Weekly Digest
Question of the Week
Solicitation season is officially here. Hit reply and tell us how it's going. If it's turning into a paper chase, we can help!
Ep. 2: Monthly Trade Policy Webinar
Getting Money Back: Duty Recovery in the U.S., Canada and the EU
Wednesday, November 18 at 1:00 pm ET
0.5 CE Hours
The Bottom Line
Last week we covered new dumping rates on Mexican coated steel and three genomics companies added to the UFLPA list. Since then, CBP rewrote who can act as importer of record starting January 5, and only 21% of customs brokers hold the CTPAT validation that foreign importers will need behind them. The ITC's final vote also put solar cell duties on India, Indonesia and Laos back in force, and Commerce set preliminary dumping deposits on oil well pipe from Austria, Taiwan and the UAE.
Importer of Record
CBP published an interim final rule on November 6 that splits importers of record into two groups, U.S. and foreign. From January 5, 2027, a foreign IOR can only make entry if it's validated in CTPAT, CBP's supply chain security program, or if it files through a broker that is.
To count as a U.S. IOR, a company has to be organized and located here. It also has to be at least 51% owned and controlled by U.S. citizens or permanent residents, or else own enough unencumbered U.S. real property. CBP didn't say how much property is enough. So a U.S. subsidiary of an overseas parent that rents its warehouse could land on the foreign side.
CBP's filing guidance adds a yes or no U.S. IOR field to every entry and entry summary. If a foreign IOR files without CTPAT cover after January 5, CBP can reject the entry. Comments on the rule are also due January 5.
CBP's own numbers show where the pressure lands. Of the importers of record that filed between October 2020 and February 2026, 16% were foreign, and about a third of those are neither CTPAT validated nor using a CTPAT validated broker. Only 21% of the 3,100 brokers that filed in that period are CTPAT validated. Those counts come from how importers file today, and we expect the foreign share to grow once the 51% ownership test starts moving U.S. subsidiaries of overseas parents into the foreign column.
CBP estimates validated brokers will pick up 9.3% more clients and absorb them without much trouble. We expect a real bottleneck, with the most pain at the northern and southern borders and on ecommerce shipments. We also expect a reshuffling of who acts as importer of record, as some foreign sellers hand the role to a U.S. buyer or distributor rather than wait in line for a new broker.
If any entity you import through could fail the U.S. IOR test, line up a CTPAT validated broker before January 5, when capacity gets tight. Brokers have to check that answer before they file, so expect yours to ask for ownership or property records.
Sources: Federal Register, CBP bulletin
Antidumping
The Alliance for American Solar Manufacturing and Trade filed this case in 2025, and the ITC has now voted that solar cells from India, Indonesia and Laos injured U.S. producers. Commerce published the duty orders November 9. Deposits started again November 5, the day the ITC vote was published.
Most Indian cells now carry 107.17% in dumping deposits and 126.09% in subsidy deposits. Indonesia is 94.36% and 73.20%. Laos is 65.36% and 82.03%.
We covered the same rates in September when Commerce made them final.
Commerce's preliminary deposits ran out October 24, so entries from October 25 through November 4 will liquidate without the dumping duty. The ITC also agreed with Commerce on critical circumstances for Indonesia, which lets CBP collect on some Indonesian entries made before the preliminary rates. It disagreed for India and Laos.
Dumping deposits paid on solar entries from October 25 through November 4 should come back when those entries liquidate.
Sources: Federal Register: antidumping orders, countervailing orders, ITC determination
Oil Country Tubular Goods
Commerce published preliminary dumping rates November 4 on oil country tubular goods from Austria, Taiwan and the UAE. That covers the casing and tubing used in oil and gas wells. CBP collects deposits on entries made from November 4.
Voestalpine Tubulars got 47.21%, the same rate as other Austrian producers. Taiwan's rate for most producers is 52.43%, with Shin Yang Steel at 51.19% and Tension Steel Industries at 54.74%. The UAE rate is 68.23%, and Ajmal Steel Tubes and Pipes got 68.88%.
Commerce postponed the final determinations for Austria and Taiwan.
Any refund of these deposits waits for the final rates and liquidation.
Sources: Federal Register: Austria, Taiwan, UAE
Garment hangers. Commerce ruled on November 6 that hangers finished in Cambodia from Chinese or Vietnamese steel wire are getting around the existing orders. Deposits reach back to entries from August 12, 2025. Most will pay the Vietnam rates, 220.68% dumping plus 31.58% subsidy. Importers with paperwork tracing the wire to China pay the China rate instead. (Federal Register)
CBS from China. CBS, a chemical used to cure rubber, picked up a preliminary dumping deposit of 281.69% on November 6. Commerce found critical circumstances too, so the deposit also covers entries from up to 90 days earlier. (Federal Register)
AGOA. USTR said on November 2 that Rwanda and South Africa will lose their AGOA benefits on January 1, 2027. (USTR)
New cases. Commerce opened dumping cases on seamless steel pipe from Georgia and India, plus a subsidy case on the Indian pipe. Wooden fence parts from China got one of each. (Federal Register: pipe, Indian pipe subsidies, fence parts)
What We're Watching
China ship fees. USTR pushed back the Section 301 fees on Chinese ships again. The hold that was due to end November 9 now runs through January 9, 2027 while talks with China continue.
List Every Company You Import Under
For each one, pull the ownership chart and check whether it owns property in the U.S. or only leases it. Any entity that fails both tests needs a CTPAT validated broker by January 5, so confirm your broker's status now. Validated brokers will fill up as the deadline gets closer.
Send Your USMCA Supplier Requests
Blanket USMCA certifications from suppliers usually run for the calendar year, so the requests for 2027 should go out now. If you're paying full duty on goods that might qualify, this is the time to find out.
Look Over Your Solar and Hanger Entries
Solar cell entries from October 25 through November 4 shouldn't have a dumping deposit on them. If they do, ask your broker why. Cambodian hanger entries back to August 12, 2025 now owe the circumvention deposit.
▸ Reach Out to Caspian to Understand Your Impact
A New Look for the Tariff Calculator
Our free tariff calculator has a new design, and so does the one inside Caspian. Try it with an HTS code you file often and see how the duty changes by country of origin.
Open the Agent From Any Screen
The agent button now sits in the bottom right of every screen in Caspian. It can see the page you have open, so from a project you can ask what's still outstanding and it will pull up the records for you.
New to Caspian? Check out our platform page to see how audits, drawback and refunds work together.
It takes just 60 seconds to find out what Customs owes you. We’ll do the rest.
Caspian Trade, Inc.Refunds recovered. Compliance handled. Margins protected.
CBP-Approved ABI Vendor Platform. Licensed customs brokers.