26-0923: Wednesday's "Export/Import Daily Bugle"

1. CBP to Conduct Electronic Export Manifest for Truck Cargo Test

(Source: 91 FR 60383, 23 Sep 2026)

AGENCY: U.S. Customs and Border Protection, DHS.

ACTION: General notice.

SUMMARY: This document announces that U.S. Customs and Border Protection (CBP) will conduct an Automated Commercial Environment (ACE) Electronic Export Manifest (EEM) for Truck Cargo Test.

     The ACE EEM for Truck Cargo Test is a voluntary test in which truck export participants agree to the submission of certain limited export manifest data electronically at least 24 hours prior to departure from the United States to a foreign destination to then be complemented by the complete export manifest filing no later than two (2) hours prior to arrival at the final port of export.
     This notice provides a description of the test, sets forth eligibility requirements for participation, and invites public comment on any aspect of the test.

DATES: The test will begin on October 23, 2026, and will run for approximately two years.

2. Commerce Posts Procedures for Implementing Tariff Adjustments for Specialty Pharmaceuticals and Technical Corrections to the HTSUSA for Duties Under Proclamation 11020

(Source: 91 FR 60360, 23 Sep 2026)

AGENCY: Bureau of Industry and Security, Office of Strategic Industries and Economic Security, U.S. Department of Commerce.

ACTION: Notice.

SUMMARY: This notice defines the pharmaceutical products and lists the jurisdictions that are eligible to receive an ad valorem tariff rate of zero pursuant to Presidential Proclamation 11020 of April 2, 2026, “Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients Into the United States,” (Proclamation 11020).

     These pharmaceutical products include drugs and associated ingredients where all approved indications are designated as orphan; nuclear medicines; plasma-derived therapies; fertility drugs; cell therapy products; gene therapy product; antibody drug conjugates; medical countermeasures related to chemical, biological, radiological, and nuclear threats; and animal health.
     Proclamation 11020 states that such products and associated ingredients receive the Section 232 zero tariff rate if they are products of a jurisdiction that has a current or forthcoming trade and security framework agreement or if they meet an urgent U.S. health need.
     This notice also includes procedures for the public to submit information for the Department of Commerce’s (Commerce) approval to determine if imports of the pharmaceutical products and associated ingredients meet an urgent U.S. health need.
     This notice also issues five technical corrections to Annex I and one technical correction to Annex IV of the Proclamation.

DATES: Submission of information will be received on an ongoing basis starting September 23, 2026.

3. OFPP, OMB, DOD, GSA, and NASA Seek Comments on Revisions of FAR Parts 16, 17, and 35

(Source: 91 FR 60421, 23 Sep 2026)

AGENCY: Office of Federal Procurement Policy (OFPP), Office of Management and Budget (OMB); Department of Defense (DOD); General Services Administration (GSA); and National Aeronautics and Space Administration (NASA).

ACTION: Notice and request for comments on “Revolutionary Federal Acquisition Regulation Overhaul Parts 16, 17, and 35,”

SUMMARY: OFPP, DOD, GSA, and NASA (FAR Council) invite public comments changes in FAR Case 2026-006, “Revolutionary Federal Acquisition Regulation Overhaul Parts 16, 17, and 35.” specifically regarding changes to information collections due to the proposed rule.

DATES: Submit comments by November 23, 2026.

4. State Amends ITAR to Correct 18 Sep 2026 ITAR Amendments

(Source: 91 FR 60299, 23 Sep 2026)

AGENCY: Department of State

ACTION: Correcting amendments; Clarifying Policies of Denial, Updating the Major Non-NATO Ally List, and Minor Corrections

SUMMARY: On September 18, 2026, the Department of State revised the International Traffic in Arms Regulations (ITAR) to clarify certain policy-of-denial provisions, update country policies for Ethiopia and Somalia, add Saudi Arabia and Peru to the list of major non-NATO allies, and make other miscellaneous corrections. That document included incorrect amendatory instructions resulting in the inadvertent removal of regulatory text. This document corrects the final regulations.

DATE: This rule is effective on September 23, 2026.

[Editor’s Note: The latest edition of Bartlett's Annotated ITAR (23 Sep 2026), containing the corrected text, is available HERE.]

5. Future Federal Register (One item.)

(Source: Future Federal Register)

6. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

7. CBP Events in September 2026

(Source: OTR Webinars)

8. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

9. DCSA: “2026 Virtual DCSA Security Conference Focuses on ‘Protect Our Potential’ Through Partnership, Modernization and Mission Readiness”

(Source: Defense Counterintelligence and Security Agency, 22 Sep 2026)

     The Defense Counterintelligence and Security Agency (DCSA) hosted the 2026 Virtual DCSA Security Conference Sept. 14-18, as cleared industry professionals, Department of War (DoW) security stakeholders and foreign ownership, control or influence (FOCI) practitioners convened under the shared theme, “Protect Our Potential.”
     DCSA combined its annual National Insider Threat Awareness Month Conference, Security Conference for Industry, Security Conference for DoW, and FOCI Conference into a single week to streamline information sharing, strengthen collaboration, and familiarize participants with DCSA’s Strategic Execution Plan to deliver data-driven, threat-informed, and customer-trusted security services at scale. …
     Mr. Rivers was among more than 60 speakers presenting briefs and technical updates while answering questions throughout the conference. Speakers emphasized the importance of defending sensitive information, technology and facilities while enabling the people, partnerships and capabilities that give the United States a sustained competitive advantage. …..

10. DSCA Posts Policy Memo on “Rough Order of Magnitude Pricing Clarification”

(Source: Defense Security Cooperation Agency)

     DSCA has posted Policy Memo 26-123 Rough Order of Magnitude Pricing Clarification. This memorandum updates the Security Assistance Management Manual (SAMM) with clarification changes to the Rough Order of Magnitude Pricing policy. This memorandum does not introduce any substantive policy changes. This memo updates:

11. State/DDTC (Nothing new.)

(Source: State/DDTC)

12. Treasury/OFAC Removes Democratic Republic of the Congo-Related Entities from SDN List

(Source: Treasury/OFAC, 23 Sep 2026)

     Specially Designated Nationals List Update. The following deletions have been made to OFAC's SDN List. …

13. UK Export Control Joint Unit: “How to Apply for an Export ‘Health Certificate’ (EHC)”

(Source: UK ECJU, 23 Sep 2026)

     Guidance for exporters in England, Scotland and Wales on applying for an “export health certificate” (EHC).
     1. Certificates you can apply for using EHC Online.

You can apply for:

     1.1 Certificates for trade with third countries (countries outside of the EU): The most frequently used certificates are available on EHC Online. They are downloaded and printed by your certifier, who is your official vet (OV) or inspector. Some EHCs are printed on special watermarked ‘crown gold’ paper and posted to your certifier by APHA.
     If an EHC is not available on EHC Online, you can apply by filling in a PDF application and sending it by email to APHA.
     1.2 Certificates for EU trade: These EHCs are downloaded from EHC Online by your certifier to print on white paper. These EHCs include a copy in the language of the border control post (BCP) where your export will enter the EU. For example, if you’re applying for an EU EHC that will enter the EU at a BCP in France and the final destination is in Spain, your certifier will get English and French language EHCs to certify.
     You do not have to fill in any questions that are not in English - the system will copy your answers automatically.
     2. Accessing EHC Online: …

14. US Trade Representative Announces Fiscal Year 2027 WTO Tariff-Rate Quota Allocations for Raw Cane Sugar

(Source: USTR Press Office, 23 Sep 2026)

     The Office of the U.S. Trade Representative (USTR) today announced country-specific in-quota allocations of the tariff-rate quota (TRQ) for imported raw cane sugar for Fiscal Year (FY) 2027 (October 1, 2026 through September 30, 2027).
     TRQs allow countries to export specified quantities of a product to the United States at a relatively low tariff, but subject all imports of the product above a pre-determined threshold to a higher tariff.
     On July 14, 2026, the Administrator of the Foreign Agricultural Service of the U.S. Department of Agriculture announced the establishment of the in-quota quantity for raw cane sugar for FY 2027.
     The in-quota quantity for the TRQ on raw cane sugar for FY 2027 is 1,117,195 metric tons raw value (MTRV), which is the minimum amount to which the United States is committed under the World Trade Organization (WTO) Agreement.
     On July 24, 2026, USTR provided notice of country-by-country allocations for 1,061,202 MTRV of the FY 2027 in-quota quantity of the WTO TRQ for imported raw cane sugar. See 91 FR 46822. The U.S. Trade Representative is allocating the remaining quantity of 55,993 MTRV to the following countries in the amounts specified below: …

15. White House Executive Actions: (No items of interest.)

(Source: The White House)

16. Expeditors News: “August 2026 Antidumping and Countervailing Duties Updates”

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

     In August of 2026, the U.S. International Trade Administration (ITA) announced several antidumping (AD) and countervailing duty (CVD) determinations, as well as the initiation of investigations. Details on these cases, including the affected HTS numbers, can be found in the official notices linked below.

Preliminary determinations were published for the following:

The following AD and CVD investigations were initiated:

Final determinations were published for the following AD and CVD cases:

17. ST&R Trade Report: “Import Restrictions Imposed to Prevent Stockpiling of Polysilicon”

(Source: Sandler, Travis & Rosenberg Trade Report, 23 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     The Bureau of Industry and Security has issued a temporary final rule designed to prevent companies from stockpiling polysilicon or its derivatives before import restrictions on those items take effect Dec. 4.
     Earlier this year President Trump issued a proclamation setting forth a number of actions against imports of polysilicon (which is used in semiconductor and solar power supply chains) and specified derivatives, including minimum import prices and a Section 232 tariff.
     The proclamation also directed the Department of Commerce to restrict imports by any company (and its affiliates) determined to be stockpiling polysilicon or derivatives before Dec. 4. The new BIS rule follows through on that requirement in the following ways: … [Continue]

18. ST&R Trade Report: “CBP to Test Electronic Export Manifests for Truck Cargo”

(Source: Sandler, Travis & Rosenberg Trade Report, 23 Sep 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     U.S. Customs and Border Protection has announced [see Item #1 above] that it will conduct a test of electronic export manifests for truck cargo. This test begins Oct. 23 and runs for about two years. It will be limited to nine truck carriers.
     Under existing regulations, truck carriers are not required to submit a manifest for cargo exported from the U.S. by truck. However, the U.S. principal party in interest is required to submit any required electronic export information for such cargo in the Automated Commercial Environment.
     Under the forthcoming test, participants will submit certain limited export manifest data in ACE at least 24 hours prior to departure from the U.S. to a foreign destination. Participants will then submit the complete export manifest filing no later than two hours prior to arrival at the final port of export. …
     Any truck cargo identified as potentially high-risk will receive a hold until required additional information related to the shipment is submitted to clarify non-descriptive, inaccurate, or insufficient information; a physical inspection is performed; or other appropriate action is taken, as specified by CBP. Once the cargo is cleared for loading, a release message will be generated and transmitted to the filer.

19. WTTL: “State Corrects ITAR Rule to Restore University Exemption Conditions and U.S. Government Transfer Exceptions”

(Source: Washington Trade & Tariff Letter, 23 Sep 2026) [Excerpts]

     The State Department has filed (91 FR 59059, 18 Sep 2026) correcting amendments to restore provisions inadvertently removed by its September 18 amendments to the International Traffic in Arms Regulations (ITAR).
     The corrections restore three conditions governing universities’ releases of technical data to foreign employees and two exceptions to restrictions on exemption use involving proscribed destinations. Publication was made today, September 23, with effectiveness upon publication. [See Item # 4 above.]
     The errors arose because the September 18 rule’s amendatory instructions replaced entire paragraphs when State intended to revise only specified portions. Instruction 7 replaced § 125.4(b)(10), omitting its subordinate conditions; instruction 9.a. replaced § 126.1(a), omitting two existing exceptions. State expressly identifies both deletions as inadvertent.
     The material differences are: … [Continue]

20. Akin: “Newly Enacted Law Targeting Russia Creates Novel Tariff Authority over Third-Country Imports, While Reinforcing Existing U.S. Sanctions Framework”

(Source: Akin News and Alerts, 23 Sep 2026) [Excerpts]

Author: Sally Stewart Laing, Akin Gump Strauss Hauer & Feld LLP

Key Points:
• On September 18, 2026, President Trump signed into law the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026. The Act passed the House of Representatives by a vote of 262-159 on September 16, following Senate passage by 86-11 on August 7.
• The Act requires the President to impose tariffs of up to 100% on all goods imported from countries that are among the top five importers of Russian crude oil or natural gas, or among the top five facilitators of Russian oil sanctions evasion. These tariffs stack on top of all other existing duties. The Act also requires the President to increase duties on Russian-origin goods up to 500%.
• In addition, the Act mandates secondary sanctions against third-country persons and vessels engaged in specified categories of Russia-related conduct, as well as primary sanctions on certain Russian persons. These provisions largely overlap with existing sanctions authorities, and despite the mandatory language, the President retains significant discretion over their implementation. Separately, the Act codifies pre-existing Russia sanctions into statute, raising the procedural bar for their removal.
• The Act provides a broad national interest waiver applicable to both tariffs and sanctions and includes a five-year sunset for those provisions.
• The Act also extends the Iran Sanctions Act of 1996 through 2031. … [Continue]

21. Fieldfisher: “Q&A: Export Controls in European Union”

(Source: Lexology Panoramic, Fieldfisher (London), 21 Sep 2026) [Excerpts]

Author: Agnieszka Paulina Regiec, Fieldfisher law firm

     What general controls are imposed on exports? The European Union export control regime governs the export, transfer, brokering and transit of dual-use items. Its objective is to contribute to international peace and security by controlling exports and other transactions involving dual-use items, including through licensing requirements and controls based on end use.
     Additionally, in the European Union, export controls encompass both EU-wide restrictions established through EU legislation and specific export controls implemented at the national level by individual EU member states.
     Under article 269 of the Union Customs Code (UCC), goods intended for export are subject to an export declaration. Moreover, these controls typically involve licensing requirements or prohibitions on the cross-border movement of items listed on specified control lists established at national or international levels. They also apply when sensitive end uses are involved, with potentially severe consequences for non-compliance.
     Examples of goods that require a licence before they can be exported are:

     The European Commission’s latest annual report on Regulation 2021/821 published in June 2026, highlights continued efforts to strengthen the implementation and enforcement of EU dual-use export controls (COM(2026) 296 final, dated 25 June 2026).
     The EU dual-use control list in Annex I to Regulation (EU) 2021/821 was most recently updated by Commission Delegated Regulation (EU) 2025/2003, applicable from November 2025.

In addition, in April 2025, the EU adopted Recommendation (EU) 2025/683 to improve coordination of national control lists and enhance transparency in export control enforcement.

     Government authorities: Which authorities handle the controls? …
     [Continue]

22. Foreign Affairs: “China Still Has What America Needs”

(Source: Foreign Affairs, 21 Sep 2026) [Excerpts of subscription service.]

Author: Adam S. Posen, President of the Peterson Institute for International Economics.

     The Trump administration approached its summit with Chinese leader Xi Jinping in October 2025 projecting confidence, asserting that it held leverage over China as the trade deficit country in the bilateral relationship.
     As U.S. Treasury Secretary Scott Bessent put it, “What do we lose by the Chinese raising tariffs on us? We export one-fifth to them of what they export to us, so that is a losing hand for them.”
     This was quickly shown to be folly. As I argued in Foreign Affairs, trade wars are easy to lose when countries depend upon an exporter for hard-to-replace inputs, yet still conceive of trade as a zero-sum game. China has escalation dominance over the United States, meaning that at any level of threat, the Chinese government has the ability to inflict more pain on the United States than vice versa.
     To ease Beijing’s restrictions on rare-earth elements, for example, which allow China to control 80 to 90 percent of production, the United States has conceded on tariffs, technology controls, and visa policies during various negotiations. …
     Economic relationships are not all or nothing; they have room for resistance and cooperation, even if one side would clearly lose if it came down to outright conflict. Despite the high distrust and strategic rivalry between the two countries, the U.S.-Chinese economic relationship does not have to be played as a zero-sum game.
     The benefits from trade and diversification for both economies remain substantial, and China’s escalation dominance would not spare its own economy pain if it were forced into a tit-for-tat conflict with Washington. Indeed, Beijing, comfortable with the status quo, has little interest in such escalation.
     At the upcoming summit between Xi and President Donald Trump, the U.S. government should initiate a different approach to the economic relationship by pursuing increased imports of key strategic goods as well as increased foreign direct investment from China. … [Continue]

23. Volkov: “Two Executives, Two Sentencings, One Week”

(Source: Volkov Law, 23 Sep 2026) [Excerpts]

Principal Author: Michael Volkov, Volkov Law Group LLC

     In this episode of Corruption, Crime and Compliance, Michael Volkov examines two significant executive sentencings handed down within a day of each other: Tomás Niembro Concha, the former CEO of Puerto Rico’s now-defunct Nodus International Bank, sentenced to more than nine years for a multiyear fraud scheme that fleeced his own bank of nearly $25 million and a scheme to evade U.S. sanctions on Venezuela by secretly selling a sanctioned individual’s foreclosed home back to him through a front company; and Javier Aguilar, a former Vitol oil trader, sentenced to four years, well below the twelve DOJ sought, for bribing officials in Ecuador and Mexico to win Vitol more than $500 million in state oil company business.
     Volkov draws out the common threads between the two cases, shell entities, sham documentation, and years of concealment from the very oversight functions meant to catch it, and highlights Aguilar’s rejected defense that the bribes were merely industry custom as a rationalization compliance programs should treat as a red flag whenever they hear it internally.
     Hear the podcast HERE.

24. Global Training Center Presents: "EAR Webinar" Live Online Training 2 Oct (Friday) 9 am to 12:30 pm (Central)

(Source: Global Training Center)

25. FD Associates Presents: “ITAR FUNdamentals” Livestream Webinar, 6-9 October

(Source: Jenny Hahn, [email protected])

26. List of Export/Import Job Openings

(Source: Editor)

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28. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

29. Today in History

(Source: History Channel)

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

(Source: Editor)

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31. 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.