Expeditors (EXPD) Status update summary

Key trade and customs developments

• Section 338 introduces new tariffs and outright import bans, with implementation dates set in advance and high rates, signaling a more aggressive trade remedy approach, especially targeting Canada but with broader product coverage than just alcoholic beverages, dairy, and motor vehicles.

• Importers are advised to check updated HTS lists, consider FTZ admissions or in-bond warehousing to manage duty payments, and ensure timely entries before bans take effect.

• New Russian sanctions impose up to 500% tariffs on goods from countries facilitating Russian oil trade, with implementation details pending; importers should review sourcing for exposure.

• Section 232 pharma updates include new zero-rate categories and HTS changes, with exclusions available for urgent health needs, requiring company-specific applications.

Legal and regulatory challenges

• Ongoing legal battles over IEEPA and other tariff programs impact refund processing, with phase III refunds limited to importers who filed in the Court of International Trade.

• Importers are encouraged to quantify potential refunds, consider protests to preserve rights, and be aware of filing deadlines for legal actions.

• Additional trade actions and comment periods are open, including FCC import restrictions and USITC discrimination definitions for Section 338.

Enforcement and compliance trends

• Customs enforcement is intensifying, with a shift toward more detailed and frequent CF-28 and CF-29 requests, often leveraging AI and data analytics to scrutinize supply chains and origin claims.

• Importers must be prepared to provide extensive documentation, map supply chains beyond Tier 1, and respond promptly to enforcement communications.

• CBP Form 5106 updates now require stricter verification, and inaccurate information can result in voided importer numbers.