THE VIGILANT VIGIL – 31st 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:

The Editing Director (T.E.D.)’s Foreword: TOMORROW IS A TERRIBLE COMPLIANCE STRATEGY

Apparently global trade compliance is a musical now. And, in fairness, I may be partially responsible.

I just finished the ICPA Global Trade Insights Conference in Dublin, where we spent two days talking about increased enforcement, European FTAs, ESG, UCC reform, sanctions, tariffs, trade wars and the future of customs. Somewhere along the way our speakers managed to invoke Annie, The Wizard of Oz and Star Wars. I even squeezed in a little Jane Austen while walking the pier with my husband. Then, at the end of my own panel on U.S. trade policy, I decided that simply referring back to Larry Hanson’s earlier Annie analogy wasn’t sufficient.

So I sang it.

Yes, in the middle of an international trade conference in Dublin, I actually broke into “Tomorrow, Tomorrow, I love ya, Tomorrow…” Thankfully, ICPA has known me long enough that nobody seemed particularly surprised.

Larry had originally invoked Tomorrow to make a very good compliance point. I’ll classify it tomorrow. I’ll validate the supplier tomorrow. I’ll audit those entries tomorrow. I’ll investigate that anomaly tomorrow. I’ll get the supporting documentation tomorrow. As Annie reminds us, tomorrow is always a day away. Unfortunately, Customs may arrive first.

That became a surprisingly useful theme for the conference because, whether we were talking about customs enforcement, sanctions, FTAs, CBAM, deforestation, forced labor, tariffs or the changing European customs environment, the message was remarkably consistent: the days of simply having a document and calling it compliance are disappearing.

For years, companies have relied heavily on documentary compliance. I have a Certificate of Origin, therefore I have origin support. I have an email from my supplier with the HTS classification, therefore I have classification support. I have an affidavit, therefore I have done my due diligence. Increasingly, governments aren’t satisfied with the existence of the document. They want to know whether you can substantiate what it says.

Can you map the supply chain? Can you identify ownership and control? Do you know where the raw materials came from? Can you explain your classification, origin and valuation decisions? Can you trace the data back to its source? Most importantly, if somebody challenges the conclusion, can you defend it?

George Reid offered perhaps my favorite analogy of the conference: you need to know how the sausage is made. It isn’t enough to possess the sausage. You need to understand the ingredients, how it was made and, increasingly, where those ingredients came from, right down to the spices. That same idea resurfaced during the sanctions discussion in slightly more theatrical form: sometimes you need to be Dorothy and look behind the curtain. Who actually owns the company? Who controls it? Where are the goods ultimately going? Who is your customer’s customer?

Yoda even made an appearance during the discussion of EU Customs reform: “Do. Or do not. There is no try.” Apparently our entire global compliance program can now be taught through Broadway musicals and science fiction.

The substance underneath the jokes was serious. Enforcement is expanding beyond what many of us traditionally considered “Customs.” European companies are confronting CBAM, EUDR, forced-labor requirements, sanctions and environmental measures, and Customs teams frequently find themselves pulled into requirements that aren’t technically Customs regulations at all. At the same time, the EU is undertaking a fundamental redesign of Customs through proposals including the EU Customs Authority and Customs Data Hub, while governments around the world increasingly share data across agencies and use analytics to identify anomalies and risk.

The United States is moving in a similar direction. Customs enforcement increasingly intersects with sanctions, export controls, forced labor, national security and criminal investigations. Governments have more data and better analytical tools, while companies are being expected to know more about their suppliers, customers and products than ever before.

And tariffs? They’re here to stay. The specific measure may change, but companies can’t build a strategy around waiting for tariffs to disappear. During the U.S. Trade Policy Measures panel I moderated, we kept coming back to the fundamentals: classification, origin and valuation. Companies redesigned supply chains away from China and toward Vietnam, only to encounter new scrutiny there. Others looked toward Canada and then watched that relationship become more complicated. The lesson isn’t that companies shouldn’t diversify. It’s that there is no permanent Easy Street.

Yes, Annie gave us that one too.

For those who don’t remember, Carol Burnett, Tim Curry and Bernadette Peters spend “Easy Street” plotting their shortcut to riches. It reminded me of the well-intentioned salesperson or engineer who just wants to close the deal or solve the customer’s problem. Maybe they make an assumption, tell a little story, skip a step or provide information they don’t completely understand because they’re trying to help. Many compliance violations begin with one person who wasn’t trying to break the law at all.

That is why training matters. Executive support matters. Good systems matter. Auditing matters. AI can absolutely help identify anomalies, connect data and scale review, but qualified humans still need to remain involved. Most importantly, companies have to invest in compliance at a level proportionate to their actual risk. Several speakers made essentially the same observation: too many organizations still underinvest in the people, systems, outside expertise and data necessary to support the obligations they have taken on.

If I had to reduce two days of excellent presentations to a handful of lessons, they would be pretty simple: don’t wait until tomorrow; know how the sausage is made; look behind the curtain; connect the data dots; train your people; and audit the crap out of it. A document is not the same thing as substantiation, a shortcut is rarely Easy Street for long, and yesterday’s answer may not survive tomorrow’s enforcement environment.

But as valuable as the sessions were, the thing I will remember most about Dublin wasn’t on a PowerPoint slide. It was the people.

ICPA’s enormous U.S. Annual Conference is wonderful, but it has become so large that I have occasionally spent three days at the same conference as a friend and never actually seen them. Other times we manage a hug and a hurried “HI!” before one of us spots another 30 people we want to see. Dublin was different. The smaller group and intentionally generous networking breaks gave us time to actually sit down and talk.

I met people from across Europe and beyond, representing different companies, countries, cultures and languages, and discovered how much we had in common. I met Dragana, a wonderful Serbian trade professional who is also an artist, and suddenly our conversation moved naturally between compliance and comparing our artwork. I’ve known Mark professionally for years, but mostly through the conference handshake and quick hello. This week we talked about our spouses, children, education, the advantages and frustrations of where we live, and discovered that both of us have histories in choirs and musical theater. Mollie and I found common ground in some of the complicated political dynamics that can exist within extended families. The list goes on and on.

Trade opened the conversation. Life made the connection.

That experience began Tuesday evening at ICPA’s appropriately named Make a Friend Dinner, where we sat with people we barely knew, or didn’t know at all, and talked about work, family, politics, travel, food and life. By the end of the conference, some acquaintances had become friends and existing friendships had become considerably deeper. It reminded me that “networking” doesn’t have to mean collecting business cards or LinkedIn connections. Sometimes it means taking enough time to understand what makes another human being tick.

In fact, that lesson started before the conference. On Monday, Martin and I joined Elisabeth, Victoria, Lynda and her husband Dan on an excursion I organized to Glanworth in rural County Cork. We explored castle, friary and abbey ruins, enjoyed beautiful countryside and met wonderful people. What I had not adequately researched was the near-total absence of taxis, restaurants and public bathrooms. Apparently “Know Your Supply Chain” also applies to rural Irish transportation.

My carefully planned transportation solution eventually evaporated, leaving six Trade Nerds stranded in a tiny Irish village considerably longer than anticipated. We ultimately got out because someone in our group had taken the time earlier to genuinely engage with one of our taxi drivers. We called him, he remembered us and, after an admittedly impatient 90-minute wait, he came back to rescue us. Along the way, we borrowed a bathroom from a gracious local resident, chatted with the parish priest, saw places well beyond the standard tourist itinerary and spent hours together on trains talking about future conferences, new initiatives, our families and life.

In retrospect, Glanworth may have been the perfect metaphor for the entire week. Do your research. Have a plan. Choose reliable partners. Prepare for something to go wrong. And build genuine relationships, because someday one of those relationships may be the reason somebody comes back to get you.

At the conference, Elisabeth and Lynda again told the story of ICPA’s beginnings: two trade women who happened to meet at a conference during a smoke break and started talking. From that conversation grew what has become a global family of Trade Nerds. After Dublin, I think I understand that story a little better.

Global trade connects countries, governments, companies, products and supply chains, but underneath all of that it connects people. Sometimes we talk about tariffs, sanctions and rules of origin. Sometimes we talk about art, music, children, spouses, politics, food or travel. Sometimes we laugh until we cry, and sometimes we actually cry. And sometimes we sit around eating cheap pizza in Dublin, comparing notes on international trade while watching emotionally manipulative dog and cat videos.

That’s networking too. And perhaps it is the best kind.

So thank you to ICPA, Elisabeth, Lynda, Victoria, the speakers, organizers and all the Trade Nerds who made Dublin special. The education was excellent, but the conversations between the sessions may have been even more valuable. ICPA celebrates its 25th anniversary at the Annual Conference in Orlando in March 2027, followed by conferences in Wembley and Toronto. Registration for Orlando opened October 1, and if you’ve never attended an ICPA conference, perhaps this is the year to join the family.

Just don’t wait until tomorrow.

Apparently it’s always a day away.

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?

**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.**

 

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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 # 70050117 – New Foreign Trade Zone (FTZ) and Cargo Release Error Codes for Restricted Canadian Products

U.S. Customs and Border Protection (CBP) has added new error codes for e214 Foreign Trade Zone (FTZ) admissions and ACE Cargo Release as part of the implementation of Proclamations 11061, 11062 and 11063.

CSMS # 70050117 – New Foreign Trade Zone (FTZ) and Cargo Release Error Codes for Restricted Canadian Products

 

 

CSMS # 70050970 – Certain Canadian Products Excluded from Importation into the United States; Presidential Proclamations 11061, 11062, and 11063

The purpose of this message is to provide guidance on the Presidential Proclamations 11061, 11062, and 11063:

CSMS # 70050970 – Certain Canadian Products Excluded from Importation into the United States; Presidential Proclamations 11061, 11062, and 11063

 

 

CSMS # 70086122 – ACE CATAIR Entry Summary Create/Update Updated: FY27 Customs COBRA User Fees

The ACE CATAIR Entry Summary Create/Update has been updated to include the Fiscal Year 2027 Customs COBRA User Fees and is posted under the Chapters: Current Capabilities tab.

The adjusted fee amounts and limitations are effective October 1, 2026.

CSMS # 70086122 – ACE CATAIR Entry Summary Create/Update Updated: FY27 Customs COBRA User Fees

 

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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

 

 

Investigations; Determinations, Modifications, and Rulings, etc.:

Thermal Paper from Germany, Japan, South Korea, and Spain

FR Document: 2026-20136 Citation: 91 FR 62555

PDF Pages 62555-62558 (4 pages) Permalink

Abstract: The Commission hereby gives notice that it has instituted reviews pursuant to the Tariff Act of 1930, as amended, to determine whether revocation of the antidumping duty orders on thermal paper from Germany, Japan, South Korea, and Spain would be likely to lead to continuation or recurrence of material injury. Pursuant to the Act, interested parties are requested to respond to this notice by submitting the information specified below to the Commission.

 

 

Aluminum Foil from Armenia, Brazil, Oman, Russia, and Turkey

FR Document: 2026-20139 Citation: 91 FR 62552

PDF Pages 62552-62555 (4 pages) Permalink

Abstract: The Commission hereby gives notice that it has instituted reviews pursuant to the Tariff Act of 1930, as amended, to determine whether revocation of the countervailing duty orders on imports of aluminum foil from Oman and Turkey and antidumping duty orders on imports of aluminum foil from Armenia, Brazil, Oman, Russia, and Turkey would be likely to lead to continuation or recurrence of material injury. Pursuant to the Act, interested parties are requested to respond to this notice by…

 

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News from other esteemed sources:

 

BAKER/MCKENZIE

Colombia: Foreign Trade and Logistics – Connecting Opportunities

Over time, technology and globalization have reshaped value chains and, with them, the legal, technical, and technological implications behind any given product or service, as well as the way it is sold in a given territory. A single product may now…
Read more…

 

 

UK introduces further sectoral sanctions against Iran, further to wider international action by the EU, US and UAE
09/30/2026

On 29 September 2026, a range of new and expanded UK sanctions targeting Iran entered into force, following the publication on 8 September 2026 of the Iran (Sanctions) (Amendment) Regulations 2026 (the “Regulations“). The Regulations…
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 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.

 

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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 export compliance right starts with understanding exactly what you have. Accurate ECCN classification requires more than a product description or an assumption that something is EAR99. It means gathering the right technical data, connecting Engineering and Trade Compliance early, understanding how product changes may affect classification, and documenting the analysis so your decisions are consistent, repeatable and defensible.

🎥 Watch the latest Trade Buzz and read more:
https://vigilantgts.com/get-export-compliance-right-every-time-hb/

 

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