1. As of September 11, Canada's Section 338 Product List Changes Again in 4 Days, September 15

Current status

Section 338 Product-List Update: CBP guidance confirmed under CSMS #69606660 that further modifications to the Canada Section 338 50% duty list take effect September 15, 2026 at 12:01 a.m. Eastern.

• Additions: Certain cheeses, lamps, and fishing equipment are being added to coverage.
• Revision: Motorboats see a revised scope.
• Removals: Two spirits tariff codes are being removed from the duty list entirely.
• Stacking Rule: This sits on top of the broader 50% Section 338 program that took effect August 22, 2026, and continues to apply in addition to any Section 232 duty on the same product, not instead of it.

Procurement action

Update the Overlay Before September 14: Refresh the Section 338 Canada overlay reference so the rate workbook reflects the corrected product list before the September 15 change lands.

• Add: The newly covered cheese, lamp, and fishing-equipment HTS lines at 50% ad valorem.
• Adjust: The motorboat entries for the revised scope.
• Remove: The two delisted spirits tariff codes, so the workbook does not overstate duty on those lines after September 15.
• Re-test: Any product carrying both a Section 338 and a Section 232 duty, for correct stacking treatment before the change lands.

2. As of September 11, Canada's Import Ban Is 18 Days Out, September 29

Current status

US Import Prohibition: Starting September 29, 2026 at 12:01 a.m. Eastern, specified Canadian beer, wine, and spirits, eight categories of whey and dairy products, molasses, and large-engine motorcycles and mopeds move from a 50% Section 338 duty to an outright US import prohibition.

• Impact on Existing Imports: Goods imported before September 29 but not yet entered for consumption or withdrawn from warehouse remain subject to the 50% duty rather than the ban.
• Economic Impact: US imports of the newly banned categories totaled roughly $846 million in 2025.
• Duty vs. Ban: A 50% duty is a cost that can be absorbed, negotiated, or passed through. A prohibition means a covered item cannot enter the United States once the ban applies, at any price.

Procurement action

Build the September 29 Exposure File: If this file does not already exist, it is the highest-priority item on this entire page.

• Scope: Every Canadian-origin SKU potentially inside the covered categories.
• Capture: HTS classification, supplier, purchase-order quantity, expected US import date, current inventory coverage, an alternate source if one exists, and contract cancellation rights.
• Why It's Different: A spreadsheet built for absorbing a duty rate will not answer the question this ban actually asks: can the shipment legally enter the country at all after September 29.

5. The United States and Mexico Are Racing Toward an Interim Trade Deal Before the Midterms

Current status

Accelerated Mexico Negotiation: US and Mexican officials are accelerating talks toward an interim bilateral trade arrangement, with both sides targeting progress before the November 3, 2026 midterm elections.

• Current Rates: Mexican steel faces a 50% Section 232 tariff; covered Mexican vehicles face 25%.
• Reported Discussion: The vehicle rate could drop toward 15%, with an added credit for verified US content in engines, electronics, and software that could push the effective rate toward roughly 7% for qualifying products.
• Recent Contact: Commerce Secretary Howard Lutnick met virtually with Mexican President Claudia Sheinbaum on September 10, 2026 as the pace of talks increased.
• Chinese-Investment Screening: Washington is separately pressing Mexico to tighten scrutiny of Chinese investment in Mexican manufacturing; Mexico is reportedly considering a new foreign-investment screening regime similar to those already used in the United States and Canada.
• Status: None of this is agreed or implemented. The current 25% and 50% rates remain the applicable law.

Procurement action

Build a Mexico Deal-Sensitive Population: Prioritize Mexican-origin vehicles, auto parts, steel, aluminum, and high-value manufactured assemblies rather than treating every Mexican SKU the same way.

• Capture: HTS code, current Section 232 treatment, documented US content percentage, and any known Chinese ownership, input, or investment exposure in the supplying facility, for each prioritized SKU.
• Start Now: Measure US content inside the Mexican product. If a negotiated framework eventually ties preferential treatment to US content, the supplier that can already document it has a sourcing advantage over one that cannot.
• Do Not: Change purchase-order pricing, supplier pass-through terms, or customs instructions based on the negotiation.
• Model: Current duty, a 15% scenario, and a roughly 7% content-adjusted scenario as three separate lines, keeping the current 25% and 50% rates as the only operating assumption.

Illustrative scenario only, not a booked saving: a company importing $100 million a year of covered Mexican-origin vehicles pays $25 million under the current 25% rate. At a possible 15% negotiated rate, the same volume would carry $15 million in duty, a $10 million difference. At a reported roughly 7% content-adjusted effective rate, the same volume would carry about $7 million in duty, an $18 million difference from the current 25% rate. No agreement currently establishes either lower rate; both remain scenarios, not booked savings.

6. Even a Canada Aluminum Tariff Cut May Not Lower Your Landed Cost

Current status

Tariff Cut Warning: Alcoa CFO Molly Beerman said that even if Washington cuts the tariff on Canadian aluminum from 50% to 25%, the US Midwest aluminum premium is unlikely to fall substantially.

• Physical Supply Gap: The United States needs roughly 4 million tons of aluminum imports annually; Canada can supply approximately 3 million tons, leaving roughly 1 million tons that must still be incentivized into the United States from other markets regardless of the Canadian duty rate.
• Current Premium: Approximately $1.09 per pound, down from a record $1.19 per pound in June 2026.
• Supply Tightness: Alcoa's North American and European order book is almost completely sold out for the remainder of 2026, while Middle East supply disruptions are tightening the market further.

Procurement action

Model the Two Costs Separately: When modeling a possible Canada aluminum tariff reduction, reduce the customs-duty line only, not the Midwest premium.

• Keep Separate: LME base price, Midwest premium, and Section 232 duty as three separate variables that sum to actual delivered metal economics.
• Two Scenarios, Not One: Model tariff relief and market-premium relief separately.

7. A New Amicus Brief Keeps the Section 122 Refund Question Alive

Current status

New Amicus Brief Filed: On September 9, 2026, the Cato Institute and Professor Ilya Somin filed an amicus brief with the US Court of Appeals for the Federal Circuit in the government's appeal of the Court of International Trade's May 7, 2026 ruling, which had found the 10% Section 122 tariff unlawful.

• Brief's Arguments: Section 122 requires a fixed-exchange-rate system that no longer exists, the tariff's economic scale triggers the major-questions doctrine, and the administration's reading of the statute would amount to an unconstitutional delegation of legislative power.
• Status Clarity: The Section 122 surcharge itself expired by operation of law on July 24, 2026, and it is not currently being collected.
• What's Unresolved: Whether importers can recover the roughly five months of Section 122 duties paid between the tariff's imposition and its expiration.

Procurement action

Update Filing Status: Set every entry carrying Section 122 duty paid between the tariff's effective date and July 24, 2026 to "Monitoring, Appeal Pending."

• Hold Off: Do not file new protests based on the CIT's invalidation until the Federal Circuit rules on the September 9, 2026 amicus filing and the underlying appeal.
• Preserve: Entry records, CBP entry numbers, and estimated refund figures, so filings can move quickly once the appeal resolves.

8. Copper Import Reporting Becomes a Hard Compliance Deadline September 14

Current status

Fatal ACE Rejection Starts September 14: CBP CSMS #69711865 confirms ACE will reject copper entry summaries lacking primary country-of-smelt and country-of-cast data as a fatal error, code F794 ("ADDTNL DEC TYPE RQRD FOR ARTICLE"), rather than the warning-level validation currently in place.

• Covered HTS Lines: 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10, imported from any country other than the United States.
• Required Declaration: A "54 record type 12" declaration with primary country of smelt (required), country of cast (required), and secondary country of smelt (optional); "OTH" may be used when origin is genuinely unknown.
• Program: This sits under the existing Section 232 copper program.

Procurement action

Confirm Broker Readiness Before September 14: Verify the customs broker's ACE filing software captures the "54 record type 12" fields.

• Flag the Workbook: Add a country-of-smelt and country-of-cast reference flag to the four affected HTS lines, so anyone importing these copper articles is prompted for the data ACE will now require on every entry summary.

9. Commerce Sets a 66.61% Preliminary Duty on Chinese Tin Mill Steel

Current status

66.61% Preliminary CVD Rate: Commerce announced a preliminary affirmative countervailing-duty determination on tin mill products from China on September 10, 2026, assigning an initial 66.61% subsidy rate.

• Covered HTS Lines: 7210.11.0000, 7210.12.0000, 7210.50.0020, 7210.50.0090, 7212.10.0000, 7212.50.0000, 7225.99.0090, and 7226.99.0180.
• Product: Tin mill steel is the base material for tin-plated cans and containers.
• Not Yet Payable: The Federal Register publication and the resulting suspension-of-liquidation and CBP cash-deposit instructions, the operational trigger for this rate to actually apply, had not been located as of this writing.

Procurement action

Identify Exposure Now: Flag any tin mill steel or tin-plated can and container spend sourced from China, and capture the specific HTS line.

• Watch For: The Federal Register notice that would activate a cash-deposit requirement.
• Do Not: Treat 66.61% as a payable rate until CBP issues implementing instructions.

12. Commerce Finalizes Steep Duties on Solar Panels From India, Indonesia, and Laos

Current status

Final AD/CVD Determinations Issued: Commerce issued final affirmative antidumping and countervailing-duty determinations on crystalline-silicon photovoltaic cells and modules from India, Indonesia, and Laos.

• Final AD Margins: 123.04% for India, 94.36% for Indonesia, and 65.43% for Laos.
• Final CVD Rates: 126.09% for India, 73.2% to 173.7% for Indonesia, and 82.03% to 153.67% for Laos.
• Not Yet an Order: These are final Commerce determinations, but final AD/CVD orders have not yet been issued.
• Next Step: The USITC's final injury vote is scheduled for October 14, 2026; if affirmative, Commerce is expected to issue final duty orders in November 2026.

Procurement action

Build the Scenario, Not the Cost: Identify all India, Indonesia, and Laos-origin solar cell and module purchases, and build a scenario at the final margin level for each country.

• Label It Correctly: Clearly mark the scenario as pending the October 14, 2026 injury vote rather than a current cost.
• Do Not: Activate any TAF-097 rate line until a final order is actually issued, which would not occur before November 2026 at the earliest.

13. Iran Sanctions Tighten Sharply, With a Bank Sanction Expected September 14

Current status

Presumption of Denial, Effective September 10: OFAC changed its Iran-specific licensing policy to a presumption of denial, except for narrow circumstances such as life, safety, or environmental emergencies, and began denying most outstanding Iran-specific license applications.

• New Designations: Treasury designated additional individuals and entities across Iraq, Lebanon, the United Arab Emirates, and Turkiye supporting Kata'ib Hizballah and Lebanese Hizballah, covering procurement, money-exchange, gold, and financial networks.
• Broader Exposure: The action also reinforces 50%-ownership blocking rules and broader secondary-sanctions exposure for companies dealing with Iran-linked networks.
• Bank Sanction Coming: Treasury Secretary Scott Bessent said the administration will sanction an unnamed large bank on September 14, 2026 as part of the same campaign; the institution and its country have not yet been identified.

Procurement action

Update Screening Now: Reflect the presumption-of-denial posture and the newly blocked procurement and financial networks in Iran counterparty and sourcing-risk screening.

• Rescreen Before September 14: Banks and payment intermediaries used in Iran-adjacent jurisdictions or supply chains, since the specific institution named that day is not yet known and broad rescreening is the only available control in the meantime.
• Keep Separate: This is a sanctions and counterparty-risk control, not a customs tariff; keep it in a separate risk layer from duty tracking.