The Customs Watch USA: Edition 30
- Annkaren Wambui
- 14 hours ago
- 6 min read
Welcome back to The Customs Watch USA. We took August off. U.S. customs and trade policy did not.
š Drone tariffs up to 100% start this week, Canada's 50% duties are active, affecting 629 U.S. tariff lines from 8 September, and CBP may void importers' numbers.
The Customs Watch USASummary:Ā The United States has returned from August with one of the busiest periods of customs and trade enforcement this year. This edition examines new Section 232 tariffs of up to 100% on drones and unmanned aircraft systems, the implementation of 50% Section 338 duties on selected Canadian goods, and Canada's retaliatory 15%, 25% and 50% counter-tariffsĀ on 629 U.S. tariff lines. CBP is also tightening operational enforcement. From 18 September 2026, inaccurate or outdated Form 5106 information could result in an importer of record number being voided, stopping cargo release and entry filing. Meanwhile, new transshipment targeting, mandatory ACH payments for duty-increasing Post Summary Corrections, minimum import prices for polysilicon and solar products, and major new AD/CVD actions continue to reshape landed costs and sourcing decisions. Businesses importing into, exporting from or trading with the United States should reassess supplier exposure, importer registration data, country-of-origin evidence, customs declarations, shipment timing and duty management strategiesĀ as enforcement moves from policy announcements into operational reality. |
The Biggest Tariff Changes Are Already Here
August was quiet for our publication schedule. It was anything but quiet for U.S. customs and trade policy.
The most immediate change is the new Section 232 action on unmanned aircraft systems, with duties of up to 100% taking effect on 3 September 2026. Larger drones, thermal-imaging systems, docking stations and specified components are affected, while smaller unmanned aircraft face a 25% rate. Although reduced rates are available in certain circumstances for goods from selected allied countries, the certification process required to access that relief has not yet been publicly established.
Canada is another major development. The United States' new 50% Section 338 duties on selected Canadian goodsĀ are now in force, and USMCA preference does not automatically remove the exposure. Importers must also pay close attention to the new Chapter 99 reporting requirements, including zero-rate provisions that must be actively claimed rather than assumed.
The response is now moving in the other direction too. From 8 September 2026, Canada will impose retaliatory surtaxes of 15%, 25% and 50% on 629 U.S. tariff lines, affecting sectors including steel, dairy, wood products, appliances and electronics.
Businesses trading across the Canadian border should carefully review product coverage, origin rules, customs declarations and shipment timing on both sides of the border.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
CBP Tightens Importer and Entry Compliance
One of the most important developments in this edition does not involve a new tariff rate.
From 18 September 2026, CBP may void an importer of record number where Form 5106 information is inaccurate, incomplete or outdated. This includes situations where a broker's, freight forwarder's or other service provider's address, email address or telephone number has been entered instead of the importer's own information.
A voided importer number can stop ACE cargo release transactions, entry summary filing and other customs functions. In practical terms, that means a company can suddenly find itself unable to import until the problem is corrected. CBP indicates that updates to an existing record can take approximately five business days to process, making this a business continuity issue as much as a compliance requirement.
CBP has also changed how duty-increasing Post Summary CorrectionsĀ are handled. Since 5 August, electronic payment is mandatory, full payment must be made at filing and partial payments and checks are no longer accepted. Companies and brokers therefore need to ensure that ACH processes and internal payment approvals can support immediate settlement of customs corrections.
At the same time, the White House has published a new transshipment targeting framework covering more than 40 jurisdictions and identifying higher-risk routing patterns. This increases the importance of being able to demonstrate genuine production and substantial transformation rather than relying solely on supplier declarations of origin.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
Trade Remedies, Supply Chains and New Compliance Risks
The August developments extend well beyond Canada and CBP operations.
Chinese-origin van-type trailers now face combined AD/CVD exposure exceeding 264%, while new and ongoing trade remedy actions are affecting products including citric acid, stainless steel pipe, rebar and pipe fittings.
Importers of quartz surface products are also dealing with a new four-year Section 201 safeguard tariff-rate quota, with a 25% duty within quota and 50% above quota, potentially stacked on existing duties and trade remedies.
Further ahead, a new Section 232 measure on polysilicon and its derivatives introduces minimum import prices and additional duties from 4 December 2026. The compliance model is particularly significant because importers may need to certify information relating to future downstream sales prices. Materially inaccurate documentation could result in a permanent prohibition on importing covered products.
The edition also covers developments involving the EU Deforestation Regulation, new miscellaneous tariff bill petition procedures, critical minerals, classification developments and customs litigation.
As customs compliance becomes increasingly connected to sourcing, sales, accounting and supply-chain data, businesses should ensure that their customs teams, brokers and internal systems are aligned with the latest requirements.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
Overview of This Week's Changes
Topic | Why It Matters |
Form 5106 Importer Numbers | CBP may void inaccurate or outdated importer of record numbers from 18 September, potentially stopping cargo release and entry filing. |
Drone Section 232 Tariffs | Duties of up to 100% take effect on 3 September on covered unmanned aircraft systems and components. |
Canada Section 338 Duties | New 50% duties on selected Canadian goods are now live with new Chapter 99 reporting requirements. |
Canada Counter-Tariffs | Canada will impose 15%, 25% and 50% surtaxes on 629 U.S. tariff lines from 8 September. |
Transshipment Enforcement | New targeting identifies high-risk jurisdictions, routes and products, increasing scrutiny of origin claims. |
Polysilicon Minimum Import Prices | New Section 232 measures introduce price floors, additional duties and severe certification consequences from December. |
Chinese Trailer Duties | Combined AD/CVD exposure now exceeds 264%, including potential coverage of subassemblies and components. |
Quartz Surface Safeguards | A new four-year tariff-rate quota applies 25% in-quota and 50% over-quota duties. |
PSC ACH Payments | Duty-increasing Post Summary Corrections now require electronic payment in full at filing. |
New AD/CVD Investigations | Stainless pipe, citric acid, rebar and other products face significant new or increased trade remedy exposure. |
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
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Author
Ann Karen | Head of Growth
Updated: September 01, 2026
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