THE VIGILANT VIGIL – 29th 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.
Vigil Viewpoint
Among My People
Last week I wrote about returning from CBP’s Trade and Cargo Security Summit in Dallas with a soundtrack running through my head. This week, after the ICPA Global Trade Pathways Conference in Grapevine, I came home with something different: a reminder of just how fortunate I am to have found my people.
And by “my people,” I mean the Trade Nerds.
Those wonderful, slightly unusual human beings who can have an animated conversation over breakfast about tariff stacking, spend lunch debating USMCA rules of origin, sit through an afternoon session on enforcement, and somehow still want to talk about Customs over dinner. These are people who understand why a new CSMS message can ruin your afternoon, why the words “scope determination” can trigger an involuntary facial expression, and why sometimes the only appropriate response to another new tariff is to laugh before you cry.
After the considerably more intense messaging at TCSS the week before, ICPA felt different. The subject matter was every bit as serious. We talked about tariffs, enforcement, audits, USMCA, continuing education requirements, Canada-U.S. trade issues and the seemingly endless complexity confronting importers and exporters. But the environment was warmer, more relaxed and extraordinarily supportive. There is something special about being surrounded by people who understand both the importance of what we do and the occasional absurdity of trying to do it.
That sense of community is not accidental. ICPA was built around it. Elisabeth Sherrell and Victoria Schneider continue to carry forward the extraordinary legacy of Ann Lister into a new era, with co-founder Lynda Thomas still very much part of the family. And then there are people like Dana Poore, who has managed vendors and supported registration for years with the kind of amazing service that most attendees probably take for granted precisely because she makes it look so easy. Anyone who has ever sponsored, exhibited or tried to get several boxes of conference materials where they are supposed to be knows that people like Dana are a huge part of what makes these events work.
As ICPA approaches its 25th year and prepares to celebrate at the 2027 Annual Conference in Orlando, I found myself thinking a lot about what Ann and Lynda created and all the people who continue to nurture it. It is much more than an association or a collection of conferences. It is a community.
And, as usual, ICPA kept me busy.
Between Vigilant and Trabex, we had two booths to set up, staff and somehow pack back into boxes when it was all over. The Voices of Compliance performed twice. We opened the conference with the U.S. National Anthem, and later performed a slightly modified “Deep in the Heart of Texas,” complete with new lyrics about tariff complexity and the strange but wonderful bond that develops when Trade Nerds gather together. The entire room even managed the claps in perfect time, which may have been the most impressive compliance achievement of the conference.
I also had the opportunity to speak twice. On Monday, Bonnie Kersch moderated our Section 338 panel, where I joined Canadian attorney George Reid and American attorney Larry Hanson for a discussion of the increasingly complicated Canada-U.S. trade relationship. I affectionately referred to the attorneys as the “vampires” on the panel because attorneys seem to become strangely energized when regulations, enforcement and litigation get more complicated. I tried to represent the slightly less bloodthirsty practical side: what all of this actually means when somebody has to configure a GTM or brokerage system, file an entry, calculate the tariffs correctly and explain to a business why the rules changed again. We also discussed the broader consequences of the Canada-U.S. dispute, including impacts that reach well beyond Customs entries into tourism, investment and places such as Arizona.
On Tuesday, I presented “Every Export Is Someone Else’s Import.” Following Cindy DeLeon’s excellent discussion of audits and enforcement, I walked through my Seven Bad Decisions: stories about generally well-meaning companies that became complacent, relied on assumptions, failed to verify something or simply did not look deeply enough. None of these companies woke up one morning and decided to create a compliance nightmare. That is precisely the point. Bad outcomes in trade compliance frequently begin with decisions that seemed perfectly reasonable at the time.
It reinforced something I say so often that perhaps I should have it embroidered on a pillow: stay vigilant.
But the sessions are only part of what makes an ICPA conference special. The best education often happens in the hallways, at the booths, over dinner or during the five minutes between sessions when someone says, “Can I ask you something?” Those conversations with peers, competitors, customers and friends are where we compare notes, admit what we don’t know, commiserate a little, laugh a lot and help one another figure out how to navigate whatever the government has thrown at us this week.
For me personally, one of the great pleasures was reconnecting with my old friend Pete Mento. Pete, along with Deep Sengupta, was among the people who encouraged me toward global trade more than 30 years ago. There is something wonderfully circular about standing at an ICPA conference three decades later, still talking about Customs, still learning from each other and, somehow, still enjoying it.
I was also fortunate to have my own support system there. Vigilant CEO Dave Moore and COO Delayne Reamsbottom joined us, along with my “work husband,” Michael Heffernan. And then there was my actual husband, Martin Hennessey, who helped organize volunteers, assisted with registration, monitored sessions, moved boxes and bags, dealt with giveaways and choir logistics, and generally served as my emotional support animal for the duration of the conference.
Every conference speaker should apparently be issued one.
One moment caught me particularly off guard. Elisabeth asked me to sing “God Bless the USA” impromptu at the opening reception. It was one of Ann’s favorite songs, and I will admit that I got emotional. Whatever our individual views about the difficult issues facing our country, standing there among friends and colleagues and thinking about Ann brought back a lot of memories. It was a moment of reflection, gratitude and hope for a country and a profession navigating a complicated time.
There were other reminders that this community extends well beyond those of us who have been doing this for decades. More than 60 university students came through the conference, attending sessions, networking with trade professionals and getting a glimpse of the strange little world some of us have made our careers in. Seeing Professor Chris Hanebeck and others bringing the next generation into these conversations was one of my favorite parts of the week. We need them.
Some of us are getting old. I won’t name names.
ICPA also reminded us that global trade is ultimately about people. We heard about the organization’s new partnership with A21 and its mission to help abolish slavery in the 21st century. We cuddled puppies from a local shelter. We talked about children, grandchildren, pets, hobbies and sports. We remembered friends we lost this year. We remembered Ann. We laughed, sang ridiculous songs, did a little line dancing, had serious conversations and, yes, some people enjoyed a cocktail or two.
Somewhere along the way I also abandoned the suit and tie and ended up wandering around in jeans, cowboy boots, a black choir T-shirt and a very large straw hat.
Frankly, it may have been an improvement.
That combination is what makes ICPA events unique. Our profession deals with enormously serious matters. Companies can lose millions of dollars. Goods can be detained. Supply chains can stop. Penalties can be substantial. Jobs and reputations can be affected. The work deserves to be taken seriously.
But that doesn’t mean we have to take ourselves seriously every minute of the day.
Ann and Lynda understood that from the beginning. They created something where education could coexist with friendship, where competitors could help one another, where serious professionals could sing in a choir, where difficult conversations could happen alongside laughter, and where people who spend most of their working lives explaining incredibly complicated rules could discover that they weren’t doing it alone.
Last week at TCSS, one of the themes I kept hearing was that “We’re All in This Together.” I added an admittedly skeptical “…Aren’t We?” to the title of my article.
After three days in Grapevine with ICPA, I think I found my answer.
Yes. At least among the Trade Nerds, we really are.
And I am extraordinarily grateful to be one of them.
Let’s veer into this week’s Vigil, shall we?
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 # 69851916 – Modifying Section 338 Additional Duties on Certain Goods of Canada
The purpose of this message is to provide guidance on the modifications to the Section 338 Canada duties pursuant to the Presidential Proclamations on Modifying the Scope of Products of Canada Subject to the Additional Duties Imposed to Offset Canadian Discrimination Against the Commerce of the United States with Respect to Alcoholic Beverages and Motor Vehicles issued on September 8, 2026.
CSMS # 69851916 – Modifying Section 338 Additional Duties on Certain Goods of Canada
CSMS # 69902241 – New Error Code for e214 Foreign Trade Zone Submissions Set to Deploy September 17, 2026, and Updates to CATAIR Appendix P and FTZ CATAIR
On September 17, 2026, U.S. Customs and Border Protection (CBP) will implement a new error code for e214 Foreign Trade Zone (FTZ) admissions in the Automated Commercial Environment (ACE) Production environment. This change is currently available in the ACE Certification environment.
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
Significant Foreign Trade Barriers for the 2027 National Trade Estimate Report
| FR Document: 2026-18775 Citation: 91 FR 58247 |
PDF Pages 58247-58250 (4 pages) Permalink |
| Abstract: The Office of the United States Trade Representative (USTR), through the Trade Policy Staff Committee (TPSC), publishes the National Trade Estimate Report on Foreign Trade Barriers (NTE Report) each year. USTR invites comments to assist it and the TPSC in identifying significant foreign barriers to, or distortions of, U.S. exports of goods and services and U.S. foreign direct investment for inclusion in the NTE Report. USTR also will consider responses to this notice as part of the annual… | |
Antidumping or Countervailing Duty Investigations, Orders, or Reviews:
Polyvinyl Alcohol from China and Japan
| FR Document: 2026-18525 Citation: 91 FR 57920 |
PDF Page 57920 (1 page) Permalink |
| Abstract: On the basis of the record developed in the subject five-year reviews, the United States International Trade Commission determines, pursuant to the Tariff Act of 1930, that revocation of the antidumping duty orders on polyvinyl alcohol from China and Japan would be likely to lead to continuation or recurrence of material injury to an industry in the United States within a reasonably foreseeable time. | |
Silicon Metal from Bosnia and Herzegovina, Iceland, Malaysia, and the Republic of Kazakhstan
| FR Document: 2026-18790 Citation: 91 FR 58413 |
PDF Page 58413 (1 page) Permalink |
| Abstract: As a result of the determinations by the U.S. Department of Commerce (Commerce) and the U.S. International Trade Commission (ITC) that revocation of the antidumping duty (AD) orders on silicon metal from Bosnia and Herzegovina, Iceland, and Malaysia, and revocation of the countervailing duty (CVD) order on silicon metal from the Republic of Kazakhstan (Kazakhstan), would likely lead to the continuation or recurrence of dumping, countervailable subsidies, and material injury to an industry in… | |
Certain Steel Racks and Parts Thereof from the People’s Republic of China
| FR Document: 2026-18791 Citation: 91 FR 58416 |
PDF Pages 58416-58418 (3 pages) Permalink |
| Abstract: The U.S. Department of Commerce (Commerce) determines that the exporters under review either sold certain steel racks and parts thereof (steel racks) from the People’s Republic of China (China) in the United States at prices below normal value (NV) during the period of review (POR) September 1, 2023, through August 31, 2024, or have not established their eligibility for a separate rate and are part of the China-wide entity. | |
News from other esteemed sources:
Sandler, Travis & Rosenberg, P.A.
ITC Seeks Input to Define Section 338 Discrimination, Tariff Triggers
STR Trade Report • September 11, 2026
The U.S. International Trade Commission is requesting public comments by Nov. 9 to structure how it identifies and assesses foreign conduct that is “unreasonable or discriminatory” under Section 338 and how such measures burden U.S. commerce. The RFI—following the statute’s recent first use to impose tariffs on Canadian autos, alcohol, and dairy—seeks input on evidence standards, information-gathering methods, and barriers that hinder stakeholders from submitting data. Submissions could shape the criteria and documentation that trigger future Section 338 tariff recommendations across markets.
U.S. bans select Canadian goods, expands 50% Section 338 tariffs
STR Trade Report • September 10, 2026
On Sept. 8, the U.S. issued five proclamations banning imports of certain Canadian alcohol, dairy, and motorcycles effective Sept. 29, while adding 100+ products (and removing 10) from the 50% Section 338 tariff list effective Sept. 15. The moves escalate a dispute that includes 50% tariffs on $20 billion of Canadian imports since Aug. 22 and Canada’s new 15–50% retaliatory duties on hundreds of U.S. goods; Section 338 applies regardless of USMCA origin and in addition to any Section 232 tariffs. Importers should review proclamation annexes to confirm coverage, reprice landed costs, and assess sourcing alternatives.
THOMPSON/HINE
CBP Seeks Comments on Implementation of Executive Order 14411
By Maryam Mahboob, David M. Schwartz, Kristina Shcheglazova* & Scott E. Diamond** on September 11, 2026
On September 2, 2026, U.S. Customs and Border Protection (CBP) published a notice seeking comments by December 1, 2026, on its implementation of several provisions of Executive Order 14411 (“EO 14411”), which mandates the collection of foreign export documentation, the expansion of the requirements for the Customs Trade Partnership Against Terrorism (CTPAT) program, and the integration of technology into supply chain tracing.
CBP Seeks Comments on Implementation of Executive Order 14411 | SmarTrade
BAKER/MCKENZIE
What the New US Trade Landscape Means for Businesses
As US trade policy continues to evolve, businesses are increasingly confronting a reality in which tariffs are not simply temporary trade measures, but a recurring feature of the commercial landscape. This shift is prompting companies to incorporate…
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:
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.
ICPA Annual Spring Conference, March 7 – March 10, 2026
Orlando, Florida, USA
This will be the 25th Anniversary Event for ICPA.
Jamie Adams will be presenting on “Networking for Career Development” and leading the Voices of Compliance Choir in multiple performances.
ICPA Global Trade Insights Conference, April 7 – April 8, 2026
Wembley, England
Jamie Adams will be presenting and also leading the choir.
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: Restricted Party Screening is about more than checking a name against a government list. Effective screening means knowing who you are doing business with, understanding ownership and affiliations, consistently reviewing and adjudicating potential matches, and documenting the due diligence behind your decisions.
🎥 Watch the latest episode:
https://vigilantgts.com/spot-risky-partners-stay-compliant-hb/
Missed a previous episode? Browse the complete Trade Buzz library at:
https://vigilantgts.com/blog/