26-0922: Tuesday's "Export/Import Daily Bugle"

1. CBP Posts Quarterly IRS Interest Rates for Calculating Interest on Overdue Accounts and Refunds of Customs Duties

(Source: 91 FR 60141, 22 Sep 2026)

* AGENCY: U.S. Customs and Border Protection, Department of Homeland Security

* ACTION: General notice.

* SUMMARY: This notice advises the public that the quarterly Internal Revenue Service interest rates used to calculate interest on overdue accounts (underpayments) and refunds (overpayments) of customs duties will remain the same from the previous quarter. For the calendar quarter beginning October 1, 2026, the interest rates for underpayments will be 7 percent for both corporations and non-corporations. The interest rate for overpayments will be 7 percent for non-corporations and 6 percent for corporations. This notice is published for the convenience of the importing public and U.S. Customs and Border Protection personnel.

* DATE: Applicable as of October 1, 2026.

2. Future Federal Register

(Source: Future Federal Register)

3. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

4. CBP Events in September 2026

(Source: OTR Webinars)

5. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

6. State/DDTC (Nothing new.)

(Source: State/DDTC)

7. White House Executive Actions (No items of interest.)

(Source: The White House)

8. Aviationist: “U.S. Approves F-35 Foreign Military Sale to Saudi Arabia”

(Source: The Aviationist, 17 Sep 2026) [Excerpts]

     The U.S. State Department has approved the Foreign Military Sale (FMS) requested by Saudi Arabia for the acquisition of the F-35 Lightning II. Saudi Arabia could get up to 48 F-35A aircraft, a spare engine and related equipment for a total estimated cost of $24.3 billion.
     The approval ends years of discussions between the two countries about the acquisition of 5th generation fighter aircraft capabilities and also marks what could be a major policy change. Both the UAE and Saudi Arabia have been negotiating to procure the F-35, however the U.S. appeared unwilling to authorize them.
     The Foreign Military Sale. The FMS notification includes a list of non-MDE (Major Defense Equipment) items which will be included, such as secure communications, spare parts, test devices and various support equipment. Interestingly, no weapons were mentioned in the notification, although they might have not been mentioned or they might be pending a separate approval. . . .

9. Diaz: “CAPE Phase 3, Russia Iran Sanctions Bill Passes, USTR Seeks Comment on Trade Barriers”

(Source: Customs & International Trade Law Blog, 18 Sep 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)

Court of International Trade (CIT)

United States Trade Representative (USTR)

Bureau of Industry and Security (BIS)

Office of Foreign Asset Control (OFAC)

Consumer Product Safety Commission (CPSC)

Congress

International

10. Expeditors News: “Argentina Enacts MERCOSUR-Singapore Free Trade Agreement”

(Source: Expeditors News, 21 Sep 2026) [Excerpts]

     On September 15, 2026, through Decree 1010/2026, Argentina enacted a free trade agreement with Singapore under the Mercado Común del Sur (MERCOSUR) framework. The agreement was approved and published under Law 27,819 on the same day.
     The agreement contains 19 chapters covering a broad range of trade-related areas, including trade in goods and services, sanitary and phytosanitary measures, intellectual property, customs procedures, and more to promote economic and commercial development.
     Under the agreement, tariff reductions will be implemented over a period of up to 15 years. Products are assigned to a duty reduction schedule that provides either:

     Singapore will eliminate tariffs on 100% of products originating from MERCOSUR, while the South American bloc will provide reduced duty rates to 95.8% of its tariff lines for products originating in Singapore.
     The enforcement date will be in accordance with Article 19.13, paragraph 3, of the agreement, the agreement will enter into force on the first day of the second month following the deposits its instrument of ratification.

For more information about Law 27,819 and Decree 1010/2026, go HERE.

11. Export Practitioner: “State Revises ITAR Country Policies, Narrows Underwater-Vehicle Controls”

(Source: The Export Practitioner, 18 Sep 2026) [Excerpts of paywall publication.]

     The Department of State issued two ITAR rules scheduled for Federal Register publication on September 18: a final rule revising denial policies and related provisions, and an interim final rule narrowing controls on certain uncrewed underwater vehicles.
     The final rule, “Clarifying Policies of Denial, Updating the Major Non-NATO Ally List, and Minor Corrections,” took effect upon publication. It removed Ethiopia’s country-specific denial policy, added Saudi Arabia and Peru to the major non-NATO ally list, and clarified that Form DSP-83 Nontransfer and Use Certificates are not required under the specified Canadian provisions.
     The rule also clarified the application of denial policies and exemption restrictions to exports, reexports, retransfers, and temporary imports, and revises provisions concerning Somalia, Libya, South Sudan, and the Democratic Republic of the Congo. Applicable licensing requirements remain in place.
     The separate Category XX(a) interim final rule narrows USML controls on uncrewed, untethered underwater vessels exceeding 3,000 pounds but not exceeding 8,000 pounds. Revised paragraph (a)(10) requires both specified autonomous endurance or range and navigation capabilities beyond fixed-waypoint routes, station-keeping, and qualifying collision avoidance.
     Vessels removed from that provision become subject to the Export Administration Regulations if not controlled elsewhere on the USML. Vessels exceeding 8,000 pounds that meet the endurance or range criteria move to new paragraph (a)(11). The existing § 126.9(u) exemption remains available for qualifying paragraph (a)(10) vessels but does not extend to paragraph (a)(11).
     The interim final rule takes effect on 19 October 2026. . . . [Full article]

12. Sat News: “Space Development Agency Issues $369 Million Solicitation for Global Missile Tracking Ground Entry Points”

(Source: Sat News, 22 Sep 2026) [Excerpts]

     On Sept. 22, 2026, the Space Development Agency (SDA) issued a formal request for proposals (RFP) valued at $369 million to procure next-generation ground communications infrastructure for its missile warning and tracking satellite constellation.
     The ground infrastructure procurement supports the expansion of the SDA’s Proliferated Warfighter Space Architecture (PWSA), a multi-tranche Low Earth Orbit (LEO) constellation designed to deliver persistent missile warning, tracking, and beyond-line-of-sight tactical communications.
     The space layer incorporates hundreds of optically linked satellites in low Earth orbit to detect and track advanced hypersonic glide vehicles and regional ballistic missile threats.
     General Dynamics Mission Systems holds the primary ground integration contract for the PWSA Tranche 1 and Tranche 2 operational layers, managing baseline ground station software, command-and-control interfaces, and entry terminals. . . . [Continue]

13. ST&R Trade Report: “White House Targets Transshipment as Customs Crackdown Continues”

(Source: Sandler, Travis & Rosenberg Trade Report, 21 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     A recent White House report focusing on the use of transshipment to avoid U.S. import tariffs and trade remedies offers yet another signal that federal authorities are strengthening customs enforcement efforts and that importers, customs brokers, and others should consider more proactive measures to attenuate related challenges.
     What the Problem Is: The core argument of the report is that substantial volumes of Chinese-origin goods (between $40 billion and $303 billion annually) are entering the U.S. through third countries, resulting in the loss of “tens of billions of dollars” a year in import duty and tariff revenue as well as bigger trade deficits, fewer domestic jobs, and lower economic growth.
     The report asserts the existence of a “global network of production hubs, logistics platforms, free-trade zones, bonded warehouses, processing corridors, and re-export centers” that facilitates illegal transshipment “through both production-side and logistics-side channels.” . . .
     The report further argues that there are more than 40 countries involved in this network, from major trading partners with diversified industrial bases (Canada, Mexico, the European Union, India, Israel, Japan, South Korea, and Taiwan) to countries that are closely integrated into China-linked production and supply networks . . .
     What the Government is Doing -- and May Do: . . .
     A Note on First Sale: Current U.S. law expressly permits first sale valuation when the legal requirements are met, and the report does not assert that first sale is illegal. However, it clearly presents first sale as contrary to the objective of maximizing tariff revenue and suggests that existing customs rules may not adequately support that objective.
     This makes first sale transactions more likely to attract audit, documentation, and policy scrutiny going forward. Companies using first sale should therefore at the very least expect from CBP more CF-28s (requests for information), more audits, and more validation of transaction structures and related-party arrangements. . . .

14. WTTL: “Trump Holds Tariff Threat Ahead of Xi Summit”

(Source: Washington Tariff & Trade Letter, 18 Sep 2026) [Excerpts of subscription publication]

     The Trump administration is holding back new tariff announcements until after President Trump meets Chinese President Xi Jinping on Sept. 24, keeping tariff pressure available while negotiators pursue a narrower package of reciprocal duty relief.
     Bloomberg reported that the administration is expected to delay new tariffs on China and other trading partners until after the summit, citing people familiar with the matter. The pause follows earlier plans for an excess-capacity trade report that could recommend a 7.5 percent tariff on Chinese goods. . . .
     Treasury Secretary Scott Bessent is set to meet Chinese Vice Premier He Lifeng in New York before the summit, with U.S. Trade Representative Jamieson Greer also participating, the Financial Times reported. The talks are expected to cover AI competition, rare earth export restrictions, a possible extension of the broader trade and technology truce, and a Board of Trade framework to identify “non-sensitive” goods for tariff reductions.
     The likely package remains narrow. Reuters reports negotiators are discussing reciprocal tariff reductions covering roughly $30 billion in goods from each country, with agriculture, energy and rare earths among the items traders are watching. China could move the framework forward by cutting duties on U.S. farm products.
     Expectations for a major breakthrough are low because … [Full article]

15. Sidley Austin: “Section 232 Pharma Tariff Update”

(Source: Author, 21 Sep 2026) [Excerpts]

* Author: Ted Murphy, Esq., [email protected]; Sidley Austin LLP

     Those of you in the life sciences/pharmaceutical space know that the Section 232 tariffs President Trump announced back in April go into effect for most companies next Tuesday, September 29, 2026. The original proclamation raised many issues regarding the scope of the tariffs.
     Monday afternoon, the Department of Commerce issued an advanced copy of a Federal Register notice that addresses many of those issues (copy attached). The notice addresses the following specific issues:

16. ST&R Trade Report: “Mexico Proposes Changes to Customs Law”

(Source: Sandler, Travis & Rosenberg Trade Report, 22 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     Mexican President Claudia Sheinbaum has submitted to the Chamber of Deputies a series of proposed changes to the country’s customs law. The proposal, which is not yet in effect, would significantly increase Mexican customs authorities’ ability to scrutinize declared values for imported goods.
     The proposed changes include the following:

     If enacted, the amendments will become effective the day after publication in Mexico’s Diario Oficial de la Federación. These proposed changes indicate that customs valuation, and the documentation supporting declared values, are likely to receive substantially greater scrutiny by Mexican authorities. . . .

17. Volkov: “The EU AI Act: The Digital Omnibus, the Current Timeline, and What to Do Now (Part II of II)”

(Source: Volkov Law, 22 Sep 2026) [Excerpts]

* Principal Author: Michael Volkov, Volkov Law Group LLC

     Part 1 of this series covered where EU AI Act enforcement genuinely stands today: prohibited practices enforceable since February 2025, general-purpose AI obligations running since August 2025, the Commission’s first formal investigations opened in June 2026 into hiring, credit scoring, and student monitoring AI systems, and full enforcement and fining authority active since August 2026.
     In Part 2, we look at what the Digital Omnibus changed, lay out the current compliance timeline across the Act’s different obligation tracks, and translate all of it into practical steps for compliance and legal teams.
     What the Digital Omnibus Actually Changed. The Digital Omnibus on AI, formally EU Regulation 1744/2026, became applicable on July 27, 2026, and its purpose was explicitly to simplify implementation, reduce regulatory duplication with existing EU frameworks, and give certain obligation categories more runway before enforcement applies. It’s important to understand this as a targeted recalibration, not a broad retreat from the Act’s core structure.
     The most significant change involves high-risk AI systems under Annex III, the category covering AI used in contexts like employment decisions, credit and financial access, education, and law enforcement-adjacent applications. Those obligations were originally set to apply starting August 2, 2026, alongside everything else. The Digital Omnibus pushed that deadline back sixteen months, to December 2, 2027.
     Separately, the obligation requiring providers of AI systems that generate or manipulate synthetic content to mark their outputs as artificially generated was deferred by four months, from August 2026 to December 2026. And the requirement that each EU member state establish at least one national regulatory sandbox was pushed back a full year, from August 2026 to August 2027. . . . [Continue]

18. Willkie: “Time for Exporters to Evaluate their Screening Capabilities: Reimposition of 50 Percent Rule on the Horizon”

(Source: Willkie Client Alerts, 21 Sep 2026) [Excerpts]

Author: Britt Mosman, WILLKIE FARR & GALLAGHER LLP

     In late 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued—and then shortly suspended implementation of—the “Affiliates Rule” (or the “Rule”). The Affiliates Rule represented BIS’s attempt to expand limits on the diversion of sensitive technologies and to align its enforcement of Export Administration Regulations (“EAR”) restricted party lists with the Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) so-called 50 percent rule. President Trump agreed to a year-long suspension of the Affiliates Rule’s implementation, beginning November 10, 2025, as part of his trade negotiations with China. That delay ends on November 9, 2026.
     The Rule imposes significant new diligence obligations on exporters (and re-exporters or transferors) of U.S.-origin commodities and technology, making such parties affirmatively responsible for determining the ownership of foreign entities involved in international transactions.
     With that suspension nearing its conclusion and BIS aggressively flexing its enforcement authorities, exporters should reacquaint themselves with the demands of the Affiliates Rule and ensure that their diligence and compliance processes incorporate sufficient detail to evaluate potential counterparties.
     Key Takeaways:
     • The Suspension of the Affiliates Rule is set to end on November 9, 2026, absent further action by the Department of Commerce. While the U.S. and China continue to engage in trade negotiations, the purported focus of the talks is tariffs and so any further suspension of the Rule is not guaranteed.
     • Under the Rule, any foreign entity that is owned 50 percent or more (directly or indirectly) by one or more parties on the BIS Entity List or Military End User (“MEU”) List will be subject to the same restrictions as the designated party. If more than one designated party collectively owns 50 percent or more of the foreign entity, the most restrictive license requirements will apply.
     • Exporters, re-exporters, and transferors will be affirmatively responsible for determining the ownership of foreign entities involved in transactions subject to the EAR. Where a listed entity has some ownership, but the percentages are uncertain, parties must determine the proportion owned by the listed party or obtain a license from BIS before proceeding, unless a license exception applies.
     • BIS has sought larger penalties under the second Trump administration and requested additional enforcement resources from Congress. When the Affiliates Rule snaps back into place, exporters should expect immediate scrutiny from BIS. . . . [Continue]

19. Global Training Center Presents "ITAR Compliance" Live Online Webinar 1 Oct (Thurs)

(Source: Global Training Center)

20. List of Export/Import Job Openings

(Source: Editor)

RECENT:

FULL LIST:

22. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

23. Today in History

(Source: History Channel)

Annually on 22 September: Designated the first day of Fall (autumn), in the United States. It begins with the autumnal equinox today at approximately 7:05 p.m. CDT (8:04-8:05 p.m. EDT). The autumnal equinox marks the moment the Sun crosses the celestial equator heading south, and day and night are nearly equal in length worldwide. After that, daylight hours continue to decrease until the winter solstice. The rate varies with latitude, but for the northern United States, the rate of decrease in September is about 2½ to 3 minutes less daylight each day. In October, about 2 to 3 minutes less daylight each day, and in December the daily loss slows to less than 1 minute per day. After the winter solstice on December 21, daylight hours begin increasing again.

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

(Source: Editor)

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25. 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.