THE VIGILANT VIGIL – 23rd EDITION
Welcome, visitor, to the Vigil. Here you will find a summation of current global trade changes and regulatory updates. We aim to deliver helpful insights in a timely and relevant manner, to help you remain vigilant in an ever-evolving trade environment.
The Editing Director (T.E.D.)’s Foreword:
Last week, I spent some time in Alberta, Canada, working remotely while also carving out a few days to reconnect with family and friends. One of the highlights was a long weekend camping in the Canadian Rockies—a welcome chance to trade conference rooms and customs rulings for mountain views, hiking trails, and fresh mountain air… at least when the wildfire smoke decided to cooperate.
As it turns out, global trade has an uncanny ability to follow you wherever you go.
Almost everywhere I went, someone eventually asked the same question:
“What’s going on in the United States?”
What struck me wasn’t just the question—it was who was asking it. These weren’t customs brokers, trade attorneys, or compliance professionals. They were teachers, nurses, entrepreneurs, electricians, museum directors, librarians, artists, web designers, retirees, and small business owners. Ordinary Albertans simply trying to understand the headlines and what they might mean for their jobs, their families, and the future of Canada.
The conversations themselves were fascinating. Canadians, much like Americans, are hardly a monolithic group. I met Albertans who passionately support provincial independence. Others believe Alberta would be better off joining the United States. Still others are fiercely proud Canadians who believe their future remains firmly within Canada. I also had thoughtful conversations with Indigenous Canadians whose concerns centered not on politics, but on how any constitutional changes might affect longstanding treaty rights and commitments.
After several of these discussions, I realized something that applies equally to all of us in global trade. My role wasn’t to persuade anyone to adopt my political opinions. Frankly, my personal politics aren’t what matter here. My responsibility—as someone who has spent nearly three decades in global trade—is to help people understand “why” governments make the decisions they make. Whether we agree with those decisions is a separate discussion. If we fail to understand the motivations behind them, however, we’ll struggle to anticipate where trade policy is headed next.
One of the recurring questions I received was, “Why all the tariffs?” That’s a fair question, and regardless of political persuasion, it’s worth understanding the administration’s stated objectives. America First policies are aimed at strengthening domestic manufacturing, encouraging investment back into the United States, reducing reliance on foreign supply chains for strategically important goods, and using tariffs as both an economic incentive and a negotiating tool. Layer on concerns around national security, forced labor, sanctions, and critical minerals, and it becomes easier to understand why trade has moved to the center of economic policy.
Whether you agree with those objectives or not is ultimately a personal decision. As trade professionals, however, our responsibility is not to debate the politics nearly as much as it is to understand the policy. The better we understand the “why”, the better we can anticipate the “what”.
This week’s Vigil reflects exactly that reality. The Federal Register continues to fill with new antidumping and countervailing duty actions, sanctions, Section 301 and 232 developments, export control changes, and enforcement initiatives. None of these are isolated events. They are all pieces of a much larger geopolitical and economic puzzle.
A longtime friend and mentor, Pete Mento, has often said, “Follow the economics. Follow the money.” I couldn’t agree more. I would simply add one more thought: “follow the motivations”. Economics explains much of what governments do, but national security, geopolitics, labor concerns, and the pursuit of strategic influence often explain “why” those economic tools are chosen.
We don’t have to like every change. We don’t even have to agree with every policy. But if we’re going to advise our companies well, we need to understand the forces driving them. Trade no longer exists in a vacuum. Politics influences economics. Economics influences trade. And trade touches every one of us.
The better we understand the motivations behind today’s decisions, the better prepared we’ll be for tomorrow’s regulations.
Stay vigilant.
Jamie Adams
Director of Global Compliance Solutions
Vigilant Global Trade Services
In this volume, we will explore:
- CSMS updates
- Updates to the Federal Registry, for both policy and product
- Cooperative call outs to other blogs
- Where to find us
- Be sure to check out our weekly edition of Trade Buzz
Let’s veer into it, shall we?
**The following contains links and citations from multiple US government agencies and other credible sources. Vigilant GTS LLC is not the source material but simply compilating the information.**
CSMS Updates
**The following are short summaries of the actual information provided by CSMS. To stay up to date with announcements and news, please subscribe at: https://www.cbp.gov/webform/subscribe-receive-cbp-access-updates **
CSMS # 69395344 – GUIDANCE: Section 232 Duties on Imports of Patented Pharmaceutical Articles and Ingredients
The purpose of this message is to provide guidance on the implementation of the April 2, 2026, Presidential Proclamation 11020, Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients Into the United States. CSMS # 69395344 – GUIDANCE: Section 232 Duties on Imports of Patented Pharmaceutical Articles and Ingredients
CSMS # 69415934 – GUIDANCE: Reduction of Tariffs on Patented Pharmaceuticals and Pharmaceutical Ingredients for Products of the United Kingdom Implemented by Presidential Proclamation 11020
This message provides guidance regarding the reduction of tariffs on patented pharmaceuticals and associated pharmaceutical ingredients that are products of the United Kingdom amending Presidential Proclamation 11020, “Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients Into the United States.” CSMS # 69415934 – GUIDANCE: Reduction of Tariffs on Patented Pharmaceuticals and Pharmaceutical Ingredients for Products of the United Kingdom Implemented by Presidential Proclamation 11020
CSMS # 69428352 – Modifications to the Processing of Post Summary Corrections
The purpose of this message is to announce modifications to the processing of Post Summary Corrections (PSCs). These modifications were announced in Federal Register Notice 91 FR 41053, “Modification and Clarification of the National Customs Automation Program Test Regarding Post Summary Corrections” issued July 6, 2026. CSMS # 69428352 – Modifications to the Processing of Post Summary Corrections
Federal Register Updates
**These are just a sampling of the many updates and changes made by the Federal Register. For a more comprehensive list, or to subscribe to the updates yourself, follow the link below, and never miss a thing.** https://www.federalregister.gov
Notices
Implementation of Duties on Additional Aluminum, Steel, and Copper Derivative Articles under Section 232
| FR Document: 2026-15961 Citation: 91 FR 50756 | PDF Pages 50756-50758 (3 pages) Permalink |
| Abstract: This notice requests public comments on a proposal to include 14 additional derivative articles within the scope of the Section 232 duties on steel, aluminum, and copper: aluminum powder; brass-wind musical instruments and their parts and accessories; parts of welding machines and apparatus; floor safes; certain electric conductor cables; fire extinguishers; parts of heat exchange units; parts of certain hydraulic engines and motors; certain self-propelled cranes, mobile lifting frames, and… | |
Free Trade Agreements
| FR Document: 2026-15610 Citation: 91 FR 48912 | PDF Pages 48912-48913 (2 pages) Permalink |
| Abstract: The Department of Homeland Security, U.S. Customs and Border Protection (CBP) will be submitting the following information collection request to the Office of Management and Budget (OMB) for review and approval in accordance with the Paperwork Reduction Act of 1995 (PRA). The information collection is published in the Federal Register to obtain comments from the public and affected agencies. | |
Customs User Fees to Be Adjusted for Inflation in Fiscal Year 2027
| FR Document: 2026-15530 Citation: 91 FR 48398 | PDF Pages 48398-48400 (3 pages) Permalink |
| Abstract: This document announces that U.S. Customs and Border Protection (CBP) is adjusting certain customs user fees and corresponding limitations established by the Consolidated Omnibus Budget Reconciliation Act (COBRA) for Fiscal Year 2027 in accordance with the Fixing America’s Surface Transportation Act (FAST Act) as implemented by the CBP regulations. | |
Sanctions Action (1 document of 8, in the last 7 days)
| FR Document: 2026-15522 Citation: 91 FR 48481 | PDF Page 48481 (1 page) Permalink |
| Abstract: The U.S. Department of State is publishing the names of persons who have been added to the Department of the Treasury’s List of Specially Designated Nationals and Blocked Persons (SDN List), administered by the Office of Foreign Assets Control (OFAC) based on the Secretary of State’s determination pursuant to and in accordance with the referenced authority that one or more applicable criteria were satisfied. All property and interests in property subject to U.S. jurisdiction of the designated… | |
Imposition of Nonproliferation Measures Against Foreign Persons, Including a Ban on U.S. Government Procurement
| FR Document: 2026-15759 Citation: 91 FR 49481 | PDF Pages 49481-49482 (2 pages) Permalink |
| Abstract: A determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to the Iran, North Korea, and Syria Nonproliferation Act (INKSNA). | |
Antidumping or Countervailing Duty Investigations, Orders, or Reviews: Mattresses from Cambodia, Malaysia, Serbia, Thailand, the Republic of Turkiye, and the Socialist Republic of Vietnam
| FR Document: 2026-15471 Citation: 91 FR 48370 | PDF Pages 48370-48371 (2 pages) Permalink |
| Abstract: The U.S. Department of Commerce (Commerce) finds that revocation of the antidumping duty (AD) orders on mattresses from Cambodia, Malaysia, Serbia, Thailand, the Republic of T[uuml]rkiye (T[uuml]rkiye) and the Socialist Republic of Vietnam (Vietnam), would be likely to lead to continuation or recurrence of dumping, at the levels indicated in the “Final Results of Sunset Reviews” section of this notice. | |
Linear hydraulic cylinders from Canada, China, India, Mexico, and South Korea
| FR Document: 2026-15722 Citation: 91 FR 49442 | PDF Pages 49442-49443 (2 pages) Permalink |
| Abstract: The Commission hereby gives notice of the institution of investigations and commencement of preliminary phase antidumping and countervailing duty investigation Nos. 701-TA-802-804 and 731-TA-1799- 1803 (Preliminary) pursuant to the Tariff Act of 1930 to determine whether there is a reasonable indication that an industry in the United States is materially injured or threatened with material injury, or the establishment of an industry in the United States is materially retarded, by reason of… | |
News from other esteemed sources:
THOMPSON/HINE
DHS Updates UFLPA Entity List with 43 Additional Chinese Companies By Scott E. Diamond**, Francesca M.S. Guerrero & Samir D. Varma on July 31, 2026 On July 31, 2026, the Department of Homeland Security (DHS) announced the addition of 43 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to 187 entities. Effective August 3, 2026, U.S. Customs and Border Protection (CBP) will apply a rebuttable presumption that goods produced by these 43 entities are prohibited from entering the United States as a result of the companies’ activities… DHS Updates UFLPA Entity List with 43 Additional Chinese Companies | SmarTrade
BRAUMILLER
A New Era of Trade Fraud Enforcement
By: Adrienne Braumiller, Partner & Founder, Braumiller Law Group
The new DHS/DOJ Trade Fraud Resource Guide should resonate across the trade ecosystem, especially for importers, Customs brokers, and in-house counsel.
What makes the Guide so notable is not just the substance, but the framing. Trade fraud is no longer being discussed as a narrow customs issue or a technical filing problem. It is being presented as an economic security issue, a public safety issue, a supply chain integrity issue, and a forced labor issue. That shift has practical consequences for everyone involved in moving goods into the United States.
The Trade Fraud Resource Guide should resonate
ST&R
Class Action Challenges 10–12.5% Section 301 Forced‑Labor Tariffs
STR Trade Report • July 31, 2026
A class-action filed at the U.S. Court of International Trade seeks to invalidate the Trump administration’s Section 301 duties of 10–12.5% on imports from 86 countries, alongside a parallel individual suit by companies that previously prevailed against the IEEPA tariffs. Plaintiffs argue USTR exceeded Section 301’s country- and practice-specific authority and that, absent such limits, the regime would unconstitutionally delegate Congress’s tariff power; they also call the action arbitrary and capricious, citing rushed investigations, near-uniform rates mirroring IEEPA, coverage tied to import value, and a lack of record-based, country-specific rationale. A favorable ruling could unwind broad duties, enable potential refund opportunities for eligible entries, and force a recalibration of USTR’s forced-labor trade strategy. Read Full Article
TI-AI
To stay even better informed about the goings on of the trade world, check out Trade Insights, and follow their weekly newsletter at: cdn.forms-content-1.sg-form.com/77528e12-73c1-11f0-bfe0-6a5b9e3a747e
Vigilant Visitation Opportunities
We will be out and about at different trade and compliance related conferences around the country! We would love for you to come to say hello, so we can get to know you better! You can also connect with us at: https://vigilantgts.com/ or through our socials, on Facebook and LinkedIn!
Where we will be:
CBP Trade and Cargo Security Summit, (Rescheduled to September, 8-10, 2026)
Dallas, TX
Jamie Adams will be attending sessions and happy to connect with you.
ICPA Global Trade Pathways Conference (Fall), September 13, 2026
Grapevine, TX
Vigilant will be a sponsor and you can visit us at our booth. Jamie Adams will be presenting and leading the choir.
ICPA Global Trade Insights Conference (Fall), September 29 – October 1, 2026
Dublin, Ireland
Jamie Adams will be moderating a panel on US Tariff Updates and Mitigation Strategies.
ICPA Mexico Conference, November 3 – November 5, 2026
Mexico City, Mexico
Jamie Adams will be moderating a panel on USMCA Enforcement and Verifications.
TRADE BUZZ – Powered by Vigilant GTS
Trade never stands still—and neither do we.
Every Tuesday, we publish a new Trade Buzz episode highlighting timely developments in customs, tariffs, export controls, sanctions, compliance, and global trade. Our goal is simple: provide practical, easy-to-understand insights that help you stay informed and prepared. This week’s topic: No one should blindly trust the internet, social media or artificial intelligence. It is crucial that we Trust But Verify or possibly even Verify and Then Trust.
🎥 Watch the latest episode: https://vigilantgts.com/avoid-penalties-trust-then-verify-hb/
Missed a previous episode? Browse the complete Trade Buzz library at: https://vigilantgts.com/webinars/