26-0925: Friday's "Export/Import Daily Bugle"

1. Commerce/CITA Adds Product to Annex 3.25 of the CAFTA—DR

(Source: Today’s Federal Register, 25 Sep 2026)

(1) 91 FR 60939: polyester/cuprammonium dyed twill lining fabric
(2) 91 FR 60940: viscose printed twill lining fabric
(3) 91 FR 60941: polyester/viscose dyed twill lining fabric

2. Future Federal Register (No items of interest.)

(Source: Future Federal Register)

3. CBP Cargo Systems Messages

(Source: DHS/CBP/CSMS)

4. CBP Changes Submission Method for Organization Broker License Applications as of 30 Sep 2026

(Source: CSMS # 70013692, 25 Sep 2026)

     CBP is automating the submission method for Organization Broker License Applications. As of September 30, 2026, organization license applicants will complete and submit all applications and associated fees through the eCBP portal.
     Organization license applications that are hand-delivered, mailed, or emailed on or after September 30, 2026, will be returned to the applicant for submission through the eCBP portal.
     Organization broker license applicants will log into eCBP using the same Login.gov account used when they applied for the Customs Broker License Exam. eCBP accepts credit and debit card payments. No additional fees are charged for payments, and receipts are provided electronically.
     The change in submission method does not confer any processing position benefit. Organization license application submissions through eCBP will place an application into the already existing queue of applications.
     For more information on the eCBP portal, including FAQs and Quick Reference Guides, visit the eCBP Broker homepage and eCBP Broker Resources page.
     For policy questions regarding organization license application submission, contact the CBP Broker Management Officer at the application processing location. Broker Management Officer contact information by location is available on the CBP Customs Brokers webpage.
For technical questions regarding the eCBP portal, contact the RevMod Service Desk (RMSD) at [email protected] or call 1-800-366-8732 Ext 4670.

5. CBP Events in September 2026

(Source: OTR Webinars)

6. Commerce/BIS (Nothing new.)

(Source: Commerce/BIS)

7. State/DDTC (Nothing new.)

(Source: State/DDTC)

8. UK Export Control Joint Unit: “Guidance on Exporting or Moving Live Animals”

(Source: UK ECJU, 24 Sep 2026)

     Guidance: What you need to do to export live animals from the UK. Contents:

9. US Trade Representative: “Ambassador Greer to Travel to Milwaukee to Host the G20 Trade Ministerial”

(Source: USTR Press Office, 25 Sep 2026)

     Ambassador Greer will travel to Milwaukee, Wisconsin, next week to host the G20 Trade Ministerial. During the ministerial, Ambassador Greer will spearhead discussions with the G20 Trade Ministers on a wide range of issues, including eliminating forced labor in global supply chains, updating the Most-Favored Nation (MFN) principle, denouncing the weaponization of trade in food, and addressing structural excess capacity and production.
     On the margins of the ministerial, Ambassador Greer will tour Rockwell Automation with the G20 Ministers. While walking the factory floor, Ambassador Greer and the G20 Ministers will meet with blue-collar workers and industry leaders to discuss how President Trump’s trade program is accelerating America’s reindustrialization and reinforcing our supply chains.

10. White House Actions (No new items of interest.)

(Source: The White House)

11. Diaz: “This Week’s Recap of the Latest Customs and International Trade News”

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

Customs and Border Protection (CBP)

Administration

Court of International Trade (CIT)

Department of Commerce

United States Trade Representative (USTR)

Office of Foreign Asset Control (OFAC)

Department of State

Food and Drug Administration (FDA)

U.S. Department of Agriculture (USDA)

Congress

International

Industry News

12. Expeditors News: “CBP Publishes Guidance on Polysilicon Product Import Ban”

(Source: Expeditors News, 24 Sep 2026)

     In a Cargo Systems Messaging Service (CSMS) bulletin issued on September 23, 2026, U.S. Customs and Border Protection (CBP) published guidance on the upcoming import ban on certain polysilicon products.
     The temporary final rule for the import ban is detailed in a Federal Register Notice (FRN) published by the Bureau of Industry and Security (BIS) on September 24, 2026.
     Under the rule, BIS will monitor existing companies that import polysilicon or polysilicon derivatives in advance of future import adjustments on December 4, 2026. According to BIS, it will review imports for “evidence of stockpiling, limit a newly established importer’s ability to stockpile, and subject companies that are stockpiling to an import prohibition if necessary.”
     Importers that become subject to a polysilicon or polysilicon derivatives import prohibition may apply for a waiver of this restriction.
The CSMS is HERE. The temporary final rule is HERE.

13. Export Practitioner: “U.S. Readies Memory-Chip Tariffs Despite Cost Concerns”

(Source: The Export Practitioner, 25 Sep 2026) [Excerpts of paywall publication.]

     The Trump administration is preparing tariffs on imported memory chips to encourage domestic production, a move that could raise costs for U.S. technology companies and consumers during a global shortage, The Wall Street Journal reported.
     The duties would affect chips used in artificial-intelligence systems, data centers and consumer electronics. The United States relies heavily on Asian factories operated by Samsung Electronics, SK Hynix and Micron Technology. Industry executives expect supply constraints to persist for at least another year, according to the Journal.
     The report builds on POLITICO’s earlier reporting that the administration was considering broad semiconductor tariffs and relief tied to investments in U.S. manufacturing. Commerce Secretary Howard Lutnick later confirmed the general approach, telling CNBC: “If you build here, you don’t pay.”
     New U.S. capacity will take years to develop. SK Hynix’s planned Indiana facility—the country’s first high-bandwidth-memory packaging plant—is expected to open in 2028 and begin mass production in 2029, the Journal reported. It remains unclear whether that project or planned investments by Micron and Samsung would qualify for exemptions. … [Continue]

14. ST&R Trade Report: “AD/CVD News -- Fatty Acids, Rail Couplers, Tubular Goods, Welded Pipe, Wire Hangers”

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

     The International Trade Administration and/or International Trade Commission have recently announced the following actions in antidumping and/or countervailing duty cases. For more information on AD/CVD issues, including how to mitigate liability, please contact STR.
     Fatty acids – preliminary affirmative AD determinations on fatty acids from Indonesia and Malaysia, new AD cash deposit requirements at rates of 4.46 to 7.06 percent for Indonesia and 12.31 to 22.96 percent for Malaysia, and preliminary affirmative critical circumstances determination in part for Indonesia
     Rail couplers – final affirmative CVD determination on freight rail couplers and parts thereof from India, with net subsidy rates of 9.71 and 75.0 percent
     Tubular goods – dumping margins of 9.8 to 29.94 percent in final results of administrative review of AD order on oil country tubular goods from South Korea for the period Sept. 1, 2023, through Aug. 31, 2024
     Welded pipe – preliminary determination that Interpro Pipe & Steel Inc. is the successor-in-interest to Evraz Inc. NA Canada with respect to the AD order on large-diameter welded pipe from Canada
     Wire hangers – preliminary determination that imports of steel wire garment hangers completed in Cambodia using steel wire or steel wire and paper accessories produced in China or Vietnam are circumventing the AD order on hangers from China or the AD and CVD orders on hangers from Vietnam

15. ST&R Trade Report: “Ocean Transportation Intermediary License Revocations”

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

     The Federal Maritime Commission has given notice that the following ocean transportation intermediary licenses have been revoked. A revocation may occur after a license is surrendered voluntarily by the OTI or for failure to maintain a valid bond.

16. The Hill: “White House Says It’s Not Preparing to Ban Diesel Exports”

(Source: The Hill, 25 Sep 2026) [Excerpts]

     The White House on Wednesday denied a report that it is planning a 90-day ban on diesel exports as Americans struggle with high fuel prices. The report, from Politico, cites five people familiar with the discussions and says that the legal process for the export ban was still being worked out.
     In an unsigned statement to The Hill, the White House said, “This is not true.” The White House referred The Hill to Energy Secretary Chris Wright’s comments to The Wall Street Journal, which the secretary said that the administration would not halt all diesel exports and would instead take a voluntary approach to bringing prices down.
     The remarks follow comments from President Trump, a day earlier, in support of a ban. “I’ve said, ‘Let’s not send out the diesel.’ We make a lot of diesel,” Trump said at the United Nations General Assembly in New York. “I’ve called for it within my people. I’ve been talking about it.”
     At the same U.N. event, Treasury Secretary Scott Bessent said that the administration has been “examining” the possibility of a ban. … [Full article]

17. Burns, Clif: “Autumn in New York”

(Source: Export Law blog, 24 Sep 2026) [Excerpts]

* Author: Clif Burns, Clark Hill LLP

     It’s autumn in New York. Fall foliage is making its annual return, the chestnut roasters are appearing on the sidewalk, and Iranian government officials are showing up to attend the opening of the UN General Assembly (UNGA).
     The State Department’s Bureau of Arms Control and Nonproliferation fears that the Iranians will descend on wholesale clubs and Fifth Avenue boutiques and then return to Iran bearing swag bags stuffed with diamond tennis bracelets, Patek Philippe wrist watches, Waterford crystal whisky glasses and more. So it has issued a stern warning in the form of an “Advisory” to NYC-area merchants to be on the lookout for this prohibited shopping spree.
     Okay, for starters, we should be clear that the UN Headquarters Agreement does not prevent the State Department from restricting Iranian UNGA attendees from purchasing luxury items and joining wholesale clubs as it says it has done in this warning. The UN Headquarters Agreement, in Article 11, prohibits federal, state and local governments from doing anything that would “impose any impediments to transit to or from the headquarters district.”
     Certainly that prevents things like banning hotel stays by Iranian attendees to the UNGA, forcing them to pitch tents in Central Park instead, or preventing them from buying food or personal necessities while attending the UNGA. But banning luxury goods purchases and wholesale club memberships by Iranian attendees while in New York is not even close to an impediment. …
     Even if such a restriction is consistent with the Headquarters Agreement, it is not clear State has the statutory right under U.S. law to impose it. State cites section 204(b) of the Foreign Missions Act, 22 U.S.C. § 4304(b), as authority for these restrictions. That section permits State to regulate the receipt of a “benefit,” but the Act defines a benefit as an acquisition in the United States “by or for a foreign mission.”
     True, the Act’s definition of a foreign mission includes “personnel” of the mission. But that just raises another question: does an Iranian government official who travels temporarily to New York to attend UNGA thereby become “personnel” of Iran’s Permanent Mission to the UN? State’s Advisory apparently assumes so, but the answer is hardly obvious. And the problem becomes even more pronounced with the dependents of those officials, who are even harder to characterize as “personnel” of the mission. … [Continue]

18. Diaz: “BIS FY2025 Annual Report Signals Major Increase in Export Enforcement”

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

* Author: Jennifer Diaz, Diaz Trade Law LLP

     The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released its Fiscal Year 2025 Annual Report to Congress, providing a detailed look at the agency’s export control, licensing, and enforcement activity.
     Key Takeaways:

     BIS Reports an 18-Fold Increase in Penalties: … [Continue]

19. Masuda: U.S. Export Control Regulator Adopts 50% Rule

(Source: JDSupra, 25 Sep 2026) [Excerpts]

     Export controls are expanding beyond traditional military applications into commercial transactions, requiring businesses to implement new compliance measures. The US Bureau of Industry and Security has introduced a significant policy shift that will fundamentally change how companies screen customers and business partners. …
     However, the US Bureau of Industry and Security (BIS) within the US Commerce Department, the agency responsible for enforcing US dual-use controls over items with both commercial and military uses, has recently added a new layer of necessary checks for businesses’ compliance programs.
     The US Treasury’s Office of Foreign Assets Control (OFAC) has long employed a “50% rule” under which an entity is considered blocked under US embargo programs even if it is not on a US blacklist or technically an entity of the affected country, as long as a blocked entity owns or controls 50% of the un-blocked entity.
     Starting in November 2026, if a business has reason to know or suspect that its customer or potential customer is owned or controlled to any degree by a blacklisted person or entity, the business will need to obtain clarification on the exact percentage of ownership or control.
     Where it is confirmed that a blacklisted person or entity owns or controls 50% or more of a customer or potential customer, the business must halt any transfers or sales unless and until an export license is obtained from BIS.
     In other words, by the end of this year, it will not be enough to verify that new and existing customers are omitted from US export blacklists. Rather, businesses will need to have some idea of the ownership and control of their customers in order to avoid potential export control violations.

20. ST&R Trade Report: “Import and Export Restrictions Proposed on Hallucinogens”

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

     The Drug Enforcement Administration has proposed to place the following tryptamine hallucinogens, including their salts, isomers, and salts of isomers, in Schedule 1 of the Controlled Substances Act.

     This rule would impose the regulatory controls and administrative, civil, and criminal sanctions applicable to schedule I controlled substances on persons who handle (import, export, manufacture, distribute, reverse distribute, engage in research or conduct instructional activities or chemical analysis with, or possess) or propose to handle these substances.

21. Global Training Center Presents: "ITAR Compliance" Live Online Webinar 1 Oct (Thursday) Morning

(Source: [email protected])

What: International Traffic in Arms Regulations (ITAR) Compliance Training webinar

Where: On Your Computer

When: Thursday, 1 Oct, 9 am-12:30 pm (Central)

Summary: ITAR training is essential for manufacturers, exporters, and distributors of defense articles, related technical data, and defense services. Our expert-led course provides an understanding of ITAR fundamentals, its U.S. regulatory framework, and crucial compliance principles. DDTC’s ITAR Compliance Program (ICP) Guidelines identify Element 5: Training as a critical component of an effective ICP.

Presenter: Expert and Trade Attorney George W Thompson

Sponsor: Global Training Center

Register: HERE

22. Global Training Center Presents: "EAR Webinar" Live Online Training 2 Oct (Friday) Morning

(Source: Global Training Center)

What: Export Administration Regulations Course, "EAR Webinar"

When: Friday, 2 Oct, 9 am to 12:30 pm (Central)

Where: Virtual - on your computer.

Presenter: Trade Attorney George W Thompson, export expert.

Summary: The Export Administration Regulations (EAR) course provides attendees with key details of export controls. It covers the concepts and authorizations needed to comply with the EAR in global business operations. Training in export controls should be the first step—never an afterthought.

Register: HERE

23. List of Export/Import Job Openings

(Source: Editor)

RECENT:

FULL LIST (Includes above entries.):

25. Bartlett's Unfamiliar Quotations

(Source: Brainy Quotes)

26. Today in History

(Source: History Channel)

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

(Source: Editor)

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28. 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.