THE VIGILANT VIGIL – 30th 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:

Coming up with something new to say every week is harder than it looks. This is the 30th edition of the Vigilant Vigil, and apparently when we started this little experiment nobody thought to tell the Editing Director that eventually he would have to write thirty bloomin’ forewords.

Some weeks the subject practically writes itself. Customs drops something enormous into the Federal Register, somebody invents another tariff, CBP gives us seventeen minutes to reconfigure the global trading system, or I return from a conference with a soundtrack running through my head. Other weeks, I stare at the screen.

This was one of those weeks. Part of the problem may simply be that I am tired.

The last few weeks have been extraordinary. I drove across Texas and back, with the frequent stops and walkabouts my doctor requires, lived out of a suitcase, tried not to survive entirely on restaurant food, ran conference errands, set up two booths, spoke twice, sang twice, met hundreds of people and tried to remain permanently switched into Sales/Marketing/Trade-Nerd mode. At the same time, CBP, DHS, Commerce, DOJ and seemingly everyone else with access to the Federal Register kept sending us a deluge of information that was often predictable, but no less serious or consequential because we saw it coming.

I eventually made my way home, with a wonderful respite visiting friends in El Paso and even squeezing in a cave tour, because apparently my response to exhaustion is recreational geology. Then it was home just long enough to pay bills, deal with some monsoon damage, refill prescriptions, do laundry, celebrate my husband’s birthday, work on art for an October gallery exhibition, repack the suitcase and prepare for the next ICPA conference in Dublin.

I realize how ridiculous this can sound. Poor Jamie. He has to go to Ireland. Queue the small violin…

I am not complaining about the life I have. Quite the opposite. I am extraordinarily fortunate. I have work I genuinely enjoy, brilliant and compassionate people around me, opportunities to travel, art and music and friends and family, and people keep handing me microphones despite considerable evidence that this may be unwise. I know how lucky I am.

But I realized something this week: gratitude and exhaustion are not mutually exclusive.

And that realization arrived from an unexpected source.

Barbie.

There is a wonderful scene in the film in which America Ferrera’s character, Gloria, finally unloads about the contradictory expectations placed on women. You have to succeed, but succeed correctly. Be strong, but vulnerable. Stand out, but fit in. Be grateful. Never fail. Eventually she says, “It’s too hard! It’s too contradictory.”

If you haven’t seen the scene, it is worth a few minutes:

https://youtu.be/CBqlDWHkdHk?si=lpdOPSKPPPcd6Q2f

I want to acknowledge the obvious: I am not comparing my experience as a white man with an enormously privileged life to the historical and continuing expectations, discrimination and inequities experienced by women. That is the context of Gloria’s speech, and it matters. But that is also one of the beautiful things about art. A painting, song, book or film can tell someone else’s very specific story and still give us language to understand something happening in our own lives.

This week, I had a little bit of a Barbie moment.

When I began this experiment in December 2025 of working for two companies, I knew it would come with complications. Vigilant and Trabex are extremely close partners. Their missions complement one another, their leaders genuinely like and respect one another, and each brings different strengths to global trade. But they are still two companies, with different responsibilities, priorities, products, information and legitimate boundaries.

Somewhere along the way, I began trying to satisfy an increasingly ridiculous collection of expectations. Prioritize ABC for one company without neglecting DEF for the other. Be available, but establish boundaries. Tell people when you’re overwhelmed, but don’t become the Drama Queen of Global Trade. Be vulnerable, but demonstrate leadership. Sell, but don’t be obnoxious. Be visible, but don’t make everything about yourself. Maintain work-life balance, but don’t let anything fall apart. Smile, engage and give good face while your head is ringing from tinnitus and you’re trying to ignore a migraine.

In other words, my own little version of Gloria’s dilemma: Be extraordinary, but don’t look like you’re trying too hard to be extraordinary.

Then I discovered something both humbling and liberating. A significant portion of that pressure wasn’t actually coming from Vigilant or Trabex.

It was coming from me.

I had one of the simplest and most beneficial conversations of my career this week. It wasn’t about tariffs, strategy, AI, sales pipelines or Section 338. It was about honesty and communication. What do you actually expect from me? What information belongs where? What are the boundaries? What is the priority? What can wait? Where do I need help? What am I assuming that nobody has actually asked me to do?

Talking openly with leaders, coworkers, friends and family made me realize that some of the impossible standard I was desperately trying to meet existed primarily inside my own head. It also turns out there are people around me who are smarter and better organized than I am, processes I can improve, and tools, including our increasingly capable AI friends, that can help. But first I had to admit that I needed help. Then I had to do something considerably harder: accept it.

And somewhere in there is a trade-compliance lesson.

Our profession is having its own little Barbie moment. Government wants partnership with industry, but also enforcement. Know your suppliers and their suppliers. Understand ownership. Validate origin, value and classification. Screen everybody. Maintain Reasonable Care. Monitor regulatory changes. Use technology and AI, but don’t blindly trust technology or AI. File faster. Know more earlier. Audit your processes. Correct your mistakes.

Oh, and keep the goods moving.

It can feel contradictory because sometimes it is contradictory. But conversations I have had with industry, attorneys, government officials and other compliance professionals keep bringing me back to something remarkably simple: you can only do what you can reasonably do. Build a thoughtful program, establish responsibilities, create guardrails, document decisions, use good technology, audit yourself, communicate when something isn’t working, correct problems when you find them and ask for help before exhaustion turns into complacency.

That last part may be the most important. Burnout creates its own compliance risk. Exhausted people stop asking the extra question. They accept the answer that looks close enough. They postpone the audit, ignore the anomaly or assume somebody else checked it. Eventually, exhaustion can begin to look a lot like complacency.

So perhaps the lesson from my Barbie moment is simply to have the conversation. If expectations are unclear, ask. If responsibilities overlap, define them. If you’re overwhelmed, say so. If information needs to remain separated, build the guardrails. If somebody offers help, consider actually accepting it. And if your compliance program depends on one exhausted person remembering everything, that isn’t a heroic employee. That’s a control weakness.

Knowledge is power, but knowledge isn’t only knowing what CBP published this morning. Sometimes it is knowing what your boss actually expects, what your team needs, where your boundaries are, and when you need help. Sometimes it is also recognizing that the little voice insisting “you are not doing enough” may be considerably less reliable than the people around you.

Next week I’ll be in Dublin, presumably smiling, speaking, networking, talking about tariffs and doing my best impression of someone who has his life completely under control.

Spoiler alert: I do not.

But I have good people around me, better guardrails than I had a week ago, and a clearer understanding that doing my best does not require doing everything. I am extraordinarily fortunate to have the life, work, people and opportunities that I do. And perhaps being grateful for all of it also means learning how to make it sustainable.

So thank you, Gloria.

Apparently what I needed this week wasn’t another CSMS message.

I needed Barbie.

Now, speaking of contradictory expectations and an impossible amount of information to process, CBP and the Federal Register have been busy again.

Let’s veer into this week’s Vigil, shall we?

 

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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?

 

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**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 # 69847323 – Information on Customs Broker Permit User Fee Changes Effective October 1, 2026

Pursuant to the General Notice (91 FR 48398) published July 31, 2026, 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 which will take effect on October 1, 2026.

CSMS # 69847323 – Information on Customs Broker Permit User Fee Changes Effective October 1, 2026

 

 

CSMS # 69980710 – Harmonized System Update (HSU) 2624

Harmonized System Update (HSU) 2624 was created on September 11, 2026, and contains 6 harmonized tariff records and 18 Automated Broker Interface (ABI) records.

HSU 2624 contains Section 338 Canada updates

CSMS # 69980710 – Harmonized System Update (HSU) 2624

 

 

CSMS # 69994928 – GUIDANCE: Import Ban of Certain Polysilicon Products Under Proclamation 11052

The purpose of this message is to provide guidance regarding the U.S. Department of Commerce’s (Commerce’s) Temporary Final Rule (TFR) on Measures to Restrict Stockpiling of Polysilicon and Polysilicon Derivatives Under Proclamation 11052.

CSMS # 69994928 – GUIDANCE: Import Ban of Certain Polysilicon Products Under Proclamation 11052

 

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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

 

 

Rules

Measures to Restrict Stockpiling of Polysilicon and Polysilicon Derivatives under Proclamation 11052

FR Document: 2026-19537 Citation: 91 FR 60505

PDF Pages 60505-60510 (6 pages) Permalink

Abstract: On August 6, 2026, the President issued Proclamation 11052, “Adjusting Imports of Polysilicon and Its Derivatives Into the United States” (Proclamation 11052), ordering the Secretary of Commerce (Secretary) to take action to restrict imports by a company if he determines the company is stockpiling polysilicon or polysilicon derivatives (Polysilicon Products) in advance of import adjustments that will be effective on December 4, 2026. The Bureau of Industry and Security (BIS), in this…

 

 

Antidumping or Countervailing Duty Investigations, Orders, or Reviews:

Steel Wire Garment Hangers from the People’s Republic of China and the Socialist Republic of Vietnam

FR Document: 2026-19376 Citation: 91 FR 60086

PDF Pages 60086-60091 (6 pages) Permalink

Abstract: The U.S. Department of Commerce (Commerce) preliminarily determines that imports of steel wire garment hangers (hangers), completed in Cambodia using: (1) steel wire or (2) steel wire and paper accessories, produced in the People’s Republic of China (China) or the Socialist Republic of Vietnam (Vietnam), are circumventing the antidumping duty (AD) order on hangers from China, or the AD and countervailing duty (CVD) orders on hangers from Vietnam. Interested parties are invited to comment on…

 

Common Alloy Aluminum Sheet from the People’s Republic of China, Bahrain, Brazil, et al.

FR Document: 2026-19516 Citation: 91 FR 60591

PDF Pages 60591-60593 (3 pages) Permalink

Abstract: The U.S. Department of Commerce (Commerce) is issuing the final results of the changed circumstances reviews (CCRs) of the antidumping duty (AD) and countervailing duty (CVD) orders on common alloy aluminum sheet (aluminum sheet) from the People’s Republic of China (China), Bahrain, Brazil, Croatia, Egypt, Germany, India, Indonesia, Italy, Oman, Romania, Serbia, Slovenia, South Africa, Spain, Taiwan, and the Republic of T[uuml]rkiye (T[uuml]rkiye), to revoke the orders, in part, with respect…

 

 

Guidance and Procedures:

Tariff Adjustments for Specialty Pharmaceuticals and Associated Pharmaceutical Ingredients and Technical Corrections to the Harmonized Tariff Schedule of the United States for Duties Imposed under Proclamation 11020

FR Document: 2026-19498 Citation: 91 FR 60360

PDF Pages 60360-60366 (7 pages) Permalink

Abstract: This notice defines the pharmaceutical products and lists the jurisdictions that are eligible to receive an ad valorem tariff rate of zero pursuant to Presidential Proclamation 11020 of April 2, 2026, “Adjusting Imports of Pharmaceuticals and Pharmaceutical Ingredients Into the United States,” (Proclamation 11020). These pharmaceutical products include drugs and associated ingredients where all approved indications are designated as orphan; nuclear medicines; plasma derived therapies;…

 

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News from other esteemed sources:

 

THOMPSON/HINE

CBP Confirms October 6, 2026 Launch of Phase 3 of the IEEPA Tariff Refund Process

By Aaron C. Mandelbaum, Maryam Mahboob & David M. Schwartz on September 16, 2026

On September 15, 2026, U.S. Customs and Border Protection (“CBP”) announced in a declaration filed in the U.S. Court of International Trade (“CIT”) that Phase 3 of the Consolidated Administration and Processing of Entries (“CAPE”), the system for administering refunds of tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), will deploy on October 6, 2026.

CBP Confirms October 6, 2026 Launch of Phase 3 of the IEEPA Tariff Refund Process | SmarTrade

 

 

 

BAKER/MCKENZIE

EU: European Parliament adopts new Union Customs Code – key developments and timing to be aware of

On 16 September 2026, the European Parliament has voted to adopt the new Union Customs Code (“nUCC“) heralding broad customs reform for the European Union (“EU“). Changes will be spread across all facets of customs compliance…
Read more…

 

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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 Annual Spring Conference, March 7 – March 10, 2026

Orlando, Florida, USA

This will be the 25^th 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.

 

A Small Change to Our Travel Calendar

In keeping with this week’s foreword about setting boundaries, accepting help and occasionally acknowledging that we cannot do everything, we have made one small adjustment to our previously announced conference schedule.

After a very busy September and with several other commitments on the horizon, we have made the decision not to attend the ICPA Global Trade Insights Conference in Mexico City this November as previously planned.

We are disappointed to miss the opportunity to be there, but part of building sustainable careers and organizations is recognizing when it makes sense to take something off the calendar rather than simply continuing to add to it. Apparently, we are going to try practicing some of the advice we give. 😉

We wish ICPA, the speakers, attendees and our many friends and colleagues attending in Mexico City a fantastic conference. We look forward to participating in another ICPA Mexico event in the future and hearing all about this year’s program from our fellow Trade Nerds.

Sometimes “Where We Will Be” also requires being honest about where we won’t be. And this time, that feels like the right decision.

 

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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: Getting product compliance right starts with understanding what you actually have and which regulations apply. Commodity Jurisdiction can determine whether a product or component falls under the EAR or ITAR, affecting classification, licensing, technical data and other compliance requirements. We also discuss why Engineering, Procurement and Trade Compliance should work together UPSTREAM rather than waiting until something is ready to ship.

And a quick mea culpa from Jamie: during the interview, I pulled a “bolt” example out of my head that wasn’t the best choice because fasteners can have specific regulatory treatment. Let’s call it a “component” instead. Even Trade Nerds need to Verify and Then Trust themselves occasionally.

🎥 Watch the latest episode:

https://vigilantgts.com/get-product-compliance-right-from-the-start-hb/

 

Missed a previous episode? Browse the complete Trade Buzz library at:
https://vigilantgts.com/blog/