Section 232 Duties on Unmanned Aircraft Systems Go Into Effect
The new Section 232 tariffs on Unmanned Aircraft Systems have gone into effect as of 12:01 AM ET on September 3. CBP issued guidance on the duties via CSMS message on Wednesday, September 2.
Unmanned aircraft, docking stations, and parts for the docking stations, parts or components for use with a UAS with a maximum take-off weight of more than 25 kgs, and unmanned aircraft with thermal imaging will see an additional 100% duty under 9903.08.21. Unmanned aircraft without thermal imaging will see an additional 25% duty under 9903.08.22. Beginning February 9, 2027, 9903.08.22 will also cover parts or components for use with an unmanned aircraft system except for those for use in or with an unmanned aircraft system with a maximum take-off weight of more than 25 kgs.
Exemptions exist for articles that are not for use in or with the products described and for companies subject to onshoring plans approved by either the Department of Homeland Security or the Department of War and the Secretary of Commerce. Reduced duty rates are available for products of the United Kingdom, Japan, Lichtenstein, South Korea, Switzerland, Taiwan, or member countries of the EU.
The UAS Section 232 duties are required in addition to any special tariff treatment given by a Free Trade Agreement or preference program and goods properly claimed under a provision of Ch. 98 are eligible for and subject to the terms of the provision and all applicable CBP regulations. Drawback is also available if certain conditions are met. Goods entered into a Foreign Trade Zone must be entered under privilege foreign status unless eligible for domestic status.
Rejections Coming for Shipments Lacking Copper Smelt and Cast Declaration
In a CSMS message issued on August 31, CBP has advised that beginning September 14, entries of goods where the copper primary country of smelt and the country of cast are not reported will be rejected.
Primary country of smelt and country of cast is required for copper goods under HTS subheadings 8544.42.10, 8544.42.20, 8544.42.90, and 8544.49.10. Secondary country of smelt may also be reported but is not required. Goods of U.S. origin do not require country of smelt and cast declaration.
USTR Amends Section 301 China Exclusions to Reflect July 1 HTS Updates
The USTR has announced the amendment of four product exclusions from the Section 301 tariffs on China that reflect the recent statistical changes brought on by the July 484(f) updates. This amendment is effective retroactively for goods entered for consumption or withdrawn from a warehouse for consumption as of 12:01 AM on July 1. The HTS numbers covered by this amendment include 8413.91.9039, 8413.91.9046, 8413.91.9059, 8413.91.9099, 3926.90.9915, and 3926.90.9920. CBP will be issuing entry and implementation guidance for these changes.
U.S. Customs Considering Significant New Import Supply Chain Disclosure Requirements
We want to bring to your attention an important regulatory development that could significantly affect U.S. importers, foreign suppliers, and manufacturers.
On September 2, 2026, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking (ANPRM) titled Heightened Import Disclosures for Supply Chain Visibility. The proposal seeks public comment on a wide range of potential new supply chain transparency requirements intended to strengthen customs enforcement, identify transshipment risks, and enhance visibility into imported goods and their origin.
How You May Be Affected
Although no new requirements have been adopted at this stage, CBP is evaluating several significant changes that could increase importer obligations if ultimately implemented.
Potential requirements under consideration include:
1. Submission and Retention of Foreign Export Documentation
CBP is considering requiring importers to obtain, maintain, and potentially submit documentation that foreign exporters provide to their local customs authorities, including “any documentation or information that the foreign exporter was required to submit to the foreign customs administration prior to exporting to the United States.”
2. Expanded Identification of Supply Chain Participants
CBP is evaluating whether to enhance or replace the current Manufacturer Identification Code (MID) with more detailed information for Manufacturers, Producers, Shippers, Exporters, and Sellers.
3. Possible Expansion of CTPAT Expectations
CBP is also evaluating whether participants in the Customs Trade Partnership Against Terrorism (CTPAT) program should face enhanced supply chain traceability and cybersecurity requirements, with corresponding benefits for compliant participants.
What You Can Do Now
Although these proposals are not yet regulatory requirements, importers may benefit from taking proactive steps now, including:
- Assess supply chain visibility
Determine whether you can identify manufacturers, producers, exporters, and other upstream parties for your imported products.
- Review supplier agreements
Evaluate whether suppliers can provide export declarations, certificates of origin, and other foreign customs documentation if requested.
- Evaluate recordkeeping procedures
Confirm whether your current systems can retain foreign export documentation and related supporting records.
- Review country of origin claims
Validate origin claims, particularly for high-risk products and sourcing regions.
- Consider traceability technologies
Review existing supply chain mapping and visibility tools and evaluate whether they provide sufficient documentation and audit support.
Our Perspective
This ANPRM signals CBP’s continued focus on supply chain transparency, anti-transshipment enforcement, forced labor compliance, origin verification, and importer accountability. While the final scope of this proposed rule remains uncertain, Importers that develop stronger visibility into their supply chains and documentation practices will likely be better positioned for future compliance requirements.
We are closely monitoring developments and would be pleased to discuss how these proposals may affect your specific supply chains, sourcing strategies, and customs compliance programs.
CPSC to Begin eFiling for Mail Shipments
In a bulletin released September 1, CPSC has advised that eFiling will be required for mail shipments under entry type 13 beginning October 22. Previously, entries by mail were not required to submit eFiling data to CPSC because CBP did not collect entry data for products imported into the US by international mail. With the advent of entry type 13, however, mail shipments will be required to submit either the full or reference message sets via ACE.
Importers are reminded that they are responsible for eFiling a certificate whenever one is required. For CPSC certificate requirements, this is the party eligible to make entry for the merchandise pursuant to CBP statues and regulations. This may be an owner, purchaser, consignee, or authorized customs broker.
If you have any questions regarding the new requirements, you may contact eFiling support at EFilingSupport@cpsc.gov.