USITC Votes Yes on Chinese Van-Type Trailers: Duty Orders Come Next, China Only

What happened

• The vote: At its 11:00 a.m. ET notational vote on September 25, 2026, the USITC found that van-type trailers and subassemblies from China injure the U.S. industry, in both the antidumping and countervailing duty cases (Inv. 701-TA-781 and 731-TA-1768). Individual Commissioner votes were not yet posted when the bulletin went out.
• China only: The vote covered China. The Canada and Mexico cases are still open on a later schedule, and Commerce's final Canada antidumping determination is due no later than December 17, 2026.
• The rates behind the orders: Commerce's final determinations for China (published August 31, 2026) set a 129.73% antidumping cash deposit for the China-wide entity (a 130.86% margin, adjusted for export subsidies) and a 134.75% countervailing rate for every company, including all others. The USITC's final report is due November 5, 2026.

Business consequence

Orders Next: An affirmative final vote means Commerce issues the antidumping and countervailing duty orders, and cash deposits continue on China-origin trailers and covered subassemblies.
No Producer Escapes It: Both final rates apply across the board, so switching Chinese suppliers does not lower the roughly 264% combined deposit.
Canada and Mexico: Canadian and Mexican supply is not settled by this vote and stays exposed through the end of the year.

Procurement Action

• Pull every open PO and inbound shipment for China-origin van-type trailers and subassemblies and confirm the country of origin and scope coverage.
• Rebuild landed cost with the 129.73% antidumping and 134.75% countervailing deposits on top of your current rate, and price U.S.-made or non-China alternatives against that number.
• Keep Canadian and Mexican trailer supply in a separate watch file until those cases close.

USITC: Van-type trailers and subassemblies from China injure U.S. industry (September 25, 2026)
USITC: notational vote, van-type trailers and subassemblies from China

Aluminum Can Stock Is Out of the Duty Orders on 17 Countries, and Unliquidated Entries Get Their Deposits Back

What happened

• The decision: Commerce issued final results of changed circumstances reviews (FR 2026-19516, applicable September 24, 2026) that revoke, in part, the antidumping and countervailing duty orders on common alloy aluminum sheet for qualifying aluminum can stock.
• Seventeen origins: The change covers China, Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and Turkiye.
• How far back: The revocation applies to all unliquidated entries of aluminum can stock, retroactive to the date suspension of liquidation began. Commerce will instruct CBP to liquidate those entries without AD/CVD and refund the deposits.
• Scope wording: Can stock is now described as generally classifiable under HTSUS 7606.12.3045 and 7606.12.3055, and the written description controls regardless of classification. Temper H-39 was added to the China exclusion.

Business consequence

Cash Back: Deposits paid on qualifying unliquidated can-stock entries come back without a protest.
Liquidated Entries: Entries that already liquidated are outside the retroactive relief, so the entry-by-entry status decides who gets money back.
Classification Is Not Enough: Because the written description controls, a shipment under 7606.12.3045 that does not meet the can-stock definition stays in the order.

Procurement Action

• Ask your broker for every unliquidated can-stock entry by order and origin, with the deposit paid on each.
• Check each shipment against the written can-stock description, not just the HTS number.
• Watch for the CBP liquidation instructions and reconcile each refund against your list.

Federal Register (GPO): common alloy aluminum sheet, final results of changed circumstances reviews (FR 2026-19516)

Section 301 Refunds on Excluded China Imports: PSCs for Entries From July 1 Through September 22

What happened

• The fix: CBP guidance CSMS #69990649, issued September 22, 2026, corrected the statistical reporting numbers under four China Section 301 exclusions in heading 9903.88.69, retroactive to July 1, 2026.
• ACE date: ACE began accepting the corrected filings at noon ET on September 23, 2026.
• The refund route: Importers that paid Section 301 duty on qualifying entries made July 1 through September 22, 2026 can file a post-summary correction. Entries outside the PSC window can be protested if they are still inside the protest period.

Business consequence

Duty Already Paid: If the exclusion did not match the new reporting numbers, the broker most likely paid the full Section 301 duty.
Not Automatic: Nothing comes back unless someone finds the entries and files.
Clock Running: Each entry's liquidation date decides whether it is a PSC or a protest.

Procurement Action

• Ask your broker for every China-origin entry from July 1 through September 22, 2026 that claimed, or should have claimed, a 9903.88.69 exclusion.
• File PSCs on unliquidated entries now and calendar protest deadlines for the rest.

GHY International: CBP guidance on the Section 301 China conforming amendment (CSMS #69990649)

The China Truce Date Moved to January 10, but 178 Exclusions and the Maritime Suspension Still End at 11:59 p.m. November 9

What happened

• The legal cutoff: The Federal Register notice that extended the 178 China Section 301 exclusions (FR 2025-21671) covers goods entered before 11:59 p.m. Eastern on November 9, 2026. That applies to both headings: 9903.88.69 (164 exclusions) and 9903.88.70 (14 solar manufacturing equipment exclusions).
• Why you have seen November 10: USTR's press release and the notice's narrative say the exclusions were extended "until November 10, 2026." The operative line is the 11:59 p.m. November 9 entry cutoff, and eligibility turns on the date of entry for consumption, not the ship or arrival date.
• Maritime: The China maritime, logistics, and shipbuilding Section 301 action stays suspended through 11:59 p.m. Eastern on November 9, 2026 (FR 2025-19873).
• The truce: Treasury Secretary Scott Bessent announced on September 23 that the broader U.S.-China truce will run to January 10, 2027. No USTR notice has moved either November 9 date.

Business consequence

Duty Snapback: Goods entered after the cutoff pay the underlying Section 301 rate again: 25% for Lists 1 through 3 and 7.5% for List 4A, on top of normal duty.
Wrong Date Risk: A plan built on January 10 or even November 10 can put a shipment on the wrong side of the line by one day.
Two Separate Files: Product exclusions and maritime fees end at the same minute but hit different budgets.

Procurement Action

• Change every exclusion-dependent SKU's cutoff to entries made by 11:59 p.m. ET November 9, 2026.
• Ask your broker to confirm entry-for-consumption timing on anything scheduled to land the first week of November.
• Log January 10, 2027 as the announced truce date only, and review it the day USTR publishes anything.

Federal Register: notice of product exclusion extensions, China Section 301 (FR 2025-21671)
Federal Register (GPO): suspension of the China maritime Section 301 action (FR 2025-19873)
CNBC: U.S.-China trade truce extended for two months, Bessent says

Trump-Xi Summit Ends With a $30 Billion Tariff-Cut Deal but No Rates: Keep China Rates Where They Are

What happened

• The outcome: President Trump and President Xi met in Washington on September 24, 2026. A White House fact sheet dated September 25 says the two sides agreed to more favorable tariff treatment on $30 billion of non-sensitive goods in each direction, handled through a new Board of Trade.
• Named categories: U.S. agricultural goods, seafood, wood products, cosmetics, and medical devices going to China; Chinese small appliances, toys, holiday decorations, and children's car seats coming to the United States.
• What is missing: No tariff rates, no HTS list, no effective date, and no CBP instruction. China announced the agreement on September 26, and USTR said more details are expected September 28, 2026.
• What stayed open: Tariff rates, Chinese purchases of U.S. goods, rare-earth supply, and technology restrictions were pushed into the next round.
• Purchases: Bessent said China is meeting its commitment to buy 25 million metric tons of U.S. soybeans but is behind on about $17 billion of other agricultural purchases, and U.S. officials say rare-earth deliveries are still below agreed levels.

Business consequence

No Savings to Book: Nothing from the summit lowers a payable duty on a China-origin entry until rates and an effective date are published.
Relief Stays a Scenario: The named categories tell you which SKUs to watch, but Board of Trade relief needs published rates and HTS coverage before it touches landed cost.
Supply Is a Separate Risk: A tariff truce does not guarantee rare-earth or critical-material deliveries.

Procurement Action

• Keep current China rates in approved landed cost.
• Model two separate scenarios: Board of Trade relief for named products, and the truce lapsing after January 10, 2027.
• Keep rare-earth and critical-material availability in its own supplier file, apart from tariff cost.

NPR: Trump and Xi strike cordial tone at summit amid underlying tensions
Bloomberg: Trump, Xi buy time on trade
White House fact sheet: fair and reciprocal relationship with China (September 25, 2026)
CNBC: China, U.S. agree to $30 billion tariff cut, Beijing says

Tris From China Now Carries Preliminary Countervailing Duties Up to 117.39%, With One Producer Reaching Back to June 26

What happened

• The rates: Commerce's preliminary countervailing duty determination on tris(hydroxymethyl)aminomethane (Tris, THAM, tromethamine) and Tris HCl from China (FR 2026-19530, published September 24, 2026) sets 117.39% for Changzhou Peicheng and 20.63% for Suzhou Yacoo and all others.
• Critical circumstances: Commerce found critical circumstances for Changzhou Peicheng only, so suspension of liquidation for that producer reaches entries made about 90 days before publication, which works out to June 26, 2026.
• Origin rule: The case follows where the Tris molecule was made, so Tris HCl processed in a third country from Chinese Tris is still covered.
• Next date: The final determination is aligned with the companion antidumping case and currently due no later than February 1, 2027.

Business consequence

Producer Swing: The same product carries 20.63% or 117.39% depending on who made it.
Look-Back: Changzhou Peicheng buyers may owe deposits on entries already made since late June.
Hidden Origin: Third-country Tris HCl can still be Chinese for this case.

Procurement Action

• Tie every Tris SKU to the actual producer and exporter, including material bought through distributors.
• Pull Changzhou Peicheng entries back to June 26, 2026 and expect deposits on them.
• Ask third-country Tris HCl suppliers where the Tris itself was made.

Federal Register (GPO): Tris from China, preliminary affirmative CVD determination (FR 2026-19530)

Polysilicon Anti-Stockpiling Rule Is Published: Import Caps, Blocked Importers, and New Checks for Customs Brokers

What happened

• Published: Commerce's temporary rule under Proclamation 11052 was published in the Federal Register on September 24, 2026 (FR 2026-19537) and runs from September 22 through December 3, 2026, the day before the Section 232 polysilicon regime starts.
• Established importers: Commerce watches for volumes well above historical averages and can have CBP stop an importer of record from making further covered entries before December 4. It can count volume moved through affiliates or new importer numbers.
• New importers: Importers of record registered after August 6, 2026 face weekly caps: 12 kg under HTSUS 2804.61.00, 7 kg under specified 3818.00 lines, 2,000 units under 8541.42.00, and 55 units under 8541.43.00, unless Commerce approves otherwise.
• Brokers: Customs brokers are directed to check whether the importer is new, the current week's volume, beneficial ownership, related importers, and the ultimate consignee. Commerce warns that brokers who help evade the limits risk CBP penalties and license action.

Business consequence

No Free Window: Pulling inventory forward before December 4 is exactly what the rule is built to stop.
Broker Friction: A broker who cannot answer the due-diligence questions may hold the entry.
Affiliate Trap: Splitting volume across a new or affiliated importer number is a stated factor against you.

Procurement Action

• Compare open polysilicon, wafer, cell, and module orders to your own historical weekly run rate before booking freight.
• Send your broker the importer-of-record list and expected weekly volume before the entry is filed.
• Prepare waiver paperwork now for any volume that needs to run above history.

Federal Register (via Justia): measures to restrict stockpiling of polysilicon and polysilicon derivatives (FR 2026-19537)

Canada Import Ban Starts 12:01 a.m. ET September 29: The Physical Import Date Decides Whether Goods Can Enter

What happened

• Three proclamations: Proclamations 11061 (alcoholic beverages), 11062 (dairy), and 11063 (motor vehicles), signed September 8, 2026, exclude the listed Canadian goods from U.S. importation for goods imported on or after 12:01 a.m. ET on September 29, 2026.
• What is covered: The annexes include beer, wine, spirits, cider, and non-alcoholic beer; eight types of whey; certain molasses products; and motorcycles and mopeds with engines over 800cc.
• Transition rule: Covered goods imported before the cutoff but not yet entered or withdrawn from warehouse for consumption stay at the 50% Section 338 duty instead of the ban.
• No deal in sight: USTR Ambassador Greer said on September 25, 2026 that the administration sees no urgency to reach a deal with Canada and is "comfortable with where we are," so plan on the ban taking effect as scheduled.

Business consequence

Access, Not Cost: For covered goods the question stops being what they cost and becomes whether they can enter at all.
One Day Matters: A load that crosses on September 29 instead of September 28 cannot be fixed by paying more duty.
Customer Exposure: Missed shipments turn into shortages and contract penalties downstream.

Procurement Action

• Give every covered Canadian SKU a documented decision: accelerate, cancel, or re-source, based on the carrier-confirmed import date.
• Log each covered supplier in your outreach tracker with a requote from a non-Canadian source.
• Escalate any load with a realistic chance of crossing after September 28.

Federal Register (GPO): Section 338 proclamation on Canadian goods (FR 2026-18835)

Pharmaceutical Tariff Cutover September 29: 100% Combined Rate for the Rest, and Two 0% Headings to Get Right

What happened

• The cutover: Companies outside the July 31 group move to the permanent Section 232 pharmaceutical treatment at 12:01 a.m. ET on September 29, 2026. CBP guidance (CSMS #69395344) says heading 9903.04.60 carries a 100% combined rate (Column 1 plus Section 232), and transitional heading 9903.04.61 covers entries only through September 28.
• Specialty drugs at 0%: Qualifying specialty pharmaceuticals (orphan, nuclear, plasma-derived, fertility, cell and gene therapy, antibody-drug conjugates, CBRN countermeasures, animal health) from one of 19 eligible jurisdictions, or with an approved urgent-health-need request, use heading 9903.04.66 at 0%.
• Clinical and R&D supply at 0%: New heading 9903.04.70 covers pharmaceutical articles and ingredients used solely for clinical trials, research and development, or other non-commercial purposes, at 0% additional.
• A correction to watch for: Some research circulating September 24 and 25 put the specialty 0% under 9903.04.70. That is the clinical-trial heading. The specialty heading is 9903.04.66 (FR 2026-19498).

Business consequence

Same HTS, Different Rate: Two products under the same HTS code can land at 100% or 0% depending on product, origin, use, and company.
Wrong Heading, Wrong Entry: Filing a specialty drug under 9903.04.70 or a clinical shipment under 9903.04.66 misreports the entry even when the rate is 0% either way.
Stale Transitional Code: Any entry still using 9903.04.61 on or after September 29 is wrong.

Procurement Action

• Map every patented pharmaceutical SKU to manufacturer, origin, specialty category (if any), and intended use before September 29.
• Remove 9903.04.61 from broker instructions for entries on or after September 29.
• Route clinical and R&D shipments to 9903.04.70 with proof of non-commercial use.

Federal Register: specialty pharmaceutical tariff adjustments and HTS corrections (FR 2026-19498)
CBP CSMS #69395344: pharmaceutical Section 232 filing guidance

UK Patented Drugs Stay at 0% Additional Under 9903.04.63: Recover Anything Filed at 10%

What happened

• The rate: CBP guidance CSMS #69415934 sets qualifying UK patented pharmaceuticals and ingredients under 9903.04.63 at 0% additional Section 232 duty, effective 12:01 a.m. ET July 31, 2026, and says ACE has been updated.
• Unchanged on September 29: The September 29 cutover does not touch 9903.04.63. The Chapter 99 heading still has to be reported even though the rate is zero.
• Recovery: Entries filed at the old 10% can be corrected with a PSC before liquidation or protested within 180 days after liquidation.

Business consequence

Overstated Cost: A rate table still carrying 10% for UK patented drugs overstates cost and may have overpaid since July 31.
Carryover Risk: A stale UK rate can ride into the September 29 rebuild if no one checks it.

Procurement Action

• Search rate tables, ERP fields, and broker instructions for any 10% UK pharmaceutical figure and replace it.
• Sort UK-origin patented pharmaceutical entries since July 31 into PSC and protest.

CBP CSMS #69415934: UK patented pharmaceuticals reduced to 0%

Canada's 50% Tariff List Changed September 15: 122 Codes Added, 10 Removed

What happened

• The count: CBP guidance CSMS #69851916 says 122 additional HTSUS classifications are now subject to headings 9903.03.12 or 9903.03.14, effective 12:01 a.m. ET September 15, 2026 (Proclamations 11064 and 11065). Some outside research put the number near 110; CBP's list says 122.
• Removed: Ten classifications came off: 2208.30.60 and 2208.70.00 under 9903.03.12, and 2501.00.00, 2523.29.00, 2940.00.60, 4803.00.40, 4818.90.00, 7801.10.00, 8537.10.91, and 9507.10.00 under 9903.03.14.
• Still stacking: The 50% Section 338 duty applies alongside AD/CVD and other duties and fees, and it is separate from the September 29 import ban.

Business consequence

Entries Since September 15: A Canadian SKU that was clean in August can be 50% now, and one that was 50% may be clear.
Two Canada Files: The tariff list and the ban list are different programs with different consequences.

Procurement Action

• Run every Canadian-origin HTS code against CSMS #69851916, line by line.
• Reconcile entries since September 15 against broker entry summaries for the added and removed codes.

CBP CSMS #69851916: modifying Section 338 additional duties on certain goods of Canada

ACE Error F884 Hard-Rejects Section 338 Exemption Lines Filed Without the Right Chapter 99 Pairing

What happened

• The error: ACE error F884, "EXEMPT HTS NOT ALLOWED FOR SECTION 338," fires when an entry line claims Section 338 exemption heading 9903.03.15 without the dutiable Section 338 Chapter 99 heading CBP expects on that line.
• Timing: The validation has been running in ACE production since August 26, 2026. CBP issued corrected CATAIR guidance on September 17.

Business consequence

Rejected Entries: A hard reject means a late entry summary and a delayed release.
Hidden Backlog: Brokers who hit F884 since August 26 may have refiled without telling you why.

Procurement Action

• Ask your broker for every F884 reject since August 26, 2026 and how each was fixed.
• Audit Canadian lines that claim 9903.03.15 before September 29, when ban and tariff lines start moving through the same entries.

Hydraulic Cylinder Duty Vote Is September 30: Finish Supplier Mapping First

What happened

• The vote: The USITC votes at 11:00 a.m. ET on September 30, 2026 on linear hydraulic cylinders and parts from Canada, China, India, Mexico, and South Korea. That date replaced earlier September 28 references.
• Scope: Commerce opened antidumping investigations on all five countries and countervailing duty investigations on China, India, and Mexico.
• Allegations only: Petition margins are allegations, not payable duties, and do not belong in current landed cost.

Business consequence

Negative Vote: A negative preliminary vote ends the cases.
Affirmative Vote: An affirmative vote moves them toward a preliminary subsidy decision around November 12 and a preliminary dumping decision around January 26, 2027.
Wide Reach: Cylinders sit inside construction, farm, mining, and material-handling equipment, so the exposure is often buried in assemblies.

Procurement Action

• Map every cylinder by manufacturer, exporter, country, part number, and annual spend before the vote.
• Request requotes from at least one alternate for your highest-spend part numbers.

USITC: notational vote, linear hydraulic cylinders, September 30, 2026

Germany Drug Pricing Investigation: Rebuttal Comments Are Due September 29, and There Is Still No Tariff

What happened

• Hearing: USTR held its Section 301 hearing on Germany's pharmaceutical pricing and reimbursement practices on September 22, 2026. USTR's posted schedule shows a single hearing day.
• Deadline: Rebuttal comments are due seven calendar days after the last hearing day, which makes the deadline September 29, 2026. Earlier editions of the free calendar hedged with September 29 or 30.
• No remedy: USTR has not proposed a tariff rate, product list, or effective date.

Business consequence

Separate Track: This investigation is separate from the Section 232 pharmaceutical cutover on the same day.
No Rate to Load: Mixing the two in a rate table creates a German drug tariff that does not exist.

Procurement Action

• Decide by September 29 whether to file a rebuttal.
• Keep German-origin pharmaceutical exposure in scenario files only, mapped by product, active ingredient, and requalification time.

USTR: Germany pharmaceutical Section 301 hearing schedule
Federal Register (GPO): Germany pharmaceutical Section 301 initiation and hearing notice (FR 2026-12671)

Sugar and Beef Quotas Open October 1: Refined Sugar Is Expected to Fill at the Opening Moment

What happened

• Raw cane sugar: USTR allocated the remaining 55,993 metric tons raw value of the FY2027 raw cane sugar quota among 28 countries (FR 2026-19399), led by the Dominican Republic (11,931), the Philippines (9,151), and Australia (5,626). That completes the 1,117,195 MTRV total. Country allocations need certificates of quota eligibility.
• Refined sugar: CBP's FY2027 bulletins say the refined sugar quota opens October 1 at 12:00 p.m. ET and is expected to be oversubscribed at the opening moment. CBP also issued opening rules for sugar-containing products and specialty sugar.
• Beef: The first 100,000-metric-ton tranche of the temporary lean-beef quota closes September 30. Tranche 2 runs October 1 through October 30. Opening-day entries filed before 8:30 a.m. ET get an 8:30 entry time, and oversubscribed groups may be prorated (Quota Bulletin 26-231).

Business consequence

Quota, Not Rate: In-quota and over-quota cost can differ sharply for the same product, depending on the minute of entry.
Proration: A full order can clear only in part if the tranche is oversubscribed.

Procurement Action

• Confirm certificates, allocation country, and entry timing for every FY2027 sugar entry.
• Price an over-quota fallback for sugar and beef before October 1.

Federal Register (GPO): FY2027 raw cane sugar tariff-rate quota allocations (FR 2026-19399)

CAPE Phase 3 Opens October 6 for a Narrow Group of Finally Liquidated IEEPA Refunds

What happened

• The source: In a sworn declaration filed with the Court of International Trade on September 15, 2026, CBP said it will deploy CAPE Phase 3 on October 6, 2026.
• Who qualifies: Phase 3 covers finally liquidated entries filed by plaintiffs for which the court has ordered reliquidation. Plaintiffs that gave CBP a valid importer-of-record number by July 30, 2026 can file on October 6; later submitters get separate instructions.
• A stale claim: Some research dated September 24 still said CBP had missed its August 20 target with no new date. The September 15 declaration set October 6.

Business consequence

Eligibility Limit: A finally liquidated entry without a court order is still outside Phase 3.
Receivable Risk: Booking refunds for entries that do not qualify overstates expected cash.
Launch Readiness: Missing ACE access or ACH details can push filing past October 6.

Procurement Action

• Sort IEEPA entries into Phase 3 eligible and not eligible.
• Confirm the court order, importer-of-record submission, ACE access, and ACH banking details before October 6.

CBP declaration, Freestyle World, Inc. v. CBP, CIT No. 26-01088 (September 15, 2026)

Up to 500% on Russian Goods and 100% on Russian-Energy Buyers: The Law's Deadline Is October 18

What happened

• The law: H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, became Public Law 119-111 on September 18, 2026.
• Section 112: Within 30 days, the President must raise duties on all Russian-origin goods, including energy, to a rate of up to 500%.
• Section 113: Goods from covered countries can face up to 100%. Covered countries are the top five importers of Russian crude or gas that keep making new purchases 30 or more days after enactment, plus the top five sanctions-evasion facilitators. USTR can set the rate anywhere above 0% up to 100% and must redetermine the list every 180 days.
• Status: October 18, 2026 is the 30-day mark and falls on a weekend. No rate and no country list has been published.

Business consequence

Whole-Country Scope: A Section 113 designation covers every product from that country, not just energy.
Scenario, Not Rate: Until a list is published, a major sourcing country that buys Russian energy is a scenario.

Procurement Action

• Model your top single-source categories from Russian-energy-buying countries at +25%, +50%, and +100%.
• Plan an exit from any Russian-origin content before October 18.
• Do not accrue any H.R. 5334 rate until one is published.

White House: H.R. 5334 signed into law
Congress.gov: Public Law 119-111 text

Solar Buyers Face an October 14 Duty Vote and a December 4 Polysilicon Price Floor: Two Programs, Two Controls

What happened

• Solar AD/CVD: The USITC votes October 14, 2026 at 11:00 a.m. ET in the final phase on crystalline silicon photovoltaic cells from India, Indonesia, and Laos, whether or not assembled into modules. Commerce's final antidumping rates are 123.04% for India, 94.36% for Indonesia, and 65.43% for Laos.
• Polysilicon Section 232: Starting 12:01 a.m. ET December 4, 2026, minimum import prices apply: $21/kg for polysilicon, $100/kg for ingots and wafers, $0.22/watt for cells, and $0.38/watt for modules, plus 15% on specified derivatives, subject to partner treatment.

Business consequence

Deposits Either Way: A negative October 14 vote ends the cases and deposits come back; an affirmative vote leads to orders.
Different Data: Solar AD/CVD runs on cell producer and cell origin; the Section 232 floor runs on transaction price and product form.

Procurement Action

• Keep a list of solar entries with deposits paid so they can be reconciled either way after October 14.
• Keep the two programs in separate fields; do not blend them into one solar rate.

Chinese Tin Mill Steel: Commerce Finals Due by November 30, and the USITC Hearing Is December 4

What happened

• Current deposits: Commerce's preliminary countervailing duty on tin mill products from China is 66.61%, and the China-wide preliminary dumping margin is 136.52%, with a 130.17% cash deposit after subsidy offsets.
• Final date: Commerce's final determinations are due no later than November 30, 2026 unless postponed. Some research dated September 24 and 25 said December 1; both Commerce notices say November 30.
• USITC final phase: The USITC scheduled its final phase on tin mill products from China, Taiwan, and Turkiye (Inv. 701-TA-792 and 731-TA-1786-1788). The hearing is December 4, 2026 at 9:30 a.m. ET, with prehearing briefs due November 27, post-hearing briefs December 11, and final comments December 30.

Business consequence

Can Cost: Tin mill steel feeds food cans, beverage cans, and aerosol containers.
Hidden Origin: Buyers who purchase through converters may not see China on their own paperwork.
Wider Case: Taiwan and Turkiye supply is also in the injury case, so switching to those sources is not a clean escape.

Procurement Action

• Ask converters for the mill of origin on every tin mill input.
• Use the broker's cash-deposit instructions for the actual producer; do not add the headline percentages.

USITC: tin mill products from China, Taiwan, and Turkey, final-phase schedule
Federal Register: tin mill products from China, preliminary AD determination (FR 2026-19274)

Section 122 Surcharge Ended July 24, but the Refund Fight Is Still at the Federal Circuit

What happened

• The surcharge: The 10% Section 122 surcharge took effect February 24, 2026 and ran through 12:01 a.m. EDT July 24, 2026. The proclamation was signed February 20.
• The courts: The Court of International Trade ruled the surcharge unlawful on May 7, 2026 (Slip Op. 26-47), after hearing argument on April 10. Relief was limited to named plaintiffs. The Federal Circuit stayed the ruling on June 11 (Nos. 2026-1804 and 2026-1805) and has not scheduled argument.
• A correction: Research dated September 24 said the surcharge started February 20 and that the Federal Circuit heard argument April 10. February 20 was the signing date, and April 10 was the CIT argument.

Business consequence

Nothing Live: No new entry should carry a Section 122 line.
Rights Still Matter: If the plaintiffs win on appeal, recovery can depend on each entry's protest rights.

Procurement Action

• Confirm your rate workbook shows Section 122 as expired, not active.
• Log every Section 122 entry with its liquidation date and file protective protests as entries liquidate.

Court of International Trade: Slip Op. 26-47 (May 7, 2026)

Freight Rail Coupler Duties: Final Rates Set, USITC Vote October 16, and India's Subsidy Deposits Paused Until Then

What happened

• Czech Republic: Commerce's final antidumping rate is 73.74% for CKD Kutna Hora and all others, and deposits continue.
• India antidumping: Final margins are 71.01% for Bhilai and Jupiter, 12.10% for Texmaco, 1.55% for all others, and a 0% adjusted deposit for Kharagpur.
• India subsidies: Final countervailing rates are 75% for Texmaco, Bhilai, and Jupiter and 9.71% for Kharagpur and all others. Provisional measures expired July 1, so these deposits resume only if the USITC votes yes.
• The vote: The USITC votes October 16, 2026 at 11:00 a.m. ET.

Business consequence

Producer Spread: An India coupler can carry about 11% or about 146% in combined duty depending on the producer.
Timing Gap: India CVD is not being collected right now, which makes current invoices look cheaper than the post-vote cost.

Procurement Action

• Tie every coupler PO to its manufacturer and exporter, and to the case it falls under.
• Price India supply with the CVD layer included, even while deposits are paused.

CBP's New Entry Type 13 for Mail Shipments Under $2,500 Is Live, and It Needs a Bond

What happened

• The option: CBP deployed Entry Type 13, an electronic informal entry for postal shipments valued at $2,500 or less, to ACE production on September 22, 2026. It is voluntary for now.
• Who can file: The merchandise owner, purchaser, or a licensed broker they designate. A foreign postal operator cannot be the importer of record.
• Conditions: A basic importation bond must be in place before filing or CBP holds release. Duty is paid by ACH on the 7th of the following month. Goods under AD/CVD orders or quotas stay on formal entry.

Business consequence

Held Samples: Samples and spare parts sent by mail can stall if no bond is on file.
IOR Accuracy: CBP began enforcing accurate importer-of-record data on postal entries September 18.

Procurement Action

• Confirm bond coverage in ACE before mail shipments arrive.
• List the samples and spare parts that arrive by mail and decide who files for each.

Still in Force: The Forced-Labor Tariff on 60 Economies and Brazil's 25%, While Brazil Holds Off Retaliation

What happened

• Forced-labor Section 301: The action on 60 economies, generally at 10% or 12.5% with product exemptions and special treatment for some partners, has applied since July 24, 2026. The CIT hears the 25-state challenge on September 30.
• Brazil: A separate 25% Section 301 duty on covered Brazil-origin goods has applied since July 22, 2026. President Lula said Brazil will not invoke its reciprocity law against the United States while talks continue.
• Section 122: The broad 10% surcharge is not part of the current stack; it ended July 24.

Business consequence

Separate Layers: Brazil-origin goods can carry both the Brazil action and the forced-labor action, each with its own Chapter 99 code.
Retaliation Risk: Brazil's restraint is a policy choice, not a legal commitment, so U.S. exporters to Brazil should keep a scenario open.

Procurement Action

• Confirm every rate line shows its own program and Chapter 99 code.
• Keep entry-level records for forced-labor duties paid since July 24 in case the CIT case goes the plaintiffs' way.

USTR: fact sheet, Section 301 action on 60 economies
USTR: Section 301 action on Brazil

Vietnam Says a U.S. Trade Deal Is "Very Close," but the 12.5% Tariff Stays Until One Is Signed

What happened

• The statements: Vietnam's President To Lam told the UN General Assembly on September 21, 2026 that the two countries are "very close to a final outcome." USTR Ambassador Greer said on September 22 that negotiators have made significant progress.
• What is on the table: Vietnam has offered more purchases of U.S. aircraft, nuclear power equipment, and infrastructure, and Washington wants tighter rules of origin on Chinese inputs.
• Current rate: Vietnam faces the 12.5% forced-labor Section 301 rate and is named in three Section 301 investigations. Nothing changes until a deal is signed and implemented.

Business consequence

Origin Rules: Tighter rules on Chinese inputs could matter more to Vietnam sourcing than any rate cut.
No Rate Change: Pricing a deal into current quotes is premature.

Procurement Action

• Tag Vietnam sourcing cases that depend on the deal, and ask suppliers how much Chinese content each product carries.