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The Customs Watch USA: Edition 33

Writer: Annkaren Wambui
Annkaren Wambui
7 hours ago
7 min read

šŸ” CBP can now void IOR numbers for inaccurate Form 5106 data, Canada's 50% Section 338 duty scope has changed, and Chinese tin mill products face a 130.17% AD deposit.

The Customs Watch USA

Summary: U.S. customs and trade policy is evolving, affecting compliance and costs through importer identity requirements, Canada tariffs, trade remedies, and customs classification.Ā This edition covers CBP's new power to void importer-of-record numbers for incorrect Form 5106 data, changes to the 50% Section 338 duty on some Canadian products, a 73.33% CVD order on Algerian steel wire rod, preliminary anti-dumping duties on Indonesian and Malaysian fatty acids, and a 130.17% preliminary AD deposit on Chinese tin mill products. It also addresses proposed supply-chain disclosure requirements, classification changes, a Korean steel CVD remand, a China Section 301 duty opportunity, the increased customs broker permit fee, and the next phase of IEEPA tariff refunds.


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Customs Manager poster showing a CBP officer at a port, U.S. flag, shipping containers, and a VOTED CBP Form 5106.
šŸ‡ŗšŸ‡ø A single Form 5106 error can stop imports, Canada's 50% Section 338 duty scope has changed, and new trade-remedy measures push costs higher on steel, tin mill products and fatty acids.

CBP Can Now Void IOR Numbers for Bad Form 5106 Data

Effective 18 September 2026, CBP can immediately void an importer-of-record number where the associated CBP Form 5106Ā contains inaccurate or incomplete information. The importer-of-record number is fundamental to entering merchandise into the United States. A voided number can therefore prevent an importer from making entries and create significant operational disruption.


CBP's requirements include accurate business contact information, including the physical business address, email and telephone number associated directly with the importer. Brokers must also maintain appropriate powers of attorney directly with the importer.

Businesses should urgently review their active Form 5106 recordsĀ and correct stale, inaccurate or third-party information before it affects an entry.




Canada's 50% Section 338 Duty Scope Has Been Revised

The scope of the live 50% Section 338 additional dutyĀ on certain Canadian-origin alcohol and motor-vehicle products was revised effective 15 September 2026. The changes modify the relevant product lists under HTSUS Note 51 and affect the Chapter 99 reporting requirements for covered merchandise.


The revised rules also clarify that USMCA status does not shield a listed product, while the Section 338 duty can interact with other applicable duties. Importers dealing with Canadian alcohol or motor vehicles should therefore review their classifications and affected entries against the revised product lists and confirm the appropriate Chapter 99 treatment.




Chinese Tin Mill Products Face a 130.17% Preliminary AD Deposit

Commerce has issued a preliminary affirmative anti-dumping determination on tin mill products from China, establishing a 130.17% cash-deposit rateĀ effective upon Federal Register publication.


The China-wide rate is based on a 136.52% weighted-average dumping margin, with the lower cash-deposit rate reflecting subsidy offsets. The measure covers specified HTSUS subheadings and is expected to proceed towards a final determination around 1 December 2026, alongside an ITC injury review.


Importers sourcing Chinese tin mill products should review the affected classifications, assess the new deposit exposure and consider the potential impact on landed costs and sourcing economics.


šŸ‘‰ Download this week's edition of The Customs Watch USA to access the full analysis, practical guidance and expert commentary.



Algeria: 73.33% CVD Order on Steel Wire Rod

Commerce has issued a final countervailing duty order covering carbon and alloy steel wire rod from Algeria, with a 73.33% ad valorem rateĀ applying to the sole respondent and the All Others category.


The measure takes effect upon publication and adds another significant trade-remedy exposure for affected steel imports.




Indonesia and Malaysia: Fatty Acid AD Duties

Preliminary affirmative AD determinations on certain fatty acids from Indonesia and MalaysiaĀ introduce cash-deposit rates of up to 22.96% for IndonesiaĀ and 7.06% for Malaysia.

Final determinations are expected around 5 February 2027, with concurrent CVD investigations and ITC injury reviews underway.




CBP Proposes New Supply-Chain Disclosures

CBP is considering rules that could require importers to disclose supply-chain parties and foreign export documentation.


The proposal is not yet a mandate, but comments are due 1 December 2026. The proposal could significantly increase data and documentation expectations for importers if adopted.




Light Stabilizers Reclassified to Heading 3812

Two hindered amine light stabilizers are being moved to HTSUS 3812.39.60, effective 15 November 2026.


Importers of the affected chemicals should review their classifications and update customs records before the effective date.




China: Kids' Portable Toilets Reclassified

CBP is moving child-sized portable toilets to HTSUS 3924.90.56, effective 15 November 2026.


The change may affect the applicable Section 301 treatmentĀ for China-origin merchandise, making classification review important before the effective date.




Korean Steel Plate CVD Case Remanded

The U.S. Court of International Trade has remanded Commerce's CVD review concerning certain Korean cut-to-length carbon-quality steel plate.


Current rates of 1.47% for Hyundai Steel and 1.61% for Dongkuk Steel MillĀ remain in place pending Commerce's redetermination, but the remand could create a future rate-revision or refund issue.




China: Feed Antibiotic Avoids 25% Section 301 Duty

The Court of International Trade has ruled that feed-grade chlortetracycline concentrateĀ should be classified as an antibiotic rather than an animal-feed preparation.

The reclassification removes the 25% Section 301 exposure previously associated with the product, potentially creating a refund or duty-recovery opportunity for importers of comparable merchandise.




Customs Broker Permit Fee Rises to $190.88

The annual customs broker permit user fee will increase from $185.38 to $190.88Ā effective 1 October 2026.


The change is an annual fee adjustment and does not introduce a new filing requirement or HTSUS change.




IEEPA Refunds: CAPE Phase 3 Opens 6 October

CBP expects CAPE Phase 3Ā to open on 6 October 2026Ā for certain finally liquidated entries subject to Court of International Trade reliquidation orders.


Importers pursuing IEEPA tariff recovery should identify potentially affected entries and consider applicable protest deadlines rather than waiting for the CAPE launch.




Overview of This Week's Edition Changes

Development

Why It Matters

IOR Numbers Voided for Bad 5106 Data

Inaccurate importer information can result in an IOR number being voided and entries being blocked.

Canada Section 338 Scope Revised

Revised product coverage changes exposure to the 50% additional duty on certain Canadian goods.

Algeria Steel Wire Rod CVD

A 73.33% countervailing duty creates significant new exposure for affected imports.

Indonesia/Malaysia Fatty Acids

Preliminary AD deposits reach up to 22.96% for Indonesia and 7.06% for Malaysia.

China Tin Mill Products

A preliminary 130.17% AD cash deposit creates major potential landed-cost exposure.

Supply-Chain Disclosures

Proposed CBP rules could expand importer data and foreign-documentation obligations.

Classification Changes

Chemical stabilizers and child-sized portable toilets face new classifications from 15 November.

Korean Steel Plate CVD

Court remand could result in revised rates and potential refund implications.

China Feed Antibiotic

A classification ruling may remove 25% Section 301 exposure for comparable merchandise.

CAPE Phase 3

The IEEPA refund pathway for qualifying finally liquidated entries is expected to open 6 October.


The free edition gives you the headline: What changed. Who is affected. Why it matters.

The Full Technical AnalysisĀ provides the detail needed to assess the implications for your organisation, including:

āœ” Specific HTSUS classifications and Chapter 99 codes

āœ” Trade-remedy rates and affected countries

āœ” Effective dates and implementation deadlines

āœ” Importer-of-record and Form 5106 requirements

āœ” Supply-chain disclosure proposals

āœ” Classification and Section 301 implications

āœ” Refund and reliquidation opportunities

āœ” Department-level implications for Trade Compliance, Finance, Sourcing and Legal

āœ” Official regulatory sources and case references



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Author:Ā 

Ann Karen | Head of Growth

Updated:Ā September 22, 2026


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