26-0825: Tuesday's "Export/Import Daily Bugle"

TUESDAY, 25 AUGUST 2026

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FEDERAL REGISTER (Trade Items)

President Orders Expansion of U.S. Space Launch/Reentry Capacity and Update of Export Controls for Space Transportation Capabilities
Commerce/BIS Seeks Comments on Temporary Final Rule on Recoverable Critical Minerals and Materials
CBP Establishes Four Customs-Enforcement Areas
Future Federal Register

OTHER U.S. GOVERNMENT SOURCES

CBP Cargo Systems Messages
CBP's Office of Trade Regulation Free Webinars
CBP's Office of Trade's National Commodity Specialist Division Free Webinars
BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd.
Commerce/BIS Changes the Name and Function of the "Regulations and Procedures Technical Advisory Committee" (RPTAC) to "Deregulation and Simplification Technical Advisory Committee" (DASTAC)
DSCA Updates SAMM to Recognize Inventory and Related Property (I&RP) in the Security Assistance Accounts (SAA) Financial Statements
Justice: "Florida Firearms Parts Dealer Pleads Guilty to Exporting Weapons Components as Part of Russia-Based Scheme"
State/DDTC (Nothing new.)
Treasury/OFAC Removes Syria's Designation as a State Sponsor of Terrorism; Iran-related Designations; Updates Iran-related General Licenses

NEWS

Breaking Defense: "How a New Pentagon Memo 'Resets' Industry Requirements, Plus Highlights from TechNet"
Diaz: "CAPE Phase 3 Postponed, Canada 338 Tariffs Delayed"
Expeditors News: "CBP Issues Guidance for Section 338 Tariffs on Canada"
FedEx News: "Regulatory Alert: US imposes Section 338 tariffs upon certain products of Canada"
ST&R Trade Report: "Section 338 Tariff Takes Effect; U.S., Canada Both Pledge Escalation"
WTTL: "White House Plans to Help U.S. Ranchers by Importing Tariff-Free Beef"

OPINION

Clif Burns: "Well, This Will Bring Iran to Its Knees"
ST&R Trade Report: "Tariff, Import Information Collections Under Review"
Troutman: "FCC Modifies Covered List Entry for Foreign-Produced Power Inverters"
Volkov: "Is Trade Fraud the Next Major False Claims Act Risk?"

TRAINING EVENTS & CONFERENCES

Global Training Center Presents: "Advanced Chemical Classification Hybrid Course" 17,18,19 November

EX/IM MOVERS & SHAKERS

List of Export/Import Job Openings

EDITOR'S NOTES

Do You Have Access to the Latest and Greatest ITAR and FTR?
Bartlett's Unfamiliar Quotations
Today in History
Do You Need to Update Your Daily Bugle Profile?
Are Your Copies of Export/Import Regulations Current?

ITEMS FROM THE FEDERAL REGISTER

1. President Orders Expansion of U.S. Space Launch/Reentry Capacity and Update of Export Controls for Space Transportation Capabilities

(Source: 91 FR 54929, 25 Aug 2026)

AGENCY: Executive Office of the President
ACTION: Administrative Order: Memorandum for the Secretaries of State, War, Interior, Commerce, Transportation, Energy, and Homeland Security, [and 8 other Executive agencies].
SUMMARY: This order of Aug 20, 2026, directs agencies to expand U.S. launch/reentry capacity toward 1,000+ launches/year by 2030. Key provisions: DoW/NASA to modernize Federal ranges and streamline commercial access; 180-day infrastructure, spectrum, and security reviews; new Federal land reentry site; industrial-base strategy within 180 days.
Tade-relevance: within 120 days, State and Commerce must update export policies/programs and export controls for space transportation capabilities to promote U.S. industry abroad while protecting IP and enabling allied/partner sales. Also sets criteria for reviewing foreign launch/reentry requests. Revokes PPD-26 (2013).

2. Commerce/BIS Seeks Comments on Temporary Final Rule on Recoverable Critical Minerals and Materials

(Source: 91 FR 54846, 25 Aug 2026)

AGENCY: Commerce, Bureau of Industry and Security
ACTION: Notice of information collection, request for comment
SUMMARY: The Department of Commerce invites comments on proposed, and continuing information collections. This notice is to allow for 60 days of public comment on the OMB approved emergency collection for the Temporary Final Rule "DPAS Directive Allocation Order and Additional Requirements for Recoverable Critical Minerals and Materials" (August 6, 2026, 91 FR 50701)
DATE: Comment by 26 Oct 2026.

3. CBP Establishes Four Customs-Enforcement Areas

(Source: 91 FR 54800, 25 Aug 2026)

AGENCY: DHS, U.S. Customs and Border Protection
ACTION: Establishment of Customs-Enforcement Areas
SUMMARY: This document sets forth the Commissioner of U.S. Customs and Border Protection's (CBP) declaration establishing four Customs-Enforcement Areas (CEA) in the near shore waters of South Florida, Central/Southern California, Puerto Rico, and the Gulf Coast of Texas.
DATES: Established as of August 25, 2026.

4. Future Federal Register

(Source: Future Federal Register)

Foreign Assets Control Office; Rules; Iranian Transactions and Sanctions Regulations. Scheduled Pub. Date: 26 Aug 2026. Permalink
U.S. Customs and Border Protection; Rules; Automated Commercial Environment (ACE) Electronic Export Manifest for Rail Cargo. Scheduled Pub. Date: 26 Aug 2026). Permalink

OTHER U.S. GOVERNMENT SOURCES:

5. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

CSMS # 69648556 - ACE Certification Standard Invasive Maintenance Window on August 26, 2026 from 5:00 p.m. to 8:00 p.m. ET
CSMS # 69647661 - Update to AESTIR Appendix A -- Commodity Filing Response Message 802
CSMS # 69635410 - Update to ACE CATAIR Error Dictionary: New Error F883 PSC NOT ALLOWED TO MODIFY IEEPA HTS
CSMS # 69632351 - YOUR FEEDBACK IS REQEUSTED: 2026 ACE User Satisfaction Survey is Now Open!

6. CBP's Office of Trade Regulation Free Webinars in Aug-Sep 2026

(Source: OTR Webinars) (All times Eastern)

Mattresses and Cushions: Hybrids and More of Heading 9404 --- Wednesday, 25 August at 1:30 p.m.
Counter-Balance: Surfaces of Chapters 68 and 70 --- Thursday, 27 August at 1:30 p.m.
Wadding, Gauze, Bandages, and Similar Articles: --- Friday, 28 August at 1:30 p.m.
Combating Unfair Trade: Understanding AD/CVD Orders and Reporting Evasion to CBP --- Monday, 21 September at 2:00 p.m.

7. CBP's Office of Trade's National Commodity Specialist Division Free Webinars in Sep 2026

(Source: OTR Webinars) (All times Eastern)

These webinars are a part of CBP's Continuing Education program (all times Eastern):

22 Sep (Tuesday) at 11:00 a.m. Seats of Cane, Osier, Bamboo — This webinar will discuss the classification of seats of cane, osier, bamboo, and similar materials of Chapter 94, Heading 9401 of the Harmonized Tariff Schedule.
24 Sep (Thursday) at 11:00 a.m. Surfactants — Global Specialty Chemicals — This webinar will identify important chemicals of international commerce, known as surface-active agents and preparations.
25 Sep (Friday) at 11:00 a.m. Sound and Visual Signaling Devices of Heading 8531 — This webinar is an overview of heading 8531, and the merchandise that will be covered.
28 Sep (Monday) at 1:30 p.m. Happy Trailers to You: Trailers of 8716 — This webinar will be describing trailers and carts, as well as the history of carts and trailers.
29 Sep (Tuesday) at 1:30 p.m. Misc. Edible Preparations of Heading 2106: Part I — This webinar is the first part of a two-part series involving the tariff classification of misc. edible preparations of the basket provision of heading 2106.
30 Sep (Wednesday) at 1:30 p.m. Misc. Edible Preparations of Heading 2106: Part II — This webinar is the second part of a two-part series involving the tariff classification of misc. edible preparations of the basket provision of heading 2106.
Register: Click on the registration links above. After the live event, this and other previously recorded webinars will be available for replay at Trade Outreach Webinars | U.S. Customs and Border Protection (cbp.gov).
Questions: Email [email protected].

8. BIS Reaches Administrative Enforcement Settlement with Container Manufacturing Ltd.

(Source: Commerce/BIS, 24 Aug 2026)

Respondent: Container Manufacturing Ltd., 6450 Poe Avenue Ste 511, Dayton, Ohio 45414
Charges: Eight violations of Section 764.2(a), engaging in prohibited conduct, and two violations of Section 764.2(e). acting with knowledge of a violation.
Allegations: As described in the attached Schedule of Violations, between on or about March 23, 2023, through on or about March 7, 2025, Container Manufacturing violated the Regulations when it sold and exported items subject to the EAR and designated EAR99 with Harmonized Tariff Schedule ("HTS")-6 codes identified on the Russian and Belarusian Industry Sector Sanctions List (Supplement No. 4 to 15 C.F.R. Part 746) to an end user in Russia without the required license or other authorization from BIS. The items, classified under HTS codes 8466.94, 8462.29, and 4016.93, include various spare parts for aluminum metalworking tools that are valued at $264,721.
Penalties:
     FIRST, Container Manufacturing shall be assessed a civil penalty of $1,000,000, the payment of which shall be made to the U.S. Department of Commerce within 30 clays of the date of this Order.
     SECOND, pursuant to the Debt Collection Act of 1982, as amended (31 U.S.C. §§ 3701-3 720E (2012)), the civil penalty owed under this Order accrues interest as more fully described in the attached Notice, and if payment is not made by the due date specified herein, Container Manufacturing will be assessed, in addition to the full amount of the civil penalty and interest, a penalty charge and an administrative charge, as more fully described in the attached Notice.
     THIRD, the full and timely payment of the civil penalty in accordance with the payment schedule set forth above is hereby made a condition to the granting, restoration. or continuing validity or any export license. license exception, permission, or privilege granted, or to be granted, to Container Manufacturing. If Container Manufacturing fails to pay the civil penalty in a full and timely manner, the undersigned may issue an order denying all of Container Manufacturing's export privileges under the Regulations for a period of one year from the date of failure to make such payment.
     FOURTH, the Proposed Charging Letter. the Settlement Agreement, and this Order shall be made available to the public.
Date: 24 Aug 2026

9. Commerce/BIS Changes the Name and Function of the "Regulations and Procedures Technical Advisory Committee" (RPTAC) to "Deregulation and Simplification Technical Advisory Committee" (DASTAC)

(Source: Editor, 25 Aug 2026)

     The "Regulations and Procedures Technical Advisory Committee" (RPTAC) has been renewed and renamed as the "Deregulation and Simplification Technical Advisory Committee" (DASTAC).
     DASTAC's role will be to review the Export Administration Regulations (EAR) and advise on technical and policy issues affecting the Department and exporters.
     DASTAC will recommend updates to the Commerce Control List (CCL) to preserve U.S. technology leadership globally, identifying controls that no longer protect national security or foreign policy interests---due to wide availability, technological obsolescence, or other factors---and are therefore unnecessary. This includes eliminating duplicative or outdated controls.
     The Committee will also recommend regulatory changes to simplify procedures, reduce complexity, and improve export control compliance, and will advise on other matters supporting ECRA Section 1752 (50 U.S.C. § 4811). DASTAC will be scheduled to meet quarterly at the request of the DFO or Chair.
     Members will be appointed by and serve at the pleasure of the Secretary of Commerce. Membership will be limited to 75 members.
     Commerce's Office of Technology Evaluation, under the BIS Deputy Assistant Secretary for Technology Security in Export Administration, BIS, will provide administrative support services.
     The DASTAC has appeared on BIS's official TAC roster for the first time. DASTAC now has its own page (currently a placeholder -- "Coming soon" content) alongside the existing TACs.
     No charter document, membership list, or Federal Register notice yet --- page reads "Coming soon" for both the committee description and members. Nothing regarding RPTAC's rename has appeared in the Federal Register.

10. DSCA Updates SAMM to Recognize Inventory and Related Property (I&RP) in the Security Assistance Accounts (SAA) Financial Statements

(Source: Defense Security Cooperation Agency, 25 Aug 2026)

DSCA posts Policy Memo 26-20 Recognition of Inventory and Related Property in the Security Assistance Accounts Financial Statements.

This memorandum updates policy in the Security Assistance Management Manual (SAMM) and establishes procedures for recognizing Inventory and Related Property (I&RP) in the Security Assistance Accounts (SAA) Financial Statements. This memo adds:

11. Justice: "Florida Firearms Parts Dealer Pleads Guilty to Exporting Weapons Components as Part of Russia-Based Scheme"

(Source: US Attorney EDNY, 25 Aug 2026)

     BROOKLYN, NY -- Earlier today, in federal court in Brooklyn, Maxim Larin pleaded guilty to conspiracy to violate the Export Control Reform Act and attempting to violate the Arms Export Control Act in connection with his shipment of weapons parts and accessories to Kazakhstan.
     Larin was arrested in Florida in August 2025. According to court documents, Larin is the owner of several U.S. based companies which deal in weapons parts and sensitive firearms accessories.
     Larin used his businesses to sell export-controlled weapons parts and accessories to his co-defendant based in Russia. The items Larin shipped to Kazakhstan were on the Commerce Control List ("CCL") and designated as export restricted because their reshipment could be detrimental to U.S. foreign policy or national security.

12. State/DDTC (Nothing new.)

(Source: State/DDTC)

13. Treasury/OFAC Removes Syria's Designation as a State Sponsor of Terrorism; Iran-related Designations; Updates Iran-related General Licenses

(Source: Treasury/OFAC, 24 Aug 2026)

The U.S. Department of State today removed Syria's designation as a State Sponsor of Terrorism. Accordingly, Syria is no longer subject to prohibitions under the Terrorism List Governments Sanctions Regulations, 31 CFR part 596 (TLGSR), or 22 USC 7205(a)(1).

The U.S. Department of State also revoked the designation of al-Nusrah Front, also known as Hay'at Tahrir al-Sham (HTS), as a Specially Designated Global Terrorist (SDGT) organization.

Concurrently, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) removed HTS from the Specially Designated Nationals and Blocked Persons List ("SDN List").

As a result, Syria General License (GL) 25, which authorized certain transactions that could otherwise have been prohibited due to the role of HTS in the Syrian government, is no longer necessary, and OFAC has revoked the general license.

OFAC also updated FAQ 1220, FAQ 1221, and FAQ 1222, and removed FAQ 1223. Also, the U.S. Departments of Commerce, State and Treasury have issued an updated Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria.

Additionally, OFAC has added numerous new Iran-related names to its SDN List, and implemented the following actions with regard to its Iran sanctions programs: [Full list of actions.]

NEWS

14. Breaking Defense: "How a New Pentagon Memo 'Resets' Industry Requirements, Plus Highlights from TechNet"

(Source: Breaking Defense News, 25 Aug 2026) [Excerpts]

In this week's episode of The Break Out, a new Defense Department memo reorients data disclosure guidance for Pentagon contractors, but it also raises several key unanswered questions, as congressional reporter Valerie Insinna tells Deputy Editor Lee Ferran.
Then networks reporter Mark Pomerleau unpacks what he learned from top Army officials during the recent TechNet Augusta conference in northern Georgia, including a few artificial intelligence initiatives in the works. [Full article]

15. Diaz: "CAPE Phase 3 Postponed, Canada 338 Tariffs Delayed"

(Source: Customs & International Trade Law Blog, 25 Aug 2026) [Excerpts]

* Author: Jennifer Diaz, Esq., Diaz Trade Law LLP

Here is a recap of the latest customs and international trade law news:

Customs and Border Protection (CBP)

CBP published a federal register notice on August 19, 2026 announcing that, beginning September 18, 2026, it will immediately void importer of record numbers when the information on CBP Form 5106 is inaccurate or incomplete.
CBP has delayed the launch of the Consolidated Administration and Processing of Entries (CAPE) refund tool Phase 3. It was originally set for Aug. 20 and is now delayed until further notice. ITT reporting.
CBP issued a CSMS message stating that HTSUS subheadings associated with Section 301 duties on certain products from Brazil and those associated with Section 301 duties on forced labor are drawback eligible.
CBP issued a CSMS message advising customs brokers to use the ACH Rejected Refunds Report in ACE to help importers identify refunds that have been rejected due to missing out on ACH enrollment.

Administration

President Trump issued a proclamation delaying the imposition of 50% Section 338 tariffs on some products from Canada until 12:01 a.m. on Aug. 22, while the U.S. and Canada finalize a deal.

U.S. Department of Justice (DOJ)

The DOJ published a notice establishing how the department will divide trade fraud.

U.S. Department of Commerce

The Commerce Department published a Federal Register notice with revised procedures that change when importers must submit documentation to reduce Section 232 tariffs on USMCA qualifying automobiles.

U.S. Trade Representative (USTR)

South Korean Industry Minister Kim Jung kwan met with U.S. Trade Representative Jamieson Greer and raised concerns over ongoing Section 301 investigations.

Office of Foreign Asset Control (OFAC)

OFAC issued a new Cuba-related Frequently Asked Question, FAQ 1264: "I am a non-U.S. person engaged in humanitarian activities specifically looking to send food, medicine, or medical devices to Cuba. What is my exposure to sanctions under Executive Order (E.O.) 14404?"

U.S. Department of State

The Department of State designated nine entities and three individuals to further the Trump Administration's comprehensive push to end the Cuban regime's malign activities. . . .

Congress

Senator Moreno of Ohio sent a letter to DHS Secretary Markwayne Mullin, noting a $112 billion trade data gap between what China reported exporting to the U.S. and what CBP recorded. The letter asked whether the department needs additional authority to catch violators.

Industry News

The Descartes Forwarder & Broker Industry is seeking survey responses for it's 10th Benchmark Study examining a longitudinal view of how freight forwarders and customs brokers have adapted through disruption, normalization, margin pressure and growing regulatory complexity.

16. Expeditors News: "CBP Issues Guidance for Section 338 Tariffs on Canada"

(Source: Expeditors News) [Excerpts]

     On August 21, 2026, U.S. Customs and Border Protection (CBP) issued a bulletin via its Cargo Systems Messaging Service (CSMS) providing guidance on the implementation of Section 338 tariffs on certain products of Canada.
     The CSMS bulletin provides guidance on the applicable Harmonized Tariff Schedule (HTS) codes used to report the additional tariffs, as well as the applicability of the tariffs to goods admitted into a Foreign Trade Zone (FTZ). The CSMS bulletin also indicates that drawback is eligible for goods subject to the additional tariffs.
     The tariffs became effective on August 22, 2026 at 12:01 am Eastern Time, and are applicable to imports from Canada of subject commodities entered for consumption, or withdrawn from warehouse for consumption, on or after that date and time.
     The CSMS bulletin can be found HERE. The original announcement of the Canadian Section 338 Tariffs was covered by Expeditors HERE.

17. FedEx News: "Regulatory Alert: US imposes Section 338 tariffs upon certain products of Canada"

(Source: FedEx Regulatory News, 25 Aug 2026) [Excerpts of client advisory.]

     The United States imposed additional 50% tariffs on certain products of Canada effective August 22, 2026. This tariff action was implemented under Section 338 of the Tariff Act of 1930 as directed by multiple Presidential Proclamations. Affected products are specified by Harmonized Tariff Schedule of the United States (HTSUS) numbers listed in the proclamations' annexes. . . .
     What has changed? The additional tariffs became effective for impacted goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on August 22, 2026. Examples of products affected include specified alcoholic beverages, dairy products, jewelry, machinery, furniture, and sporting goods. . . .
     Goods that qualify for an exemption should have any applicable Chapter 99 HTSUS subheading(s) noted on the commercial invoice along with all supporting documentation to substantiate the claim.
     Q&A Q 1: Does this action mean that all products of Canada now have a 50% duty rate? A 1: . . .
     Q 2: If my products qualify for special tariff treatment under the United States-Mexico Canada Agreement (USMCA), do these additional tariffs still apply? A 2: . . .
     Q 3: Is duty drawback available for duties paid related to the Section 338 duties? A 3: . . .
     Q 4: Are there impacts to products being imported to a Foreign Trade Zone (FTZ)? A 4: . . .
     [Full article]

18. ST&R Trade Report: "Section 338 Tariff Takes Effect; U.S., Canada Both Pledge Escalation"

(Source: Sandler, Travis & Rosenberg Trade Report, 25 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The U.S. has imposed its first-ever Section 338 tariff, on imports from Canada, after weeks of negotiations failed to yield an agreement to avoid it. Both sides have pledged actions that would further escalate a burgeoning trade war.
     Tariff Details: The new 50 percent tariff took effect for covered goods entered or withdrawn from warehouse for consumption on or after 12:01 a.m. EDT on Aug. 22, with no apparent termination date.
     Affected products represent about five percent of Canadian exports to the U.S. (valued at approximately $20 billion) and are set forth in the annexes of the three original proclamations (available here, here, and here). They include: . . .
     Further Actions: . . . Talks broke down late Aug. 21, and both sides blamed the other. U.S. Trade Representative Jamieson Greer accused Ottawa of "new demands and walkbacks of other commitments" that "upended the careful balance reached in the past days." Canadian Prime Minister Mark Carney rejected that accusation and attributed the collapse to "last-minute changes in the U.S. proposed terms" that were "unfair, uneconomic, and called into question the reliability of any deal."
     Carney said his government plans to levy "dollar for dollar" retaliatory tariffs against imports from the U.S., with an anticipated start date of Sept. 8. Carney said affected products will include steel, dairy, appliances, agricultural equipment, pulp and paper, and electronics and that more details will be announced soon.
     President Trump reportedly responded that he will double tariffs on imports of Canadian cars, trucks, and auto parts to 50 percent beginning Jan. 1, 2027.

19. WTTL: "White House Plans to Help U.S. Ranchers by Importing Tariff-Free Beef"

(Source: Washington Tariff & Trade Letter, 21 Aug 2026) [Excerpts of subscription publication]

     President Trump announced a temporary tariff concession for imported beef, presenting it as a way to increase near-term ground-beef supplies while American ranchers rebuild the domestic cattle herd.
     Under the plan, the United States will allow as much as 300,000 metric tons of products intended for ground beef to enter during the next 90 days without an out-of-quota tariff. Trump also said there was a commitment to sell the imported beef at 25% below current market prices. . . .
     Trump's argument reflects the time required to expand cattle supplies. Ranchers must retain cows and replacement heifers for breeding rather than slaughter, which can restrict beef production before the additional animals begin contributing to the herd. . . . [Full article]

OPINION

20. Clif Burns: "Well, This Will Bring Iran to Its Knees"

(Source: Export Law Blog, 24 Aug 2026) [Excerpts]

* Author: Clif Burns, Clark Hill PLLC

     As part of the announcement of today's "Economic D-Day Against Iran," the Office of Foreign Asset Controls ("OFAC") announced a revocation of certain general licenses under the Iran sanctions. Most of them have to do with exceptions relating to educational and professional conference activity. Personal remittances are also no longer subject to a general license.
     But this one hits home for me and shows that we really mean business about crushing Iran's economy. A long time ago (and before we were, er, strongly encouraged to go dark), I posted about Adel Borghei, an Iranian tennis referee who showed up at the U.S. Tennis Open and was politely told that the sanctions on Iran prevented him from performing his anticipated role as a line referee at the match. The nice folks at my then firm, Bryan Cave, agreed we should help Mr. Borghei out in his predicament. . . .
     Shortly after granting the license for Mr. Borghei, OFAC adopted the now-revoked General License F ("[a]uthorizing certain services in support of professional and amateur sports activities and exchanges").
     Leaving aside whether the full panoply of economic sanctions, including the secondary sanctions teased but undisclosed by Secretary Bessent, will accomplish their intended purpose, it seems safe to say that telling Iranian athletes that they can't come to the United States to play in their sports will have little effect one way or another.
     After we exiled Iran's World Cup team to Tijuana (of all places), it is doubtful that Iran footballers are chomping at the bit to come to the United States. Is OFAC thinking about secondary sanctions on countries that allow Iranian athletes to participate in professional sports in those countries? Even if so, that seems unlikely in and of itself to have any impact on the Iranian government and the current conflict.
     We should remember that for years we tried to tailor sanctions to minimize harm to the innocent populations of rogue states. There was, of course, a good reason for that.
     In other news, several other colleagues and I have accepted positions at Clark Hill.

21. ST&R Trade Report: "Tariff, Import Information Collections Under Review"

(Source: Sandler, Travis & Rosenberg Trade Report, 25 Aug 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

The federal agencies listed below are accepting comments on new, revised, or extended information collections concerning the following:

Department of Commerce: Procedures for submissions by steel and aluminum producers committing to new U.S. steel or aluminum production to obtain tariff adjustments (extension)
Food and Drug Administration: Import and electronic import entries, including the weekly entry filing program for foreign-trade zones; the Import Trade Auxiliary Communication System; form FDA 766, application for authorization to relabel or recondition noncompliant articles; and form FDA 5054, new inquiry form -- import compliance branch (extension)

22. Troutman: "FCC Modifies Covered List Entry for Foreign-Produced Power Inverters"

(Source: Troutman Pepper Locke, 25 Aug 2026) [Excerpts]

* Author: Ryan Last, Troutman Pepper Locke LLP

Key Points:

The FCC's PSHSB updated the Covered List on August 20, 2026, based on a second National Security Determination from DoD/W narrowing the definition of covered "power inverters" to utility-interactive inverters as defined in UL 1741 that contain or can accept remote connectivity components.
The revised definition confirms that the connectivity prong is satisfied if an inverter is "designed, equipped, or configured to accept" a communications component --- even if that component is not installed at the time of manufacture.
Foreign-produced power inverters eligible for the Advanced Manufacturing Tax Credit under 26 U.S.C. § 45X are no longer considered "foreign-produced" for Covered List purposes and are exempt from the listing.
Inverters have three potential routes off the Covered List: eligibility for the section 45X domestic production credit, qualification as a Buy American Act domestic end product under 48 C.F.R. § 25.101(a), or Conditional Approval from DOD/W or DHS.
The July 28 permissive changes waiver under 47 C.F.R. §§ 2.932(b) and 2.1043(b), permitting software and firmware updates to previously authorized covered devices, continues to apply under the revised power inverter definitions. [Full article]

23. Volkov: "Is Trade Fraud the Next Major False Claims Act Risk?"

(Source: Volkov Law, 25 Aug 2026) [Excerpts]

* Principal Author: Michael Volkov, Volkov Law Group LLC

     If you think your company can smuggle and fly under the radar screen, think again. When your company touches imports, customs, or tariffs, you need to know this.
     The Justice Department stood up a dedicated trade fraud task force in August of last year. Its first settlement came three months later. This past May, it delivered the largest customs-related False Claims Act recovery ever: $550 million from aluminum companies and their warehouses. A week later, two steel companies paid $19 million for misrepresenting Chinese, Indonesian, Italian, Turkish, and Vietnamese steel as Canadian or American-made.
     Underpaying customs duties you legitimately owe is a reverse false claim, meaning it's a False Claims Act case with triple damages and whistleblowers ready to report you.
     As tariffs climb, so does the incentive to misdeclare country of origin, and DOJ now has a dedicated task force and a whistleblower bar ready and good at spotting those situations.
     If trade compliance isn't in your risk assessment right now, fix that immediately. [Hear podcast]

TRAINING EVENTS & CONFERENCES

24. Global Training Center Presents: "Advanced Chemical Classification Hybrid Course" 17,18,19 November

(Source: Global Training Center)

What: Advanced Chemical Classification Hybrid - 3-day Mini Course
When: Tuesday, Wednesday, Thursday 17, 18, 19 November 2026. 12pm - 1pm CT each day
Where: Hybrid: Recorded and Live Sessions over 3 days.
Summary: This course is a 3-day program designed for professionals handling chemical product classification under the Harmonized Tariff Schedule. Designed for those with prior classification experience; foundational material will not be covered. 4.5 Credits Available
Presenter: Bonnie Kersch
Register: HERE. More information: email [email protected].

EX/IM MOVERS & SHAKERS

25. List of Export/Import Job Openings

(Source: Editor)

Submit job openings HERE.

(To view job description, click Job ID or Title.)

RECENT:

Northrop Grumman. Job location: 9 locations Title: Principal International Trade Compliance Analyst. Job ID: R10240096
Northrop Grumman. Job locations: Linthicum, MD and 5 other locations. Title: Manager 3 - Global Trade. Job ID: R10238060
Rieter AG. Job location: Winterthur, Switzerland. Title: Head of Trade Compliance. Contact: Jasmin Bauer
SpaceX, Job location: Palo Alto, CA. Title: Counsel, Global Trade Compliance

FULL LIST:

Alcon Research. Job location: Fort Worth, TX. Title: International Trade Counsel Global Trade Compliance. Job ID: R-2026-46235
Amazon LEO. Job location: Bellvue, WA. Title: Sr. Export Compliance Manager. Job ID: 10469204
Amazon Services. Job location: Arlington, VA. Title: Senior Export Compliance Manager, Global Trade Services.
Analog Devices. Job locations: Germany, Munich, Otl-Aicher-Strasse. Title: Sr. Trade Compliance and Audit Officer. Job ID: LI-RW1
Anduril Industries. Job location: US sites. Title: Senior International Trade Compliance Engineer. Job ID: 5217656007
Abrams Airborne Manufacturing. Job location: on-site. Title: Export Compliance Officer, Job ID: 1. Contact Cindy Valencia, 1-520-887-1727
Altimeter Solutions. Job location: Londonderry, NH. Title: Remote Export Compliance Coordinator. Job ID: JP6978
Anduril Industries. Job location: Costa Mesa, CA. Title: Director of Air Maneuver Dominance & Maritime, International Trade Compliance. Job ID: 5100621007
Arotech. Job location: Ann Arbor, MI (Hybrid). Title: Director of Trade Compliance. Job ID: 2026-072101. Contact: Erin Heine, 734-761-5836
Arrow. Job location: Denver, CO. Title: Director, Global Trade Compliance Counsel
AV. Job location: Simi Valley, CA (+ other locations). Title: Trade Compliance Officer. Job ID: 8195. Contact: Cherie Labick
AV. Job location: Simi Valley, CA. Title: Export Controls Officer. Job ID: 8215. Contact: Cherie Labick
Axiom Law. Job location: U.S. Remote. Title: Export Trade Compliance Counsel
BAE Systems. Job location: McLean, VA, or Rockville, MD. Title: Import Export Analyst. Job ID: 125516BR. Contact: Jordan Reisman, 301-944-4700
BAE Systems. Job location: Greenlawn, NY; Fort Wayne, IN; Wayne, NJ; Reston, VA (Hybrid). Title: Senior International Trade Analyst. Job ID: 125393BR. Contact Robert Wojcik, 412-377-3351
Barnes & Thornburg. Job location: Washington, D.C. Title: International Trade Associate.
Castelion, Job location: Washington, DC. Title: Senior Counsel, Trade & Export Compliance
Castelion, Job location: Torrence, CA. Title: Senior Counsel, Trade & Export Compliance
Continental Electronics. Job location: Richardson, TX. Title: Trade Compliance Analyst. Job ID: 36830. Contact: Danny Bell, 310-896-6904
Elanco. Job location: Indianapolis, IN. Title: Senior Counsel, Global Trade
Expeditors; Job location: Noorderlaan, Antwerpen, Belgium. Title: Customs Brokerage Agent
Expeditors. Job location: Brisbane, CA. Grapevine, TX. Title: Customs Brokerage Agent
Export Compliance Solutions & Consulting. Job location: Remote, USA. Title: Sales Representative/Software Sales; Contact Suzanne Palmer
FedEx. Job location: Queensland, AU. Title: Customs Broker. Job ID: P25-249616-2
General Atomics Aeronautical Systems. Job location: San Diego (Poway) CA (hybrid). Title: Senior Director, International Trade Compliance. Job ID: 54950BR. Contact Arthur Shulman
General Atomics. Job location: San Diego CA (hybrid) or another U.S. location including Wash DC; Huntsville, AL; Tupelo, MS; Denver, CO. Title: Senior Trade Compliance Integrator. Job ID: 52696BR; Contact James Van Eenenaam
General Dynamics. Job location: Scranton, PA. Title: Regulations Compliance Specialist II. Job ID: 2026-35876
Hermes. Job location: Manhattan, NYC. Title: Customs / Import-Export Coordinator (Temporary or Full-time)
Hillspire. Job locations: Arlington, VA; Washington, DC; New York, NY; Long Beach, CA; Los Angeles, CA; San Francisco, CA. Title: Export Control Jurisdiction and Classification Manager. Job ID: 1762. Contact: Tracy Gronewold
Hillspire. Job locations: Arlington, VA and New York, NY. Title: Trade Compliance Counsel. Job ID: 1761. Contact: Tracy Gronewold
Home Depot. Job location: Atlanta, GA. Title: Corporate Counsel, Supply Chain and International
Honeywell Aerospace. Job location: Charlotte, NC. Title: Trade Compliance General Counsel. Job ID: 147681
Honeywell Aerospace. Job location: Charlotte, NC. Title: Senior Trade Compliance Investigator. Job ID: 150642
Horizon3 AI. Job location: U.S> Remote. Title: Senior Legal, Privacy & Export Compliance
Immigration & Customs Enforcement (ICE). Job Location: Birmingham, AL. Title: General Attorney, Immigration and Customs
Immigration & Customs Enforcement (ICE). Job Location: Washington, DC. Title: General Attorney, Criminal/Customs
L3Harris. Job location: Ottawa, Canada. Title: Trade Compliance Senior Specialist. Job ID: 38357
Lockheed Martin. Job location: Syracuse & Owego, NY. Title: International Trade Compliance, Senior Staff. Job ID: 733880BR. Contact: Rebecca Edwards, 203-540-7922
Mastronardi Produce. Job Location: Livonia, MI; Title: Customs Manager (Certified Customs Specialist); Job ID: CUSTO011196. Contact Tiziana Mastronardi, 519-796-7710
McCarter & English. Job locations: Newark, NJ; Stamford, CT; New York, NY. Title: Trade Specialist. Job ID: 001. Contact: Christine Lydon
Mercedes-Benz. Job location: US Remote/Hybrid. Title: Senior Counsel, Export Compliance (Contractor). Job ID: Legal (4031)
Northrop Grumman. Job location: 9 locations Title: Principal International Trade Compliance Analyst. Job ID: R10240096
Northrop Grumman. Job location: Falls Church, VA or Linthicum, MD. Title: Corporate Counsel II - Export/Import. Job ID: R10243093
Northrop Grumman. Job location: Linthicum, MD; San Diego, CA; Rolling Meadows, IL; Charlottesville, VA; or Woodland Hills, CA. Title: Manager 3 - Global Trade. Job ID: R10238060
PCC Airfoils. Job Location: On-site; Title: Facility Trade Compliance Officer, Job ID: 13286
Peraton. Job location: Reston, VA (& local remote). Title: Manager, Trade Compliance. Job ID: 169785. Contact: Julia Mason
Planet. Job location: DC Metro Area; Denver; San Francisco; Remote. Title: Technical Program Manager, Trade Compliance. Job ID: 8014103. Contact Ashley McNally.
Planet Labs. Job location: San Francisco, CA. Title: Senior Analyst, International Trade Compliance. Job ID: 8069677. Contact: Albert Zuniga
Planet Labs. Job location: San Francisco, CA. Title: Analyst, International Trade Compliance. Job ID: 8077154. Contact: Albert Zuniga
Radiant. Job Location: Renton, WA. Title: International Operations Specialist Lead
Rapiscan Systems. Job location: Billerica, MA. Title: Trade Compliance Manager. Job ID: 37117. Contact: Jon Logins, 978-584-6450
Regeneron. Job location: East Greenbush, NY. Title: Senior Trade Analyst, Customs Brokerage. Job ID: R46522
Rieter AG. Job location: Winterthur, Switzerland. Title: Head of Trade Compliance. Contact: Jasmin Bauer
Rocket Lab Corp. Job location: Long Beach, CA. Title: Senior Legal Counsel
Safran Nacelles Services Americas. Job location: Plainfield, IN (or remote). Title: Import & Export Control Specialist. Job ID: 2026-181128. Contact: Kendall Hatcher, 214-882-3886
Safran Power Units Dallas. Job location: Grand Prairie, TX (or remote). Title: Trade Compliance Manager. Job ID: 170562. Contact: Meagan Montelongo, 858-276-8242
Salesforce. Job location: Wash DC. Title: Export Control Manager & ITAR Compliance Official. Job ID: JR346062. Contact: Amber Graves
SpaceX, Job location: Hawthorne, CA. Title: Counsel, Global Trade Compliance
SpaceX, Job location: Palo Alto, CA. Title: Counsel, Global Trade Compliance
STENA. Job location: Baltimore, MD. Title: MRO Customer Program Manager
Teledyne. Job locations: Elkridge, MD; Billerica, MA; Goleta, CA; Hudson, NH. Title: Export Licensing Specialist (EAR/ITAR). Job ID: REQ36249
Teledyne. Job location: Garland, TX; Billerica, MA; Elkridge, MD. Title: Trade Compliance Director, Aerospace & Electronics Segment. Job ID: REQ33489.
TikTok. Job location: Wash DC. Title: Global Head of Export Control & Trade Compliance
Tower Semiconductor. Job location: Newport Beach, CA. Title: In-House Legal Counsel. Job ID: 9452. Contact: Alyssa Olaosebikan, 949-435-8549
Trane Technologies. Job location: Davidson, NC; San Diego, CA. Title: Trade Compliance Specialist
Unical Aviation. Job location: Glendale, AZ. Title: Senior Export Control Manager. Job ID: 2026-0778. Contact: Rebecca Whiteley, 626-949-3325
Wurth Industry USA. Job locations: Greenwood, IN; Brooklyn Park, MN; Roanoke, VA; or Bondurant, IA. Title: Logistics Specialist. Job ID: LOGIS006301. Contact: Stephanie Johnston, 612-505-1605
Wurth Industry USA. Job locations: Greenwood, IN; Brooklyn Park, MN; Roanoke, VA; Bondurant, IA. Title: Export Compliance Specialist. Job ID: EXPOR006254. Contact: Stephanie Johnston, 612-505-1605
Zygo. Job location: Location of Employment: Middlefield, CT. Title: Trade Compliance Specialist. Job ID: 70100. Contact: James Scroggins, 860-652-2971

EDITOR'S NOTES

26. Do You Have Access to the Latest and Greatest ITAR and FTR?

Bartlett's Annotated ITAR ("BITAR") (6 July 2026) and Bartlett's Annotated FTR ("BAFTR") (6 July 2026) are Word documents to download to your laptop to keep you updated on the latest amendments to the International Traffic in Arms Regulations (22 CFR 120-130) and the Foreign Trade Regulations (15 CFR Part 30).

They contain over a thousand footnotes of errors in the official text, section histories, key cases, practice tips, Consent Agreements, glossaries, and extensive Tables of Contents. You download the updated edition when the regs are amended, so you'll always have the latest regulations.

But if the official on-line version of the ITAR is free, why subscribe to the BITAR?"

Answer: Compare the BITAR with the Government's free version.

Compare the BITAR with the Government's free version

Download this PDF by clicking the button below.

411.65 KB • File

You'll see why all export professionals must use the BITAR and BAFTR.

Subscribe today!

27. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

Bret Harte (born Francis Brett Hart; August 25, 1836 -- May 5, 1902; was an American short story writer and poet, best remembered for his short fiction featuring miners, gamblers, and other romantic figures of the California Gold Rush.)
- "The only sure thing about luck is that it will change."
- "Never a tear bedims the eye that time and patience will not dry."
William A. Feather (25 Aug 1889 -- 7 Jan 1981; was an American publisher and author, based in Cleveland, Ohio.)
- "Setting a good example for children takes all the fun out of middle age."
Sean Connery (Sir Thomas Sean Connery; 25 Aug 1930 -- 31 Oct 2020; was a Scottish actor and film producer. Connery was the first actor to portray the fictional British secret agent James Bond in motion pictures, starring in seven Bond films between 1962 and 1983.)
- "There is nothing like a challenge to bring out the best in man."
- "Some age, others mature."

28. Today in History (Source: History Channel)

1944 -- Paris was liberated from Nazi occupation; the German commander surrendered to Allied forces.

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

(Source: Editor)

Don't miss an issue of the Daily Bugle if you change your email. Click here to manage your profile.

30. Are Your Copies of Export/Import Regulations Current?

(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.