26-0904: Friday's "Export/Import Daily Bugle"

(Source: Today's Federal Register)

(Source: Future Federal Register)

(Source: DHS/CBP/CSMS)

(Source: OTR Webinars)

(Source: Commerce/BIS)

(Source: State/DDTC)

(Source: Treasury/OFAC, 4 Sep 2026)

The Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing Iran General License CC, "Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on September 4, 2026."

(Source: The White House)

(Source: Breaking Defense News, 3 Sep 2026) [Excerpts]

     President Donald Trump announced this evening that Adam Telle will step in as the acting Army secretary, "effective immediately."
     Telle, currently serving as the Senate-confirmed assistant secretary of the Army for Civil Works, will take the Army's top civilian role following today's departure of Secretary Dan Driscoll, who handed in his resignation Monday. He will jump the line on Michael Obadal, the undersecretary of the Army, a position which commonly becomes the acting secretary in such cases. . . . [Full article]

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

     In a Cargo Systems Messaging Service (CSMS) bulletin published on September 2, 2026, U.S. Customs and Border Protection (CBP) provided guidance on the implementation of Section 232 duties on unmanned aircraft systems (UAS) and UAS components.
     The guidance was issued following the Presidential Proclamation, "Adjusting Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components into the United States", issued on August 13, 2026.
     The CSMS includes entry filing instructions on UAS and UAS components and provides the applicable Chapter 99 tariff provisions for each scenario that was detailed in the original proclamation.
     CBP also confirmed that manufacturing drawback claims shall be available on these Section 232 duties imposed under this action.
     In addition, products entered into a Foreign Trade Zone (FTZ) that are subject to the duties imposed by the proclamation may only be entered under "privileged foreign status," unless eligible for admission under "domestic status", and will be subject to these Section 232 duties when entered for consumption.
     The section 232 duties on unmanned aircraft will go into effect on UAS entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on September 3, 2026. Duties on UAS components will go into effect on or after 12:01 a.m. Eastern Time on February 9, 2027.

CSMS #69738151 is HERE. The "Adjusting Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components into the United States" Presidential Proclamation is HERE.

(Source: Sandler, Travis & Rosenberg Trade Report, 4 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Bureau of Industry and Security's most recent annual report highlights that federal trade enforcement efforts are expanding significantly on the export side as well as the import side.
     The report offers the following data on BIS enforcement efforts in 2025:

     BIS further expanded export controls in 2025, including by restricting exports of high-performance semiconductor chips, adding 142 entities to the Entity List, requiring export licenses for semiconductor manufacturing equipment and consumables to Korean- and Taiwanese-owned manufacturing facilities in China, and drastically curtailing the issuance of licenses for exports to companies on the Entity List.
     BIS also worked to secure foreign alignment with U.S. export controls, including through commitments in reciprocal trade agreements. . . . [Full article]

(Source: Sandler, Travis & Rosenberg Trade Report, 4 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Consumer Product Safety Commission has issued a guidance document to help importers and customs brokers comply with the CPSC's eFiling requirement for mail shipments using the new entry type 13.
     The CPSC's eFiling program requires importers to electronically file data elements at the time of filing an entry, including (1) identification of the finished product, (2) the party certifying compliance, (3) each consumer product safety rule to which the finished product has been certified, (4) the date and place the finished product was manufactured, (5) when and where the finished product was most recently tested for compliance, and (6) contact information for the person maintaining test records. This requirement applies to imports of all CPSC-regulated consumer products and substances that require certification, including de minimis shipments.
     In conjunction with U.S. Customs and Border Protection's upcoming launch of a test of a new electronic informal entry type 13 for international mail shipments valued at $2,500 or less, beginning Oct. 22 the CPSC will require eFiled certificates for mail shipments via a full or reference message set in the Automated Commercial Environment. ...

[Full article]

(Source: Sandler, Travis & Rosenberg Trade Report, 4 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Federal Maritime Commission has issued a final rule regarding the filing of charge complaints, which provide a simplified way to dispute charges assessed by common carriers (e.g., demurrage and detention fees) that may not comply with the Ocean Shipping Reform Act of 2022.
     The FMC previously established an interim procedure under which the filing of a charge complaint initiates an informal process of investigation by the FMC's Bureau of Enforcement, Investigations, and Compliance.
     If that investigation supports a finding of violation, BEIC recommends that the FMC order the carrier to show cause why it should not be ordered to refund or waive the relevant fees or charges. . . .
     The FMC is now amending its regulations to clarify that a charge complaint may be pursued not only through the interim procedure but also through the FMC's traditional complaint processes; i.e., by filing a private party formal complaint or a small claims complaint. . . . [Full article]

(Source: Export Law blog, 4 Sep 2026) [Excerpts]

     Container Manufacturing, Ltd., based in Dayton, Ohio, was charged by the Bureau of Industry and Security ("BIS") with exporting equipment valued at $264,721 and used in the manufacture of aluminum beverage cans to a company in Russia.
     According to the charging documents, these EAR99 exports required licenses because they had HTSUS classifications 8466.94 and 8462.29, both listed on Supplement 4 to Part 746.
     The company, which did not file a voluntary disclosure, but which did cooperate with the BIS investigation, was hit with, and agreed to pay, an eye-watering $1 million fine within 30 days of the settlement. That $1 million penalty, incidentally, was nearly four times the value of the exports.
     There does not appear to be any reason to contest that the items were properly classified as HTS 8466.94 and 8462.29 and were exported by the company to Russia without the required export licenses. Or that the company could be punished for this violation.
     But the BIS charging documents went beyond that and charged the company with knowing violations under EAR section 764.2(e).
     A key element in establishing a knowing export violation would be what the company said was the HTS or Schedule B classification of the can manufacturing parts on the EEIs that it filed with the export declaration.
     Oddly, absolutely nothing at all was said about this in the charging documents. I'm going to bet that's because the EEIs did not state that the items were 8466.94 and/or 8462.29. If they did state that, well, I'm 10,000 percent certain BIS would have highlighted that.
     So, how did BIS reach the conclusion, without an EEI admission, that the company acted with knowledge? BIS says . . . [Full article]

(Source: Customs & International Trade Law Blog, 4 Sep 2026) [Excerpts]

     As mandated by Section 10612 of the CHIPS and Science Act, the White House Office of Science and Technology Policy (OSTP) issued the National Security Science and Technology Strategy (NSSTS), which implements the S&T priorities of the 2025 National Security Strategy.
     While framed as a technology strategy, the NSSTS previews concrete near-term action on CFIUS, outbound investment, export controls, and federal research security --- direct touchpoints for clients in cross-border investment, controlled technology, and federally funded R&D.
     Key Takeaways:

     For companies involved in cross-border investment, the NSSTS signals that national security review may become relevant to a broader range of transactions and investment structures. . . .
     U.S. companies seeking foreign capital should also conduct greater diligence into prospective investors, their ownership and affiliations, and any connections to countries or entities of concern. . . . [Full article]

(Source: Gibson Dunn Insights; 3 Sep 2026) [Excerpts]

     We examine the Commerce Department's four 2026 antiboycott settlements and what they reveal about an enforcement program enhanced under the prior administration --- and accelerating under the current one.
     The last two years have produced the most intensive period of U.S.-Gulf commercial engagement in a generation, with announced trade and investment commitments across the Gulf Cooperation Council states spanning artificial intelligence and data center buildouts, civil and military aviation, energy and critical minerals, advanced manufacturing, and healthcare. At the same time, Gulf sovereign wealth funds have become among the most active foreign investors in U.S. capital markets.
     As U.S. companies compete for regional tenders, procurement programs, joint ventures, and new investment opportunities, their operational footprint will expand into precisely the jurisdictions where the Arab League boycott of Israel retains commercial expression.
     Because the U.S. antiboycott regimes attach liability to the receipt of certain requests to participate in unsanctioned foreign boycotts, the same growth that makes the Gulf a strategic priority also increases the risks that can arise from failing to identify reportable boycott requests.
     Against this backdrop, the U.S. Commerce Department's Office of Antiboycott Compliance (OAC) has already announced four public settlements in 2026, resolving charges that arose not from deliberate boycott participation, but from routine commercial paperwork, including pre-populated trade show shipping documents and boilerplate purchase order terms containing boycott-related language. . . .
     For companies doing business in the Gulf, where U.S. commercial engagement is at a generational high and where the Arab League boycott of Israel remains a feature of domestic law, the top takeaway is that antiboycott compliance must remain top-of-mind, not only for compliance and legal departments but also for sales and logistics teams and contract reviewers up and down the organization.
     I. Antiboycott Legal Framework in Brief: . . .
     II. The Four 2026 Settlements: . . .

     As summarized below, each of the four settlements to-date in 2026 followed a voluntary self-disclosure; each required the respondent to admit the conduct alleged; and each resulted in a public charging letter, settlement agreement, and order. . . . [Full article]

(Source: Sandler, Travis & Rosenberg Trade Report, 4 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     A report from the International Trade Commission finds that the revocation of permanent normal trade relations treatment for goods imported from China would have mixed effects on U.S. consumers and producers.
     The report states that duty rates for manufactured products from China would increase by 28.8 percentage points, compared to increases of 7.3 and 0.8 percentage points for agriculture products and mining and energy products, respectively.
     As a result, U.S. consumers and producers would adjust their purchases away from Chinese imports, which would fall 30.8 percent after six years and 73.8 percent in the long run.
     Instead, imports from other trading partners would increase, especially from Mexico, Taiwan, Vietnam, Canada, Japan, and South Korea. Purchases of domestic shipments would see small increases as well, by 0.6 percent in the sixth year and 1.8 percent in the long run.
     Over time, the report states, these changes would result in U.S. consumers and producers facing price increases of 0.7 percent and 0.5 percent, respectively, and higher prices on intermediate goods would reduce real output by 0.2 percent. . . . [Full article]

(Source: Editor)

(Source: Brainy Quotes)

Friday Funnies --- Ironic anagrams:

(Source: History Channel)

1781: Los Angeles was founded by Spanish settlers as "El Pueblo de Nuestra Señora la Reina de los Ángeles." The full translated name was "The Town of Our Lady, Queen of the Angels, of the Porciúncula River." The "Porciúncula" reference traces back to a Franciscan feast day name --- the site had been named by Fray Juan Crespí during the 1769 Portolá expedition, since the party arrived there on the day tied to that feast.

1886: Geronimo surrenders. On September 4, 1886, Apache leader Geronimo surrendered to U.S. government troops. For 30 years, the Native American warrior had battled to protect his tribe's homeland; however, by 1886 the Apaches were exhausted and outnumbered. General Nelson Miles accepted Geronimo's surrender, making him the last Native American warrior to formally give in to U.S. forces and signaling the end of the Indian Wars in the Southwest.

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(Source: Editor)

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23. 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.