26-1020: Tuesday's "Export/Import Daily Bugle"

1. Today's Federal Register (No relevant items.)
(Source: Federal Register)

2. Future Federal Register
(Source: Future Federal Register)

3. CBP Cargo Systems Messages
(Source: DHS/CBP/CSMS)

4. CBP Reminder: Licensed Customs Brokers Must complete Continuing Education by 31 Jan 2027
(Source: CBP Continuing Education, 1 Oct 2026)

     “Dear Licensed Customs Broker: To maintain your license, you are required to complete 20 hours of Continuing Education (CE) no later than January 31, 2027. Don’t wait until the last minute. Failure to meet these requirements will result in the revocation of your customs broker’s license.
     If you have not yet done so, start your CE training today. Visit the Customs Broker Triennial Status Report (TSR) and Continuing Education (CE) Requirements | U.S. Customs and Border Protection and Customs Broker Continuing Education | U.S. Customs and Border Protection webpages.
     CE Requirements: Individual brokers are required to complete 20 hours of CE credits to maintain their license for the current triennial.

     TSR Requirements: Filing the TSR requires that individual brokers with an active license: certify CE compliance, provide CBP with current contact information, and pay the triennial fee.

     CBP recommends that brokers file their TSR as soon as their CE credits are complete. The deadline to complete the 20 hours of CE credits is January 31, 2027.”

5. CBP to Host UFLPA Webinar 28 Oct 2026
(Source: OTR Webinars)

6. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS)

7. State/DDTC (Nothing new.)
(Source: Defense Directorate of Trade Controls)

8. White House Actions (No relevant items.)
(Source: The White House)

9. Expeditors News: “EPA Issues Significant New Use Rules on 19 Chemicals”
(Source: Expeditors News, 20 Oct 2026) [Excerpts]

     In a Federal Register Notice (FRN) published on October 15, 2026, The Environmental Protection Agency (EPA) announced the issuance of significant new use rules (SNURs) under the Toxic Substances Control Act (TSCA) for 19 chemical substances.
     Under TSCA, SNURs will “require persons to notify EPA at least 90 days before commencing the manufacture (defined by statute to include import) or processing of any of these chemical substances for an activity that is designated as a significant new use.”
     This notification requirement allows EPA to evaluate potential risks associated with the new use before the activity begins. Manufacture (including import) or processing for a significant new use may not commence until EPA has conducted a review of the notification.
     SNURs were issued for the following chemicals: . . . [List]
     FRN 2026-21051 is HERE.

10. Inside Defense: “Pentagon Scales Back Midyear Reprogramming to $3.3B After Congressional Review”
(Source: Inside Defense, 20 Oct 2026) [Editor’s summary]

     The Defense Department’s final FY-2026 omnibus reprogramming action shifts about $3.3 billion across defense accounts, down from the $4.3 billion originally requested after Congress rejected some transfers and DOD scaled back others.
     The funding is largely redirected to cover higher-than-anticipated military personnel costs and National Guard training, including increases of $572.5 million for Army personnel and $701 million for the Army National Guard.
     To offset these costs, DOD reduced funding for numerous procurement, operations, and research programs. The Navy cut $612.2 million for its second T-AGOS surveillance ship due to construction delays, moving the funding into FY-2027, and reduced CVN-81 aircraft-carrier funding by about $164 million because of a two-year delivery delay.
     Additional Navy reductions affected DDG-1000 support equipment, while Congress blocked a proposed cut to LPD-class support equipment.
     The Air Force reduced aircraft procurement by $273.7 million, far less than originally proposed, after several planned cuts were deferred. Funding reductions tied to delayed F-35 depot-engineering work, KC-46 requirements, C-130 modernization, and other aircraft programs shifted needs into FY-2027. Congress also rejected a proposed cut to National Security Space Launch funding.
     The Army accounted for roughly $1.2 billion in reductions, including $745.9 million in operations and maintenance savings from deferred projects. Additional cuts affected Stinger missile modifications, command-post infrastructure, air-defense programs, surveillance systems, and Chinook helicopter upgrades, while Congress blocked reductions to several missile-procurement programs.
     The Space Force also reduced research funding because of contract terminations, delayed awards, and schedule changes.
     . . . [Full article]

11. ST&R Trade Report: “President Delays New Russia-Related Tariffs”
(Source: Sandler, Travis & Rosenberg Trade Report, 20 Oct 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     President Trump has issued an executive order waiving new tariffs required under a recent law targeted at Russia and countries that provide it with certain support.
     The law requires the president to (1) increase tariff rates on virtually all imports from Russia to as much as 500 percent and (2) impose up to 100 percent tariffs on goods imported from:
     (a) countries that knowingly make new purchases of Russian oil or gas on or after the date that is 30 days after the bill’s enactment,
     (b) the world’s top five purchasers of Russian oil or gas (with an exception for countries importing less than 15 percent of Russia’s oil and gas exports and taking significant steps to reduce those imports), or
     (c) the top five facilitators of Russian oil sanctions evasion.
     These tariffs would stack on top of applicable antidumping and countervailing duties as well as Section 122, 201, 232, or 301 tariffs.
     The law requires the tariffs to be imposed within 30 days but allows the president to waive them if doing so is deemed to be in the national interest. . . . [Full article]

12. ST&R Trade Report: “AD/CVD News: End Blocks, Nails, Pasta, Trailers, Wood Moldings”
(Source: Sandler, Travis & Rosenberg Trade Report, 20 Oct 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. . . .
     End blocks – dumping margin of 7.55 percent (up from 2.97 percent) in amended final results of administrative review of forged steel fluid end blocks from Italy for the period July 23, 2020, through Dec. 31, 2021
     Nails – dumping margins of zero and 9.1 percent in preliminary results of administrative review of AD order on steel nails from Oman for the period July 1, 2024, through June 30, 2025
     Pasta – dumping margins of 3.62 to 6.47 percent in preliminary results of administrative review of AD order on pasta from Italy for the period July 1, 2024, through June 30, 2025
     Trailers – final affirmative AD and CVD injury determinations on van-type trailers and subassemblies from China
     Wood moldings – (1) assignment of cash deposit rate of 8.89 percent to two companies in amended final results of administrative review of AD order on wood moldings and millwork products from China for the period June 12, 2020, through Dec. 31, 2021, and (2) assignment of cash deposit rate of 220.87 percent to one company in amended final results of administrative review of this order for the period Aug. 12, 2020, through Jan. 31, 2022. [Full article]

13. WTTL: “Pentagon Reports Research Security Audits at 30 Universities as MI5 Warns of Chinese Funding Links”
(Source: Washington Tariff & Trade Letter, 19 Oct 2026) [Editor’s summary of subscription publication.]

     The Pentagon announced October 19 that all 30 universities reviewed under its initial research-security audits had mitigated relationships with foreign entities of concern on the July 2026 Section 1286 list.
     The audits resulted in more than 80 termination-related actions, including some precautionary terminations involving entities not on the list. The announcement reports corrective action but does not provide project-level details or findings of research theft. Because some actions were precautionary, the figure should not be interpreted as more than 80 confirmed violations.
     The Defense Department highlighted Oklahoma State, Penn State, UNC-Chapel Hill, South Carolina, USC, Texas-Austin, and Virginia Tech for prompt compliance and additional safeguards. It also indicated that Section 1286 reviews and updates will continue.
     The findings strengthen Rep. John Moolenaar’s (R-MI) push for the Securing Innovation and Research from Adversaries Act (SIRA), which would bar federally funded research collaborations with entities or individuals linked to specified U.S. restricted lists.
     The proposal would cover co-authorship, data sharing, joint laboratories, visiting scholars, and researcher supervision, while allowing limited waivers for national security, scientific, or public-health purposes. SIRA remains a proposal and is separate from existing NSF disclosure requirements concerning foreign affiliations, appointments, and funding.
     A parallel MI5 warning highlighted risks from indirect sponsorship, identifying China General Technology Research Institute funding of research linked to Chinese intelligence interests. Both developments underscore the importance of robust screening, transparency, and documentation of foreign relationships.
     Universities continue to balance research-security obligations against concerns over academic collaboration, talent recruitment, and potential discriminatory enforcement.

14. ArentFox: “Commerce Defines ‘U.S. Content’ for USMCA-Qualifying Mobile Industrial Equipment and Certain Parts”
(Source: ArentFox Perspectives/Alerts, 20 Oct 2026) [Excerpts]

• Principal Author: James Kim, ArentFox Schiff LLP

     The US Department of Commerce’s Bureau of Industry and Security (BIS) has issued guidance to US Customs and Border Protection (CBP) on how to assess “U.S. content” in certain products of Canada and Mexico.
     The notice was published in the Federal Register on October 14. It implements clause (2)(d) of Presidential Proclamation 11032 of June 1. That proclamation modified and consolidated the metals tariff regimes established under Proclamations 9704, 9705, and 10962, as amended.
     The newly released guidance matters most to importers of United States-Mexico-Canada Agreement (USMCA)-qualifying Canadian and Mexican goods covered by clause (2) of Proclamation 11032, which covers mobile industrial equipment such as forklifts and their parts; graders, levelers, shovel-loaders, backhoes, bulldozers, similar machinery, and their parts; tractors, mobile cranes, and mobile drilling derricks. . . . [Full article]

15. Diaz: “IEEPA Refund Class Certified: Why Importers With Significant Phase 3 Refunds Should Still File Their Own Suit”
(Source: Customs & International Trade Law Blog, 20 Oct 2026) [Editor’s summary]

• Author: Jennifer Diaz, Diaz Trade Law LLP

     On October 8, 2026, the U.S. Court of International Trade (CIT) certified a nationwide class of importers that paid IEEPA duties between February 1, 2025, and February 19, 2026, excluding companies that have already filed their own refund lawsuits. The certification potentially covers thousands of importers but does not itself authorize refunds or require CBP to reliquidate entries.
     The ruling is significant because CBP opened CAPE Phase 3 on October 6, 2026, allowing refunds on finally liquidated entries for importers that filed individual CIT cases and obtained court orders directing reliquidation. Importers relying solely on membership in the class action do not currently have access to Phase 3.
     The class case also faces additional litigation risk. The government has already appealed earlier IEEPA refund rulings, and many observers expect an appeal of the class-certification order as well. As a result, obtaining refunds through the class process could take months or even years.
     For importers, the key question is the amount of money at stake. Companies with significant IEEPA duties on finally liquidated entries may benefit from filing their own CIT actions to seek quicker access to refunds and CAPE Phase 3 processing. Those with relatively small refund claims may find it more cost-effective to remain in the class action and monitor developments.
     In the near term, importers should review their ACE data, determine the amount of IEEPA duties paid on finally liquidated entries, pursue any available CAPE claims, and evaluate whether an individual CIT lawsuit is warranted.

16. Friling: “ITAR Reform in 2026: Proposed USML Changes for Defense Suppliers”
(Source: JDSupra, 20 Oct 2026) [Editor’s summary]

• Author: Diana Friling, Friling Law

     A pending State Department proposal published October 1, 2026, would revise selected U.S. Munitions List (USML) controls, add two new exclusions to the ITAR definition of “specially designed,” and create a conditional exemption for certain temporary exports of foreign defense articles. . . .
     The proposal, issued in response to Executive Order 14268, would remove some smooth-bore canister launchers and most radar altimeters from the USML, revise controls on ocular protection and submersible equipment, and designate certain naval nuclear-propulsion items as Significant Military Equipment (SME). Because SME status can trigger DSP-83 certification requirements, companies would need to consider both classification and resulting documentation obligations.
     A central issue is how the proposed ITAR exclusions would apply. One exclusion would focus on an item’s development history, requiring companies to document when and how a product was developed and whether later versions retain the same or equivalent form, fit, and function.
     Another exclusion would cover certain basic commodities, such as brackets and passenger seats, but only under limited conditions. Even if an item qualifies for an ITAR exclusion, a separate analysis may still be required under the EAR.
     The proposal highlights the continuing importance of accurate USML classification, engineering records, development histories, and technical documentation. Where jurisdiction remains uncertain, companies may seek a formal determination through DDTC’s commodity-jurisdiction process.
     The proposed repair exemption would simplify some transactions, but technical data, defense services, import requirements, and other ITAR obligations would still require separate review. . . . [Full article]

17. Pillsbury: “Three Russia Export Cases Put End-User Diligence in the Spotlight”
(Source: Global Trade Blog, 20 Oct 2026) [Editor’s summary]

• Principal Author: Stephan E. Becker, Benjamin J. Cote, Evan Turgeon, Pillsbury Winthrop Shaw Pittman LLP

     Three recent DOJ export-enforcement cases illustrate a key compliance lesson: diversion risk cannot be assessed solely by screening the named customer or destination. Since Russia’s 2022 invasion of Ukraine, illicit procurement networks have increasingly used third-country buyers, consignees, and transshipment routes to conceal Russian end users from U.S. suppliers.
     The cases do not suggest knowing participation by the U.S. companies involved. Rather, they show how legitimate firms can be deceived by intermediaries acting on behalf of sanctioned parties, foreign governments, or prohibited end users.
     Effective compliance requires looking beyond restricted-party screening to evaluate whether the customer, product, payment source, end use, and shipping route make commercial sense as a whole. These lessons apply not only to Russia, but also to controls targeting China, Iran, North Korea, and other high-risk jurisdictions.
     The three cases involved:

     Key compliance takeaways include risk-based know-your-customer procedures, verification of beneficial ownership and end users, independent destination checks, continuous screening against OFAC and Commerce lists, reassessment of existing customers as risks evolve, and heightened scrutiny of unusual routing, payment, or secrecy requests.
     As enforcement pressure increases, these measures should complement, not replace, core EAR, ITAR, and sanctions compliance programs. . . . [Full article]

18. Troutman: “Forty Percent or Bust: Commerce Defines ‘US Content’ for USMCA Metals-Derivative Equipment, and the Definition Matters Less Than the Cap”
(Source: Troutman Pepper Locke, 20 Oct 2026) [Excerpts]

• Author: Ryan Last, Troutman Pepper Locke LLP

Key Points

     [Full article]

19. Volkov: “Does Your Compliance Data Prove Your Program Works?”
(Source: Volkov Law, 20 Oct 2026) [Excerpts]

• Principal Author: Michael Volkov, Volkov Law Group LLC

     Compliance used to count training completions. Today, regulators want proof your program actually works. That shift didn’t happen by accident. Twenty years ago, compliance data meant hotline calls and a training checklist. The numbers were easy to collect and nearly impossible to interpret.
     A quiet hotline could mean a great culture or a terrified workforce.
     Then regulators started asking harder questions: Do you track your own data, and do you use it?
     Privacy laws demanded real-time visibility into how personal data moves. Cyber threats made annual reviews look dangerously slow, so compliance built continuous monitoring, integrated dashboards, and risk indicators that warn you before a problem arrives.
     Now comes AI, which can spot patterns no human-written rule would catch and compress the time from detection to action from months to hours.
     And here’s the twist: AI is also the newest risk compliance has to monitor. But AI is only as good as the data discipline underneath it.
     If you never built integrated systems, clean data, and a habit of using metrics to change behavior, AI will simply automate your blind spots.
     Build the foundation first. The tools will follow. . . . [Full article and podcast link.]

20. FD Associates Presents: “Brokering Under the ITAR” Webinar, 3 Nov 2026
(Source: Jenny Hahn, [email protected])

21. Global Training Center Presents: “ITAR for Empowered Officials” 9 Nov 2026
(Source: Global Training Center)

22. List of Export/Import Job Openings
(Source: Editor)

RECENT:

FULL LIST (Includes above entries.):

23. Changes Coming to the Daily Bugle
(Source: Editor)

     For 25 years, I've published The Import/Export Daily Bugle as a free newsletter, but publishing expenses leave me with a tough choice: either start charging for subscriptions or stop publishing.
     I would hate to see the Daily Bugle end. Starting today, new subscribers will receive a free 14-day trial. After the trial, subscriptions will cost $10 per month or a discounted annual rate of $100. Current subscribers have until November 2^nd to resubscribe HERE. After November 2^nd, current subscribers who have not resubscribed will no longer receive the Bugle.
     The Daily Bugle has always been a labor of love, and I hope it has been useful to you over the years. If enough readers subscribe to cover costs—with, I hope, a little left over—the Bugle can continue for many years to come.
     Sincerely — Jim Bartlett

25. Bartlett's Unfamiliar Quotations
(Source: Brainy Quotes)

26. Today in History
(Source: History Channel)

     1803: On October 20, 1803, the U.S. Senate approved the treaty purchasing Louisiana from France for $15 million, doubling the size of the United States. The vast territory had been transferred from Spain back to France in 1801, raising concerns that Napoleon Bonaparte might block American access to the Mississippi River and the port of New Orleans.
     President Thomas Jefferson sent James Monroe and Robert Livingston to negotiate the purchase of New Orleans, but Napoleon, needing funds for war with Great Britain and unable to secure a North American empire, unexpectedly offered the entire Louisiana Territory. Recognizing the opportunity, the American negotiators accepted.
     Although Jefferson questioned whether the Constitution authorized such an acquisition, he submitted the treaty to the Senate, which ratified it. The Louisiana Purchase became one of the most important land acquisitions in U.S. history and is widely regarded as Jefferson’s greatest presidential achievement.

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.