THE VIGILANT VIGIL – 26th 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:
Don’t Let Conflict Become the Operating System
Some weeks make it very tempting to turn off the news, close social media, silence the phone, avoid humanity altogether and hope the world sorts itself out without us.
This may have been one of those weeks.
The United States implemented its new Section 338 tariffs against certain Canadian goods, and Canada promptly announced countermeasures of its own. Trade professionals had precious little time to get new tariff requirements into systems and entry processes. We continue to see new enforcement guidance, investigations, forced labor requirements and regulatory changes. Outside of trade, natural disasters, wars, political conflict and a particularly sad week of losses in the entertainment world have added to the general sense that there is an awful lot coming at us all at once.
And, because apparently the universe likes a theme, I had a few conflicts of my own this week. Nothing requiring a Federal Register notice, thankfully, but enough frustrating conversations, competing priorities, deadlines and personalities to leave me thinking about how much of our energy is spent battling things we either cannot control or cannot change by simply pushing harder.
That may be the more important issue.
Conflict itself is not unusual. What worries me lately is how quickly conflict becomes the default operating system. Governments retaliate against governments. Political parties attack the other side. Coworkers defend their territory. Consultants defend their recommendations. Companies blame brokers. Brokers blame importers. Importers blame the government. Someone says something ugly on social media and suddenly everyone is choosing teams.
Meanwhile, the actual problem is still sitting there waiting to be solved.
The U.S. and Canada are a perfect example. Our governments may currently be engaged in an increasingly contentious tariff dispute, but millions of Americans and Canadians remain coworkers, customers, suppliers, friends and family. I happen to be married to a Canadian. I have Canadian family and friends whom I love dearly. A tariff proclamation does not suddenly make them my adversaries, nor does Canada’s response make me theirs.
We need to remember how to separate disagreement from disrespect.
That applies equally inside our organizations. We do not have to agree with every regulatory policy, executive decision, consultant recommendation, technology strategy or colleague’s opinion. But if our first response is defensiveness, finger-pointing or digging trenches around our position, we usually make the problem harder to solve.
Trade compliance, perhaps more than most professions, requires us to live in the world as it actually exists. We may not like a new tariff, but we still need to determine how it applies. We may disagree with an enforcement policy, but we still need to build a compliant response. We may have concerns about Artificial Intelligence, but refusing to engage with it while governments and competitors embrace increasingly sophisticated technology is probably not a sustainable strategy.
Our job is not always to explain why something shouldn’t be happening.
Often, our job is to ask: Given that it IS happening, what can we do about it?
That means understanding what we can control and what we cannot. Where we have influence, we should use it. Fix the process. Correct the data. Improve the system. Train the people. Challenge an assumption. File the protest. Ask the question. Escalate the legitimate concern.
Where we do not have control, perhaps the better response is to adjust our approach rather than repeatedly charging into the same wall.
I keep thinking about leaders from very different political traditions who managed to work together despite profound disagreement. Senator Ted Kennedy and Senator John McCain certainly did not share the same political worldview, yet they built a genuine friendship and worked together on legislation because both understood that governing sometimes required conversation, negotiation, compromise and respect.
We could use a little more of that spirit, not merely in politics, but in business and in life.
This is also something I am reminding myself this week. I am not always the calm person observing the storm from a safe distance. Sometimes I am standing right in the middle of it, annoyed, defensive and convinced that if everyone would simply listen to me the problem would be solved. Imagine that. 😄
Sometimes the best thing we can do is step away from the argument long enough to determine what actually matters. Protect appropriate boundaries, certainly. Do not tolerate bullying, dishonesty or abusive behavior. But boundaries are different from walls. The objective should still be to find a productive path forward whenever one exists.
There are plenty of difficult things in the world right now. There are also plenty of good things. I work with people of tremendous integrity who genuinely want to do the right thing. I have colleagues throughout this industry who have become family. I am preparing for several ICPA conferences that will undoubtedly exhaust me, but will also put me in rooms full of people I respect, enjoy and learn from. I recently had an art event that didn’t draw the crowd I hoped for, but the people who did attend were generous, supportive, and included friends I had not seen in years. And while Phoenix may currently feel like someone accidentally left the oven door open at 115 degrees, I have air conditioning and a sturdy home to retreat to when the haboobs arrive.
Both things can be true.
The world can be difficult, and life can still be good.
People can disagree, and still respect one another.
Trade policy can become adversarial without trade professionals becoming adversaries.
We can call problems exactly as we see them without allowing conflict to consume us.
So perhaps that is my advice to myself, and anyone else who needs it this week: focus your energy on what you can influence, approach what you cannot with perspective, and whenever possible, look for the common ground where something productive can actually happen.
Because there will be another tariff next week. Another regulation. Another disagreement. Another personality that tests our patience.
We might as well get better at working through them together.
Now, let’s veer into this week’s Vigil.
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 # 69606660 – GUIDANCE: Section 338 Additional Duties on Certain Goods of Canada
The purpose of this message is to provide guidance on the implementation of the July 20, 2026, Presidential Proclamations on Imposing Additional Duties to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Alcoholic Beverages, Dairy, and Motor Vehicles.
CSMS # 69606660 – GUIDANCE: Section 338 Additional Duties on Certain Goods of Canada
CSMS # 69647661 – Update to AESTIR Appendix A – Commodity Filing Response Message 802
At the request of the Bureau of Industry and Security (BIS), Customs and Border Protection (CBP) will set AESTIR Commodity Response Code 802 to Fatal on September 25, 2026. The code is currently set to Verify. Once set to Fatal, the EEI will be rejected; the EEI must be corrected for the submission to be accepted.
CSMS # 69647661 – Update to AESTIR Appendix A – Commodity Filing Response Message 802
CSMS # 69668138 – Updated Guidance: Entry Summary Order of Reporting for Multiple HTS when 98 or 99 HTS are Required
The purpose of this message is to update the order of reporting in ACE to report multiple Harmonized Tariff Schedule of the United States (HTSUS) classifications for an article on the same entry summary line when a Chapter 98 or 99 HTSUS classification is required and/or applicable. ACE is the system of record for all entry summaries.
CSMS # 69647683 – REMINDER: ACE User Satisfaction Survey – Your Input Matters!
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
Agency Information Collection Activities; Proposals, Submissions, and Approvals:
Procedures for Submissions by Certain Steel and Aluminum Producers Committing to New U.S. Steel or Aluminum Production to Obtain Tariff Adjustments under Proclamation 10984
| FR Document: 2026-17155 Citation: 91 FR 54308 |
PDF Pages 54308-54309 (2 pages) Permalink |
| Abstract: On October 17, 2025, the President issued Proclamation 10984 (Adjusting Imports of Medium- and Heavy-Duty Vehicles, Medium- and Heavy-Duty Vehicle Parts, and Buses Into the United States) (90 FR 48451), finding that imports of medium- and heavy-duty vehicles (MHDVs), medium- and heavy-duty vehicle parts (MHDVPs), and buses threaten to impair the national security of the United States, and determining that it is necessary and appropriate to impose specified tariffs to adjust imports | |
Investigations; Determinations, Modifications, and Rulings, etc.:
Linear Hydraulic Cylinders from Canada, China, India, Mexico, and South Korea
| FR Document: 2026-17367 Citation: 91 FR 55112 |
PDF Pages 55112-55113 (2 pages) Permalink |
| Abstract: On July 29, 2026, the Commission established a schedule for the conduct of the final phase of the subject investigations (91 FR 49442, August 4, 2026). Subsequently, the Department of Commerce (“Commerce”) extended the deadline for its initiation determination to September 8, 2026 (91 FR 53848, August 20, 2026). The Commission, therefore, is revising its schedule to conform with Commerce’s new schedule. | |
News from other esteemed sources:
BAKER/MCKENZIE
United States Imposes Section 338 Duties on Canadian Goods
The United States has imposed additional 50% duties on certain Canadian-origin imports pursuant to Section 338 of the Tariff Act of 1930, marking the first use of a rarely invoked authority in decades. The duties, which took effect on imported…
Read more…
Canada Announces New Counter-Tariffs Following Suspension of Canada-U.S. Trade Negotiations
On August 25, 2026, the Government of Canada announced a new package of trade countermeasures and financial support programs in response to recent U.S. tariff actions. The announcement follows Canada’s decision to suspend trade negotiations…
Read more…
EU publishes guidelines on the application of the EU Forced Labour Regulation
On 26 June 2026, the European Commission published its long-awaited guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market (the “Guidelines”), available here. The Guidelines are…
Read more…
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: Trade savings can be significant, but only if you know what opportunities are available and can confidently support the claims you make. From Free Trade Agreements and special trade programs to tariff exclusions, duty mitigation strategies, drawback and reconciliation, companies should be looking carefully at where they may be leaving money on the table. The key is not simply finding the savings. It is making sure you have the data, documentation and compliance processes to defend them.
🎥 Watch the latest episode:
https://vigilantgts.com/confidently-claim-your-trade-savings-hb/
Missed a previous episode? Browse the complete Trade Buzz library at:
https://vigilantgts.com/webinars/