26-1103: Tuesday's "Export/Import Daily Bugle"

1. Today’s Federal Register (No relevant items.)
(Source: Federal Register, 3 Nov 2026)

2. Future Federal Register (Four items.)
(Source: Future Federal Register, 3 Nov 2026)

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)

     To maintain your Customs Broker license, you must complete 20 hours of Continuing Education (CE) by January 31, 2027. Failure to meet these requirements will result in the revocation of your Customs Broker’s license.
     Visit the “Customs Broker Triennial Status Report (TSR) and Continuing Education (CE) Requirements” HERE, and “Customs Broker Continuing Education” HERE.
     CE Requirements: Individual brokers must complete 20 hours of CE credits to maintain their license for the current triennial.
     Brokers should file their TSR as soon as their CE credits are complete. The deadline is January 31, 2027.

5. CBP Proposes Updates to Low-Value Shipment Entry Requirements
(Source: CBP Gov Trade, 3 Nov 2026) [Excerpts]

     Per Executive Order 14411, CBP published a Notice of Proposed Rulemaking (NPRM) that proposes to amend the CBP regulations to require bonds for all informal entries.
     This is but one of the changes proposed in the NPRM, which is broadly intended to modernize low-value shipment processing.
     The NPRM seeks to improve data availability and filing timeliness to protect the revenue and enhance national security across all modes of transportation, and it includes a new electronic entry type for international mail shipments.
     Submit comments during the 60-day comment period ending December 7, 2026.

6. Commerce/BIS (Nothing new.)
(Source: Commerce/BIS, 3 Nov 2026)

7. State/DDTC DECCS System Will be Out 5 Nov 2026
(Source: Directorate of Defense Trade Controls)

     The Defense Export Control and Compliance System (DECCS) will undergo system maintenance on Thursday, November 5th, 2026, from 5:00 to 7:00pm (ET). Industry users may experience service degradation, interruptions, or limited application functionality within DECCS during this maintenance window.

8. US Trade Representative: “United States and Mexico Announce Memorandum of Understanding at Industrias Tecnos Facility”
(Source: USTR.gov, 2 Nov 2026) [Editor’s summary]

     A memorandum of understanding between the United States and Mexico establishes corrective measures at the Industrias Tecnos facility in Morelos, Mexico, following allegations that workers’ freedom of association and collective bargaining rights were violated.
     The agreement requires the company to compensate unlawfully dismissed workers, implement and train employees on labor-rights neutrality policies, establish confidential complaint mechanisms, and make labor-rights information readily available.
     Mexico will verify worker remedies, monitor compliance, provide worker and management training, and maintain anonymous reporting channels for labor-rights violations. Both governments agreed to complete all corrective actions by October 15, 2026.
     The case originated from a 2024 labor complaint under the USMCA Rapid Response Labor Mechanism. [Full statement]

9. White House Actions (No relevant items.)
(Source: The White House, 3 Nov 2026)

10. Breaking Defense: “SOCOM Taps Aeon for Limited Run of Shoulder-Fired Zeus with $13.8M Deal”
(Source: Breaking Defense News, 3 Nov 2026) [Editor’s summary]

     SOCOM has awarded Aeon Industrial a $13.8 million contract to produce fewer than 100 shoulder-fired Zeus missile systems for delivery over the next year.
     Designed for urban and confined environments, the 20-pound weapon is intended as a lower-cost precision alternative to legacy guided systems such as Javelin.
     Zeus features a modular design that allows operators to swap warheads and seekers in the field and launch the system from the shoulder, vehicles, surface vessels, or drones.
     Aeon says the weapon has undergone extensive testing with Army and Defense Department partners and is being adapted for counter-drone and unmanned-surface-vessel missions.

11. Expeditors News: “CBP Publishes Guidance on Modified Section 338 Duties”
(Source: Expeditors News, 2 Nov 2026) [Editor’s Summary]

     CBP has issued guidance implementing modified Section 338 duties on certain Canadian products following the October 23, 2026, Presidential Proclamation on Canadian trade measures affecting U.S. motor vehicles. The October 29 CSMS bulletin provides entry-filing instructions, identifies HTSUS classifications removed from the 50% additional duty under HTSUS 9903.03.14, and adds 100 classifications to that provision.
     CBP also confirmed that duties imposed under HTSUS 9903.03.12 through 9903.03.14 are eligible for drawback. Goods subject to the proclamation that enter a Foreign Trade Zone generally must be admitted in privileged foreign status and remain subject to the Section 338 duties upon entry for consumption.
     The modified duties apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. ET on October 30, 2026.
     CSMS #70314289 can be found HERE. The “Further Modifying the Scope of Products of Canada Subject to the Additional Duties Imposed to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Motor Vehicles” Presidential Proclamation can be found HERE.

12. ST&R Trade Report: “Import Alerts: Laser Products, Soap Bags, Toothpaste, Milk, Tomatoes”
(Source: Sandler, Travis & Rosenberg Trade Report, 3 Nov 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     Food and Drug Administration import alerts affecting the following have been newly issued or modified in the past week.

-- baked beans from South Africa
-- dried mango from Vietnam
-- dried mint from Türkiye
-- drug products from India
-- husk tomatoes from Mexico
-- laurel soap bag with loofah from Syria
-- material processing laser products from China
-- mussels from Italy
-- tamarind paste from Thailand
-- toothpastes from India
-- ultra-high temperature milk from Vietnam

     Import alerts inform FDA field staff that the agency has enough evidence or other information to allow a product that appears to be in violation of FDA laws and regulations to be detained without physical examination at the time of entry. Import alerts may cover products from designated countries or areas (including from all foreign countries), manufacturers, or shippers.
     Firms and/or products on the “red list” of an import alert are subject to DWPE, while firms and/or products on the “green list” are not because they have met the criteria for exclusion. Some import alerts include a “yellow list” of firms, products, and/or countries subject to intensified surveillance because the nature of the violations may warrant further field examinations of individual entries and/or additional analyses.
     . . . [Full article]

13. Baker McKenzie: “OFAC Adds Iran’s Automotive and Rail Sectors Under EO 13902, Amends FAQ 831, and Designates the A7 Network as a Transnational Criminal Organization”
(Source: Global Sanctions and Export Controls Blog, 3 Nov 2026) [Editor’s Summary]
• Principal Author: Paul Amberg (Spain), Baker McKenzie

     On October 1, 2026, the U.S. Treasury's OFAC expanded Executive Order 13902 sanctions to Iran's automotive and rail sectors, while designating 28 entities and two individuals linked to Iran-related activities.
     OFAC also broadened FAQ 831's definition of Iran's financial sector, increasing sanctions risk for non-Iranian banks, payment providers, exchange houses, and other firms providing financial services involving Iran.
     Separately, OFAC designated the Russia-linked A7 Network as a significant transnational criminal organization, describing it as a sanctions-evasion and shadow-banking network used by Iran, including the IRGC.
     FinCEN proposed a rule prohibiting U.S. financial institutions from processing fund transfers involving A7-controlled "Sub-Agents," including cryptocurrency transactions, and issued an alert outlining red flags for detecting A7-related sanctions evasion and money laundering. . . . [Full article]

14. Morrison Foerster: DOJ National Security Division Issues First “Near-Miss” Non-Prosecution Agreement Under Revised Corporate Enforcement Policy
(Source: Morrison Foerster LLP Client Alert, 02 Nov 2026)
• Principal Author: Brandon Van Grack, Morrison Foerster LLP

     On October 27, 2026, the Department of Justice (“DOJ”)’s National Security Division (“NSD”) and the U.S. Attorney’s Office for the Eastern District of North Carolina announced that they had entered into a non-prosecution agreement (“NPA”) with Extreme Networks, Inc. (“Extreme Networks” or the “Company”) to resolve an investigation into sanctions and export control violations involving sales of networking equipment and services to a Russian weapons manufacturer owned by a sanctioned entity. Under the NPA, Extreme Networks agreed to pay approximately $975,722, consisting of a $487,860.92 criminal fine and an equal amount in forfeiture.
     The resolution marks DOJ’s first “near-miss” NPA under the revised department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), issued in March 2026, and follows NSD’s June 2026 declination involving Robert Bosch GmbH (“Bosch”).
     Although Extreme Networks did not qualify for a declination because its disclosure occurred in anticipation of imminent press coverage, DOJ credited the Company’s earlier good-faith investigative efforts, full cooperation, and remediation in resolving the matter through an NPA. [Full article]

15. Steptoe: “US Resolves Extreme Networks Case Over Exports to Blocked Russian Defense Manufacturer”
(Source: International Compliance Blog, 3 Nov 2026) [Editor’s Summary]
• Principal Author: Evan T. Abrams, Steptoe LLP

     Extreme Networks agreed to pay $1.53 million to OFAC and nearly $1 million to the Department of Justice over exports to a Russian missile manufacturer that was blocked under OFAC's 50 Percent Rule, despite not being specifically designated at the time. Compliance lessons: conduct sanctions due diligence during acquisitions, independently verify end users, scrutinize red flags such as mismatched addresses and email domains, and maintain oversight of foreign subsidiaries.
     Separately, OFAC sanctioned individuals and entities supporting North Korea's IT worker schemes and expanded sanctions targeting support for M23 in the Democratic Republic of the Congo. Companies should refresh screening, review supply chains involving Congolese minerals, and strengthen controls against sanctions evasion and hidden beneficial ownership.

16. ST&R Trade Report: “Nairobi Protocol Offers Another Way to Mitigate Import Tariffs”
(Source: Sandler, Travis & Rosenberg Trade Report, 3 Nov 2026) [Excerpts]. Contact: [email protected], 1-305-894-1035

     There are many established and relatively well-known strategies for avoiding, mitigating, and/or recovering the growing number of tariffs the U.S. imposes on imported goods.
     One that importers may be less familiar with is the Nairobi Protocol covering goods specially designed or adapted for the use or benefit of handicapped persons.
     An international agreement concluded in 1950 provides for duty-free trade among signatory countries in specified categories of articles, including books, works of art, visual and auditory materials, scientific instruments, and articles for the blind.
     A subsequent amendment to that agreement, the Nairobi Protocol, broadened its scope to include duty-free treatment for articles for any handicapped persons without regard to the source of their affliction. The U.S. ratified the Nairobi Protocol in 1982.
     As a result, imports of articles specially designed or adapted for the use or benefit of handicapped persons, as well as specially designed or adapted parts and accessories thereof, are eligible for duty-free treatment under HTSUS subheadings 9817.00.92 through 9817.00.96. This means that such goods are exempt from not only regular Column 1 duty rates but also tariffs imposed under Section 301, Section 232, or other statutory authorities.
     U.S. Customs and Border Protection uses various factors to determine whether an imported article qualifies for such treatment. There are also specific exclusions, including articles for transient disability and therapeutic and diagnostic articles. . . . [Full article]

17. Volkov: “How Far Does Your Supply Chain Risk Go?”
(Source: Volkov Law, 3 Nov 2026) [Editor’s Summary]
• Principal Author: Michael Volkov, Volkov Law Group LLC

     Your supply chain doesn’t end at your supplier. Neither does your liability. Three risks are converging on the same shipments.
     Sanctions. Evasion networks use transshipment hubs, shell companies, and last-minute routing changes, and regulators now expect you to screen your cargo, not just your counterparties.
     Forced labor. U.S. law presumes goods linked to restricted regions or entities were made with forced labor unless you prove otherwise. And one blacklisted component several tiers down got thousands of luxury vehicles stopped at U.S. ports in 2024. Add country-level forced labor tariffs in the U.S. and an outright EU product ban fully applicable at the end of 2027.
     Then there’s human trafficking, which rarely announces itself. Look for workers in debt from recruitment fees, employers holding passports, delayed wages or inflated deductions, and overtime enforced by threats.
     The fix is the same for all three. See below the first tier.
     Assess residual risk based on a supplier’s tested controls rather than its ZIP code. Write enforceable contract terms, verify with audits and worker channels, and fix root causes instead of simply dropping a supplier. Build evidence, not a policy binder, before a customs officer asks a question you can’t answer. [Full article]

18. FD Associates Presents: “ITAR AUKUS Exemption” Webinar, 17 Nov 2026
(Source: Sarah Huffman)

19. Global Training Center Presents International Trade Seminars in Houston on 8, 9, 10, and 11 Dec 2026
(Source: Global Training Center)

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

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FULL LIST (Includes above entries.):

22. Bartlett's Unfamiliar Quotations
(Source: BrainyQuotes)

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

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24. 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.