026, and refunds are being processed (480 million entries accounting for ~$40 billion in refunds by the end of the month, according to CBP). If you have not filed for refunds of CAPE Phase 1-eligible entries, you should do so. . . . [Full Advisory]

23. Troutman: "New Sheriff at the Port: President Trump's Executive Order Rewrites the Rules on Customs Enforcement"

(Source: Troutman Pepper Locke advisories, 5 Jun 2026) [Excerpts]

Key Points:

24. Volkov: "What Compliance Functions Should You Automate First?"

(Source: Volkov Law, 9 Jun 2026) [Excerpts]

If you want to give your compliance team superpowers, then give them the power of automation. If your compliance program is still operating primarily through spreadsheets, emails, and manual tracking, regulators already view your program as ineffective.

Modern compliance risks move too fast for manual systems.

You need to have sanction screening, third-party monitoring, transaction testing, hotline analytics, policy certifications, and training program metrics. The Justice Department evaluates whether compliance programs have access to data, testing capability, and real-time monitoring.

Manual systems create blind spots, delayed escalation, inconsistent oversight. And weak documentation.

Automation does not replace human judgment, it enhances it.

25. ACI Presents: ACI's "Trade Compliance Tech" July 22-23 in Wash DC

(Source: Shannon Kao, ACI)

26. List of Export/Import Job Openings

(Source: Editor)

RECENT:

28. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

Saul Bellow (born Solomon Bellows; 10 Jun 1915 – 5 Apr 2005; was a Canadian-American writer. For his literary work, Bellow was awarded the Pulitzer Prize, the Nobel Prize for Literature, and the National Medal of Arts. His best known works include The Adventures of Augie March, Henderson the Rain King, Herzog, Mr. Sammler's Planet, Seize the Day, Humboldt's Gift and Ravelstein. Bellow is widely regarded as one of the 20th century's greatest authors.)

"California is like an artificial limb the rest of the country doesn't really need. You can quote me on that."

"When we ask for advice, we are usually looking for an accomplice."

"If women are expected to do the same work as men, we must teach them the same things."

"All a writer has to do to get a woman is to say he's a writer. It's an aphrodisiac."

F. Lee Bailey (Francis Lee Bailey Jr., 10 Jun 1933 – 3 Jun 2021; was a prominent and controversial American criminal defense attorney known for his involvement in some of the most high-profile legal cases of the 20th century, including as part of the "Dream Team" in the 1995 acquittal of O.J. Simpson.)

"Can any of you seriously say the Bill of Rights could get through Congress today? It wouldn't even get out of committee."

29. Today in History

(Source: History Channel)

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31. 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.