The Customs Watch USA: Edition 31
- Annkaren Wambui
- Sep 8
- 7 min read
š Canada faces 50% duties, drones up to 100%, and CBP tightens importer and copper filing requirements.
The Customs Watch USASummary:Ā This week's edition focuses on a series of developments that can directly affect whether goods clear the border and what they cost. The United States has implemented new 50% Section 338 duties on covered Canadian goods, new Section 232 tariffs of up to 100% on drones and related products, and is preparing to enforce importer-of-record data accuracy from 18 September 2026. The edition also examines a tighter origin test affecting the U.S.-Bahrain FTA, new fatal ACE rejection rules for copper entries, a proposed CBP supply-chain visibility regime, temporary quota opportunities for lean beef trimmings and new trade-remedy developments. |
Canada's 50% Duties Are Live and USMCA Does Not Provide Automatic Protection
The United States has now deployed the new Section 338 tariff records into ACE, placing an additional 50% ad valorem dutyĀ on covered Canadian goods. For affected importers, one of the most important points is that USMCA qualification does not automatically shield a listed product from the new duty. The correct Chapter 99 reporting requirements must also be followed.
The same update introduces changes to FSIS Partner Government Agency flags affecting certain egg and food-preparation tariff lines, creating additional filing decisions and data requirements at entry.
Businesses importing affected Canadian products should immediately review:
Whether their products are covered by the new Section 338 measures.
The applicable Chapter 99 reporting requirements.
Whether their current USMCA assumptions remain valid.
New FSIS PGA requirements affecting relevant food and egg products.
For some importers, the change is both a tariff problem and an entry-filing problem.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
Drones Face Duties of up to 100%
New Section 232 duties ranging from 10% to 100%Ā on covered unmanned aircraft systems and components took effect on 3 September 2026.
The potential impact goes beyond a marginal increase in landed cost. For businesses importing affected drones, parts or components, the new rates can fundamentally change the commercial viability of a product line.
Businesses involved in affected products should review:
Product classification.
Scope of the new measures.
Supplier and country exposure.
Current landed-cost calculations.
Pricing and sourcing strategies.
A tariff of up to 100% is not simply another customs cost. For some products, it can rewrite the entire business case.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
Your Importer Number Could Be Void from 18 September
One of the most operationally significant developments this week is CBP's upcoming enforcement of importer-of-record data accuracy requirements. From 18 September 2026, CBP may void an importer-of-record number where information submitted through Form 5106Ā is inaccurate. This can include incorrect names, EINs or SSNs, physical addresses, email addresses and telephone numbers. The physical address must belong directly to the importer and cannot simply be a broker, freight forwarder, registered agent, P.O. box or business service centre.
A voided importer number could prevent the business from filing entries and importing goods.
Businesses should now review:
Form 5106 information.
Physical addresses.
Contact details.
EIN and identity information.
Broker relationships and Powers of Attorney.
This is not a future policy discussion. A data problem can become a cargo-release problem from 18 September.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
Free-Trade Origin Rules Face a Tougher Test
A recent Court of International Trade ruling involving the U.S.-Bahrain Free Trade AgreementĀ has invalidated CBP's tariff-shift regulation for determining whether certain third-country input costs count towards the agreement's value-content requirement. The court concluded that the applicable statutory test requires double substantial transformationĀ rather than relying on a single tariff classification change. The decision could create denied preference claims and potential back-duty exposure for businesses relying on the previous approach.
This week's edition examines:
What the court decided.
Why the tariff-shift approach was rejected.
The double substantial transformation test.
Which origin claims may require reassessment.
Potential implications for businesses relying on preferential tariff treatment.
An FTA preference claim is only as strong as the origin methodology supporting it.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
Copper Entries Face Fatal ACE Rejections from 14 September
From 14 September 2026, ACE will issue a fatal error for covered copper entries that do not include the required primary country of smelt and country of castĀ information. The reporting requirement already exists, but the system will now stop accepting non-compliant entries. That means missing data can result in an outright entry rejection rather than simply creating a later compliance issue.
Businesses importing covered copper articles should ensure that:
Suppliers can provide smelt information.
Country-of-cast information is available.
Trade systems can populate the required data fields.
Brokers receive the information before filing.
For affected copper imports, supplier data quality will now determine whether the entry can be accepted.
š Download this week's edition of The Customs Watch USAĀ to access the full analysis, practical guidance and expert commentary.
CBP Wants Greater Visibility Across the Entire Supply Chain
CBP has published an advance notice of proposed rulemaking that could significantly expand the information importers are expected to maintain about their supply chains.
The proposal would move towards visibility covering parties throughout the transaction; from the foreign manufacturer through intermediaries and potentially to the final delivery address.
The proposal is not yet a binding requirement, but it provides a clear indication of the direction of U.S. customs enforcement: more data, more traceability and greater accountability for the information behind an import transaction.Ā
Businesses should consider:
Mapping existing supply-chain visibility.
Identifying information gaps.
Reviewing the proposed requirements.
Considering whether to submit comments.
Tomorrow's customs compliance requirements may depend increasingly on information that companies are not currently collecting today.
Additional Developments This Week
This edition also covers:
A temporary quota increase for lean beef trimmings, creating a time-limited opportunity for eligible importers to secure in-quota treatment.
Preliminary 10.17% countervailing duties on Austrian OCTG steel pipe, creating immediate cash-deposit exposure for affected imports.
A proposed duty-refund opportunity involving entries that paid both AD/CVD and IEEPA tariffs, with oral argument scheduled for 15 September.
New mandatory CPSC eFiling requirements for international mail shipments from 22 October 2026.Ā
The 2027 dairy tariff-rate quota import licence fee of $325 per licence.Ā
Developments involving UFLPA listings, Chinese tyre entries, UAE steel pipe and other trade-remedy actions.
Overview of This Week's Changes
Topic | Why It Matters |
Canada Section 338 Duties | New 50% additional duties are live in ACE for covered Canadian goods. USMCA qualification does not automatically remove the exposure. |
Drone Section 232 Tariffs | Duties of up to 100% are now in force on covered unmanned aircraft systems and components. |
Importer Number Enforcement | CBP may void inaccurate importer-of-record numbers from 18 September, potentially stopping customs entries. |
Bahrain FTA Origin | A court ruling has tightened the origin test for certain third-country inputs and may affect preferential duty claims. |
Copper ACE Reporting | Missing smelt and cast information will trigger fatal entry rejection from 14 September. |
CBP Supply-Chain Visibility | A proposed rule could significantly expand the information importers must maintain about parties across the supply chain. |
Lean Beef Quota | A temporary, first-come quota opportunity is available through 30 November for eligible lean beef trimmings. |
Austrian OCTG Steel | Preliminary 10.17% CVD creates immediate cash-deposit obligations for affected imports. |
CPSC Mail eFiling | New mandatory eFiling requirements begin for covered international mail shipments on 22 October. |
AD/CVD Refund Litigation | A pending court motion could potentially create future refund opportunities for certain entries that also paid IEEPA tariffs. |
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Whether your business imports goods into the United States, manages global supply chains, works with customs brokers or is responsible for trade compliance, The Customs Watch USAĀ helps you monitor the developments that can affect your transactions.
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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 08, 2026
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