Monday Morning eBriefing

Customs and Border Protection (CBP) on Dec. 18 issued a Withhold Release Order (WRO) against automobile tires manufactured in Serbia by Linglong International Europe D.O.O. Zrenjanin. Effective immediately, the agency said CBP personnel at all U.S. ports of entry will detain shipments of these tires due to evidence reasonably indicating the use of forced labor in their production.

Don't wait to register to attend the upcoming 2026 NCBFAA Annual Conference at the JW Marriott San Antonio Hill Country Resort & Spa in San Antonio, Texas, on April 12-15, 2026, or it may be too late.

U.S. bankruptcies have continued to surpass pre-pandemic levels, starting in 2019, according to a recent report by Marcos Carias, credit risk firm Coface’s economist for North America. In fact, U.S. business bankruptcies reached 6,574 in Q3 2025, the highest since Q2 2014 and 15% above the 2019 average, marking two consecutive quarters above pre-pandemic levels, Coface noted. While the tariffs have acerbated this trend, U.S. bankruptcies are anticipated to pile on in the coming year.

Customs and Border Protection (CBP) announced Dec. 16 that between Jan. 20 and Dec. 15, 2025, it had collected more than $200 billion in tariffs due to more than 40 executive orders put in place by the Trump Administration.

Customs and Border Protection (CBP) on Dec. 17 reported it has collected more than $1 billion in duties on over 246 million low-cost shipments since the Trump Administration began phasing out de minimis in May 2025.

Customs and Border Protection (CBP) on Dec. 16 enhanced the ACE Secure Data Portal to enable additional account user access to the ACH Refund Authorization tab under the Importer sub-account view.

Customs and Border Protection (CBP) has updated the ACE CAMIR ACE Ocean/Rail Import Manifest Appendix D - Disposition Codes for a future enhancement with new disposition codes: D2 – Seal Added and D3 – Seal Deleted.

Customs and Border Protection (CBP) has updated the ACE truck implementation guides to reflect the new Carnet codes.

FIATA highlighted that the United Nations (UN) General Assembly on Dec. 15 adopted the UN Convention on Negotiable Cargo Documents (NCD Convention), marking a significant milestone for international trade, multimodal transport and the digitalization of global supply chains.

In a meeting with NCBFAA Regulatory Agencies Committee (RAC) leaders, the Consumer Product Safety Commission (CPSC) report that the updated HTS code flagging list for the CPSC e-filing initiative should be available by the end of January. So far, CPSC says they are reducing the list to around 620 HTS codes, with fewer than 200 that are not disclaimable.

A summary of the latest customs and cross-border trade regulatory updates brought to you by our NCBFAA Customs Counsel firm Sandler, Travis & Rosenberg.

The NCBFAA Customs Committee and Counsel of Sandler, Travis & Rosenberg, P.A., continue to provide our customs broker members with the latest details regarding tariff changes resulting from the implementation of the U.S.-Korea Strategic Trade and Investment Deal, as well as the latest Customs and Border Protection (CBP) IEEPA guidance and FAQ updates. The Committee will continue sending our members Trump Administration tariff updates and subsequent CBP guidance, as soon as received.

The USDA Food Safety and Inspection Service (FSIS) announced updates to its label approval guidelines to help establishments to meet new requirements for use of voluntary U.S.-origin label claims on FSIS-regulated products (meat, poultry and eggs).

The NCBFAA Regulatory Agencies Committee (RAC) is making the resources in the CPSC Toolkit available to association members’ importer clients to help prepare them for the Consumer Product Safety Commission (CPSC) Certificate E-Filing requirements which take effect July 8, 2026.

Beginning Jan. 1, 2026, certain species of fish or fish products exported from 34 countries must provide through ACE a Certificate of Admissibility (COA) signed by an authorized official and also an attestation signed by the U.S. Importer of Record that the fish was not harvested in a fishery that was denied a comparability finding.

The National Oceanic and Atmospheric Administration (NOAA) Fisheries Office of International Affairs, Trade, and Commerce will host a webinar on Dec. 18, from 2-3 p.m. ET, to explain new catch certificate requirements for all seafood products exported to the European Union. NOAA Fisheries invites all SIP stakeholders planning to export to the European Union (EU) or who regularly request a U.S. Legal Harvest Certificate to attend to learn about the new requirements.

It has been brought to the NCBFAA Customs Committee’s attention by the U.S. International Trade Commission (USITC) Committee for the Statistical Annotation of Tariff Schedules, or 484(f) Committee, that the approved changes in the Schedule B will likely become effective Jan. 1, 2026. However, due to time lost during the government shutdown, there will be some delays in finalizing and updating approved changes to the Harmonized Tariff Schedule (HTS). Thus, requested HTS breakouts that are approved will instead become effective on or around Feb. 1, 2026.

A summary of the latest legislative and regulatory transport, logistics and trade sector updates brought to you by our NCBFAA Transportation Counsel firm Venable.

NCBFAA wishes you and your family Happy Holidays! And what better way to treat yourself than to register to attend the upcoming 2026 NCBFAA Annual Conference at the JW Marriott San Antonio Hill Country Resort & Spa in San Antonio, Texas, on April 12-15, 2026.

Hundreds of importers are dashing to the Court of International Trade to enjoin Customs and Border Protection (CBP) from assessing the IEEPA tariffs. But is it really necessary? And when will we know for sure? NCBFAA Customs Counsel Lenny Feldman of Sandler, Travis & Rosenberg, P.A. (ST&R) reflects upon these important questions.