The Customs Watch USA: Edition 32
š Canada moves from 50% duties to outright import bans, solar duties reach approximately 233%, and new U.S. trade controls hit drones, tin mill products and Russia-bound exports.
The Customs Watch USASummary:Ā This week's edition focuses on major changes affecting Canadian imports, solar products, drones, Chinese tin mill products and Russia-related exports. The United States is moving certain Canadian motor vehicle, dairy and alcohol products from additional duties to outright import bans from 29 September 2026, while a revised Section 338 duty scope takes effect from 15 September. Final AD/CVD determinations on solar cells from India, Indonesia and Laos create potentially extreme combined duty exposure, while new Section 232 duties of up to 100% on drones are already live. The edition also examines a 66.61% preliminary CVD rate on Chinese tin mill products, a $1 million BIS enforcement action involving EAR99 goods exported to Russia, and new AD/CVD investigations into hydraulic cylinders. |

Canada Moves From 50% Duties to Import Bans
The United States has taken its response to certain Canadian trade measures a significant step further.
Under new Section 338 actions, certain Canadian motor vehicle, dairy and alcohol products are scheduled to become prohibited from entering the United States from 29 September 2026.
That is a fundamentally different commercial risk from a tariff increase. A 50% duty changes the economics of an import. An import ban can stop the transaction altogether.
Businesses with Canadian supply chains should now be considering:
Which products are affected?
What inventory is already in transit?
What happens to shipments that arrive around the September 29 cutoff?
Could alternative sourcing be required?
š Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.
Solar Cells Face Potentially Extreme AD/CVD Exposure
The latest U.S. trade-remedy action on solar cells from India, Indonesia and Laos creates a very different kind of customs risk. Commerce has issued final affirmative AD and CVD determinations, with final AD margins reaching 123.04% for India, 94.36% for Indonesia and 65.43% for Laos.
For Indian-origin cells, combined deposits can reach approximately 233%.
The Laos investigation is also significant because imports increased dramatically between 2023 and 2024, highlighting growing scrutiny of Southeast Asian supply routes connected to Chinese solar production.
For businesses sourcing solar products, the issue is no longer simply the headline tariff rate.
It is also about origin, supplier exposure and the structure of the supply chain.
š Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.Ā
Drones Face Duties of up to 100%
New Section 232 duties on unmanned aircraft systems and components are already in force.
Rates range from 10% to 100%, with certain additional component duties scheduled for February 2027.
For businesses importing drones, parts or components, the impact could extend well beyond a routine increase in customs costs. A tariff of up to 100% can fundamentally change the commercial viability of a product, particularly where businesses operate on tight margins or depend heavily on particular sourcing countries.
The new rules also contain specific provisions affecting certain products connected with qualifying Blue UAS and FCC listings.
š Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.Ā
China Tin Mill Products Face 66.61% CVD Deposits
Chinese tin mill products are facing another significant trade-remedy development.
Commerce has made a preliminary affirmative countervailing-duty determination setting a 66.61% ad valorem cash-deposit rateĀ across the covered Chinese producers.
The potential exposure does not end there. A companion anti-dumping determination is scheduled for December 1, 2026, creating the possibility of an additional duty layer.
For businesses importing Chinese tin mill products, this is therefore both an immediate cash-flow issue and a potential future landed-cost problem.
š Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.Ā
EAR99 Does Not Mean Licence-Free
A new BIS enforcement case provides a major warning for businesses exporting goods to Russia. BIS fined an Ohio exporter $1 millionĀ for ten export-control violations involving tooling parts classified as EAR99.
The important lesson is that an EAR99 classification does not automatically mean that no export licence is required. The case involved products whose HTS-6 codes brought them within Russia-specific controls. Party screening also did not identify the problem.
The enforcement action demonstrates why exporters need to look beyond restricted-party screening when assessing Russia-related transactions.
š Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.Ā
New Hydraulic Cylinder Investigations Could Create Major Future Exposure
Commerce has opened new AD and CVD investigations into linear hydraulic cylinders involving Canada, China, India, Korea and Mexico. The alleged dumping margins are substantial, reaching as high as 744.85% for Canada.
No cash deposits are due yet, but the cases could have significant implications for businesses sourcing hydraulic cylinders and related products for manufacturing, construction and agricultural equipment.
This is therefore a development to monitor before the financial impact becomes immediate.
š Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.Ā
Additional Developments This Week
This edition also covers:
New CBP filing guidance implementing the September 15 Canadian Section 338 changes.
New documentation requirements for duty-free U.S. goods returned under HTSUS 9801.00.20 from November 8.
A proposed CBP change to the country-of-origin treatment of outdoor split air conditioning units, with comments due October 9.
New mandatory ACE export manifest requirements for rail cargo.
Two CBP classification changes affecting specific product lines.
Four new Customs-Enforcement Areas covering near-shore waters in South Florida, California, Puerto Rico and the Gulf Coast of Texas.
A proposed withdrawal of the international airport designation of Miami Seaplane Base.
Ā Ā
Overview of This Week's Edition Changes
Topic | Why It Matters |
Canada Import Bans | Certain Canadian motor vehicle, dairy and alcohol products are scheduled to become prohibited from U.S. entry on September 29. |
Canada Section 338 Duties | The 50% duty scope changes from September 15, with new CBP filing requirements. |
Solar AD/CVD | Final determinations create potentially extreme combined duty exposure on affected solar cells. |
Drone Section 232 | Duties of up to 100% are already in force on covered UAS products. |
China Tin Mill CVD | A preliminary 66.61% CVD rate creates immediate potential cash-deposit exposure. |
Russia Export Enforcement | A $1 million BIS penalty demonstrates that EAR99 goods can still require a Russia export licence. |
Hydraulic Cylinders | New AD/CVD investigations create potentially significant future duty exposure. |
9801.00.20 Returned Goods | CBP is changing the documentary basis for duty-free returned U.S. goods. |
Split AC Origin | A proposed origin change could affect Section 301 and trade-remedy exposure. |
Rail ACE Manifests | New electronic export manifest requirements create a future compliance and systems obligation. |
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Author
Ann Karen | Head of Growth
Updated: September 15, 2026
Disclaimer
This article is provided for general informational purposes only and does not constitute legal, customs or tax advice. Businesses should seek professional advice based on their individual trading arrangements and compliance obligations.
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