26-1022: Thursday's "Export/Import Daily Bugle"

1. CBP Extends Compliance Date of De Minimis Exemption for Postal Imports
(Source: 91 FR 66638, 22 Oct 2026)

2. CBP Modifies Test of Electronic Informal Entry via Postal Imports
(Source: 91 FR 66707, 22 Oct 2026)

3. Future Federal Register (No relevant items.)
(Source: Future Federal Register)

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

5. 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) by 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 individual brokers with an active license to 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.

6. CBP to Hold UFLPA Enforcement Statistics Dashboard Webinar 28 Oct 2026
(Source: OTR Webinars)

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

8. Commerce/USCS to Host “Singapore Autonomous Applications for Maritime Security” Webinar 18 Nov 2026
(Source: USCS, Aerospace & Defense, 21 Oct 2026)

9. DSCA Posts Procedures for Repair of Defense Articles Using Ukraine Security Assistance Initiative Authorities
(Source: Defense Security Cooperation Agency, 22 Oct 2026)

     DSCA posts Policy Memo 26-40 Accountability Procedures for Defense Articles Being Refurbished or Repaired Using Ukraine Security Assistance Initiative Authorities.
     This policy memorandum establishes accountability procedures concerning Ukrainian titled defense articles being refurbished or repaired using Ukraine Security Assistance Initiative (USAI) Authorities, and for USAI funded defense articles being used in such refurbishment or repair.
     This policy memorandum is in response to issues discovered in the DoDIG-2025-152 “Evaluation of DoD Processes to Provide Repair Parts to Support Ukrainian Armed Forces.” This memo adds:

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

11. Treasury/OFAC (Nothing new.)
(Source: Treasury/OFAC)

12. US Trade Representative Announces 2026 Award Recipients
(Source: USTR.gov, 21 Oct 2026)

     Today, the Office of the United States Trade Representative (USTR) hosted its annual awards ceremony, celebrating the achievements and notable milestones of its staff.
     During the program, award recipients were announced in the following categories: Ambassador’s Award, William B. Kelly Award, Linda Enoch Award, Excellence in Service Award, Erland Herfindahl Award, Superior Achievement Award, Distinguished Career Service Award, Team Award, Way to Go Award, and Length of Service Award.
     [Names of award winners HERE.]

13. White House Adjusts Imports of Wind Turbines and Parts
(Source: The White House, 22 Oct 2026) [Editor’s Summary]

     Following a Section 232 investigation, the Commerce Secretary concluded that imports of wind turbines and their components threaten U.S. national security. The report cited reliance on foreign-made components, cybersecurity vulnerabilities that could permit remote access to power systems, interference with military and civilian radar, grid reliability concerns due to intermittent wind generation, and growing dependence on imported equipment.
     President Trump concurred with these findings and directed the Commerce Secretary and U.S. Trade Representative to negotiate with foreign trading partners to address the threat.
     Existing Section 232 tariffs on steel, aluminum, and copper remain unchanged, while further import restrictions could be considered.

14. Breaking Defense: “Air Force Needs 1,509 Combat-Ready Jets by 2035, Service Tells Congress”
(Source: Breaking Defense News, 21 Oct 2026) [Editor’s Summary]

     The U.S. Air Force’s 2026 fighter force report projects it will need 1,509 combat-ready fighter aircraft by 2035 to sustain a moderate-risk operational posture, and 1,723 fighters for a low-risk posture.
     The moderate-risk figure is considered the more realistic planning target, as Air Force leaders say they generally do not plan for a low-risk environment.
     The updated analysis also argues for changes in how combat-ready aircraft are counted, drawing on lessons from recent operations against Iran. However, achieving these force levels will depend heavily on congressional funding.
     Air Force leaders warn that budget constraints, competing modernization priorities, and congressional resistance to retiring older aircraft could make it difficult to procure enough new fighters, including planned purchases of F-35s and F-15EXs. . . . [Full article]

15. Digitalshield: “ITAR: The US Veto Shaping Military Sovereignty in Spain and Morocco”
(Source: Digitalshield News, 22 Oct 2026) [Editor’s Summary]

     The U.S. International Traffic in Arms Regulations (ITAR) give Washington significant influence over the use, transfer, and support of U.S.-origin military technology worldwide.
     Because Morocco's recent military modernization relies heavily on American systems such as F‑16 fighters, Apache helicopters, Abrams tanks, and HIMARS launchers, its armed forces depend on continued access to U.S. spare parts, software, technical data, and support. A strict U.S. embargo could severely degrade the effectiveness of many of these systems.
     Spain also operates some U.S.-origin equipment but has increasingly pursued technological sovereignty through European and domestic programs such as the Eurofighter, F‑110 frigate, and Dragón armored vehicle. This strategy reduces exposure to foreign export controls and provides greater operational independence.
     In a hypothetical Spain-Morocco conflict, a comprehensive U.S. cutoff would likely affect both countries, but Morocco could face greater disruption because of its heavier reliance on American military technology. Spain would retain substantial capabilities through European and national defense programs, while Morocco would continue to field some French, Israeli, Chinese, and other non-U.S. systems. . . . [Full article]

16. Expeditors News: “Section 338 Tariffs on Canadian Goods Challenged in Court”
(Source: Expeditors News, 21 Oct 2026) [Editor’s Summary]

     On October 20, 2026, importer Gellert Global Group Corp. filed a complaint with the U.S. Court of International Trade (CIT) challenging Section 338 tariffs imposed on Canadian Goods on August 22, 2026.
     In Gellert Global Group Corp. v. Trump, CIT No. 26-04636, the plaintiff asserts that “Section 338 has been impliedly repealed or, at a minimum, is controlled by Section 301” and that the tariffs did not satisfy the requirements outlined within 19 U.S.C. § 1338(a) for determining whether the “United States at a disadvantage compared with the commerce of any foreign country.”
     The plaintiff also requested that the case proceed as a class action. Gellert Global Group Corp. v. Trump, CIT No. 26-04636 Complaint with the CIT is HERE.

17. ST&R Trade Report: “CBP Modifies Test of Informal Entry for Mail Shipments”
(Source: Sandler, Travis & Rosenberg Trade Report, 22 Oct 2026). Contact: [email protected], 1-305-894-1035

     Effective Oct. 22, U.S. Customs and Border Protection is modifying its test of a new electronic informal entry type for merchandise entering the U.S. through the international mail process to permit transmission of the entry with or without electronic partner government agency data.
     On Sept. 22 CBP began a test of entry type 13, a new electronic informal entry process for shipments valued at $2,500 or less, including those that would previously have been eligible for the de minimis duty exemption, that are sent to the U.S. through the international postal network. This test creates an informal entry pathway for low-value international mail shipments subject to PGA data requirements or duties other than those set forth in HTSUS Chapters 1-97 (which are ineligible for the interim process for informal mail entries).
     CBP states that test participants with shipments subject to PGA data requirements may transmit PGA data electronically in ACE with their entry type 13 filing. However, CBP is modifying the test to also temporarily accept transmission of an entry type 13 that is not accompanied by complete electronic PGA data. CBP states that this will allow filers to begin using entry type 13 while they work to ensure that they can electronically submit all of the data required for complete PGA submissions.

18. Baker McKenzie: “OFAC Designates the International Criminal Court and Issues Four Related General Licenses”
(Source: Global Sanctions and Export Controls Blog, 21 Oct 2026) [Editor’s Summary]
• Principal Author: Alison J. Stafford Powell, Baker McKenzie

     On October 9, 2026, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added the International Criminal Court (ICC) to the Specially Designated Nationals and Blocked Persons (SDN) List under Executive Order 14203.
     The action follows earlier sanctions on 17 ICC-affiliated individuals and was described by the U.S. government as necessary to defend U.S. sovereignty and address perceived threats posed by the ICC.
     As a result, all ICC property and interests in property subject to U.S. jurisdiction are blocked. U.S. persons are generally prohibited from engaging in transactions involving the ICC, including the provision or receipt of funds, goods, or services.
     OFAC simultaneously issued four general licenses:

     The European Union criticized the sanctions and urged the United States to reverse them, while indicating it may take measures to ensure the ICC can continue operating effectively. Companies subject to both U.S. and EU jurisdiction should monitor potential EU responses.
     . . . [Full article]

19. Burns, Clif: “The Death of an ITAR Amendment”
(Source: Export Law blog, 22 Oct 2026) [Editor’s Summary]
• Author: Clif Burns, Clark Hill LLP

     For more than fifteen years, the State Department has acknowledged that the ITAR definition of “defense services” may be overly broad. Since 2011, DDTC has proposed four different revisions to the definition, but none has ever been finalized. After years of delays, deferrals, and silence following a fourth proposal in 2024, DDTC issued a new proposal on October 1, 2026.
     The latest change does not narrow the definition. Instead, it adds eight words to § 120.32 stating that a defense service means, “except as noted in § 120.35 of this subchapter.” The problem is that § 120.35 describes excluded commodities and information, not services, making the exception unclear and potentially meaningless.
     If DDTC intends to exclude the furnishing of certain unclassified information from the definition of a defense service, the new language may nevertheless create uncertainty.
     In particular, § 120.35(b)(2) excludes only information that does not convey “requirements or specifications,” raising questions about whether even basic factual details concerning defense articles could require authorization when disclosed to foreign persons.
     Rather than narrowing ITAR controls, the proposal arguably expands them, suggesting that hopes for a more limited definition of “defense services” have effectively disappeared. . . . [Full article]

20. ECCN Finder: “2026 BIS Export Enforcement Cases & Compliance Lessons”
(Source: ECCNFinder.com, 22 Oct 2026) [Editor’s Summary]

     In 2026, the Bureau of Industry and Security (BIS) imposed more than $290 million in civil penalties against major companies including:

     The cases highlight four major compliance lessons:

21. Legal Desire Press: “FCPA Explained: Rules, Penalties and 2026 Enforcement”
(Source: Legal Desire Press, 22 Oct 2026) [Editor’s Summary]

     Key takeaways:

     FCPA explained: . . . [Full article]

22. ST&R Trade Report: “USDA to Play Role in Preferential Tariff Treatment for Apparel Imports”
(Source: Sandler, Travis & Rosenberg Trade Report, 22 Oct 2026) [Editor’s Summary]. Contact: [email protected], 1-305-894-1035

     The Department of Agriculture announced in May the Great American Cotton Plan, a comprehensive initiative that among other things seeks to improve cotton trade by (1) implementing a three-point trade plan to expand export opportunities for U.S. cotton, (2) secured commitments from Indonesia and Bangladesh that will support future U.S. cotton purchases and textile production using U.S. cotton, and (3) continued USDA support of cotton exports through the Market Access Program and COTTON USA™ licensing initiatives. . . .
     USDA has now announced that its Foreign Agricultural Service is designing a mechanism that will incentivize purchases of U.S. cotton that will launch in 2027.
     Specifically, FAS will play a key role in verifying purchases of U.S. cotton by select countries (Bangladesh, Indonesia, Cambodia, and Malaysia) in exchange for preferential tariff treatment on imports of apparel produced using U.S. cotton and textile inputs. [Full article]

23. Volkov: “Is Your Sanctions Program Out of Date?”
(Source: Volkov Law, 22 Oct 2026)
• Principal Author: Michael Volkov, Volkov Law Group LLC

     If your sanctions program is still the 2019 version, it’s missing the last seven years of enforcement. OFAC’s 2019 framework is still your foundation: management commitment, risk assessment, internal controls, testing, and training.
     But DOJ, Commerce, and Treasury have layered new expectations on top of that through joint Tri-Seal Notes.
     Four of them should be on your list today.
     One, U.S. nexus now reaches foreign companies that touch U.S. clearing, U.S. servers, or U.S.-origin components, and parent companies answer for their foreign subsidiaries. Centralize your program.
     Two, voluntary self-disclosure under BIS rules. Staying silent about a significant violation is now an aggravating factor. Silence is no longer neutral.
     Three, know your cargo. Watch transshipment through hubs like Hong Kong, Turkey, and the UAE, last-minute shipping changes, and shell companies. And fold export controls into your sanctions risk assessment rather than running them as separate work streams.
     Four, OFAC’s statute of limitations is now 10 years, not five. If your records retention stops at five, your program has a gap.
     Don’t replace the 2019 framework. Build on it. [Full article]

24. Skill Dynamics Presents: “Jurisdiction, Classification, & Confidence” Webinar 5 Nov 2026
(Source: Skill Dynamics -- previously Content Enablers)

25. FD Associates Presents “U.S. Canada Joint Certification Program” Webinar, 10 Nov 2026
(Source: Sarah Huffman, [email protected])

26. Partnering for Compliance™ Presents: “12th Annual Customs/Import Boot Camp Conference,” 21 Jan 2027
(Source: Ailish M. Nic Phaidin)

     [Registrations for our 16-18 March 2027 (in-person/Orlando and virtual) Partnering for Compliance™ conference are also open.]

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

RECENT:

FULL LIST (Includes above entries.):

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

30. Today in History
(Source: History Channel)

     1797: First parachute jump is made over Paris. The first parachute jump of note is made by André-Jacques Garnerin from a hydrogen balloon 3,200 feet above Paris on October 22, 1797.

     1962: JFK’s address on Cuban Missile Crisis shocks the nation. In a televised speech of extraordinary gravity, President John F. Kennedy announces on October 22, 1962, that U.S. spy planes have discovered Soviet missile bases in Cuba. Kennedy announced that he was ordering a naval quarantine of Cuba to prevent Soviet ships from transporting any more offensive weapons to the island and explained that the United States would not tolerate the existence of the missile sites currently in place. At the direction of the Joint Chiefs of Staff, U.S. military forces went to DEFCON 2, the highest military alert ever reached in the postwar era. On October 28, Khrushchev announced his government’s intent to dismantle and remove all offensive Soviet weapons in Cuba. In the afternoon, Soviet technicians began dismantling the missile sites, and the world stepped back from the brink of nuclear war. The Cuban Missile Crisis was effectively over.

31. Do You Need to Update Your Daily Bugle Profile?
(Source: Editor)

     Don't miss an issue of the Daily Bugle if you change your email. Click here to manage your profile.

32. 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.