De Minimis Crackdown Tops Week: AD/CVD Wave, Mexico Tariffs, Forced‑Labor Actions
NEWSLETTER | Trade Insight AI
CBP Collects $1B After De Minimis Ends; Scrutiny Rises for e-commerce
CBP Media Releases • December 17, 2025
CBP has collected over $1 billion in duties on more than 246 million low-value shipments since the May 2, 2025 phaseout of de minimis for China and Hong Kong, extended worldwide on August 29. With full vetting of low-value parcels, seizures of unsafe and non-compliant goods are up 82%, reflecting tighter data requirements and enforcement across e-commerce channels. Importers and marketplaces should reassess low-value routing, landed-cost models, and compliance controls given higher duty exposure and inspection risk.
Enforcement & Compliance Watch
DOJ Secures $118M FCPA Deal Over Guatemala Bribery Scheme
STR Trade Report •December 19, 2025
DOJ reached a two-year deferred prosecution agreement with a Guatemalan subsidiary of a Luxembourg-headquartered company (with its principal place of business in the U.S.) over a 2012–2018 scheme involving monthly bribes to Guatemalan legislators; the resolution totals more than $118 million, including a $60 million criminal penalty and $58.2 million forfeiture. The company and its parent must continue cooperating, enhance compliance, and report on remediation, with DOJ citing aggravating conduct (continued wrongdoing during an initial probe) and crediting proactive disclosures and extensive remedial steps. For trade compliance teams, the case underscores DOJ’s heightened FCPA posture—emphasizing individual accountability—and the expectation for robust, well-resourced global compliance programs.
CBP Issues WRO Detaining Serbian-Made Linglong Tires Over Forced Labor
CBP Media Releases •December 18, 2025
U.S. Customs and Border Protection issued a Withhold Release Order against automobile tires made in Serbia by Linglong International Europe D.O.O. Zrenjanin, directing all U.S. ports to detain shipments under 19 U.S.C. § 1307. CBP cited evidence of nine ILO forced labor indicators supported by worker testimony, documents, and open-source reporting; the action is the fifth WRO in 2025 and second of FY 2026. Importers must export or destroy detained goods or prove the tires were not made with forced labor, signaling heightened compliance risk for tire supply chains.
CBP Revokes More Than Two Dozen Broker Permits for Nonpayment
STR Trade Report •December 17, 2025
CBP has revoked over two dozen national customs broker permits after the holders failed to pay the annual user fee required under 19 CFR 111.96, according to a Federal Register notice. The 2026 fee is $185.38 (up from $180.57 in 2025) and is due Jan. 30, 2026; nonpayment by the deadline triggers automatic permit revocation. Brokers should confirm timely payment and permit status, and importers should verify broker authorization to avoid clearance disruptions.
CBP-FDA Cincinnati seize 448 shipments; $408K in unapproved pharma
CBP Media Releases •December 16, 2025
In late October, a joint CBP-FDA operation at Cincinnati targeted high‑risk, FDA‑regulated imports and seized 448 shipments bound for U.S. addresses. Officers intercepted 8,521 pairs of undeclared/misdeclared contact lenses and 50 shipments of misbranded drugs and devices—including GLP‑1 medications, Botox, and dermal fillers—with the prohibited pharmaceuticals alone valued at $407,784 (MSRP). The scale versus a similar FY2025 sweep signals heightened scrutiny at express hubs and online marketplaces; importers of FDA‑regulated goods should expect rigorous exams and ensure prescriptions, approvals, and accurate declarations.
Trade Remedies & Duty Actions
U.S. AD/CVD Roundup: Steel Orders, Molded Fiber, Off‑Grid Solar
STR Trade Report •December 19, 2025
U.S. authorities issued antidumping orders on corrosion‑resistant steel from Australia, Brazil, Canada, Mexico, the Netherlands, South Africa, Taiwan, Türkiye, and the UAE, and countervailing duty orders on such steel from Brazil, Canada, Mexico, and Vietnam, effective Dec. 19. The ITC also made final affirmative injury determinations on thermoformed molded fiber products from China and Vietnam, with a critical circumstances finding for Vietnam that could trigger retroactive duties. Sunset reviews keep orders on quartz surface products from India and Turkey and on silicon metal from Russia in place, while certain off‑grid Chinese CSPV panels are carved out from the solar AD/CVD orders as of Dec. 19.
Chinese Taipei challenges Canada’s steel TRQs, surtaxes and derivative duties at WTO
WTO Latest News •December 17, 2025
Chinese Taipei has requested WTO consultations with Canada over tariff-rate quotas and a surtax on certain steel, plus a global duty on specific steel derivative products. The complaint (WT/DS643/1) alleges breaches of GATT 1994 and the Agreement on Import Licensing Procedures. If unresolved after 60 days of consultations, a panel may be requested—importers and steel suppliers should monitor for potential changes to Canada’s quota, duty, and licensing regimes.
CIT Affirms Refund Path, No Immediate Suits Needed on IEEPA Tariffs
STR Trade Report •December 17, 2025
On Dec. 15, the Court of International Trade held that liquidation of entries will not bar the court from ordering reliquidation and refunds if IEEPA tariffs are ultimately invalidated, denying a request to enjoin CBP liquidations. The ruling confirms importers need not rush to file suit before liquidation to preserve refund rights, with pre–Supreme Court challenges proceeding under the court’s residual jurisdiction (28 U.S.C. § 1581(i)). Practical takeaway: continue filing protests as a safeguard given unresolved post-decision procedures and uncertainty over CBP refunds via protest.
Trade Enforcement Tightens: EU €3 Parcel Duty, UK Powers, U.S. Ramp-Up
STR Trade Report •December 18, 2025
Compliance pressure is set to rise across major markets. In the U.S., practitioners expect a 2026 ramp-up in CBP tariff enforcement after a rapid, complex overhaul that has produced widespread errors. The EU will impose a temporary 3-euro customs duty per low-value parcel from non‑EU countries (separate from a potential handling fee), and the UK plans to let the Business and Trade Secretary direct the TRA to initiate anti-dumping probes—raising cross-border e-commerce costs and signaling more politically driven trade defenses.
Tariff Policy & Market Access
Mexico to Impose 5–50% Tariffs on 1,300 Non‑FTA Imports Jan. 1, 2026
STR Trade Report •December 18, 2025
Mexico’s Congress has approved tariff increases of 5–50% on more than 1,300 products from countries without FTAs (e.g., China, India, South Korea, Thailand, Indonesia), effective Jan. 1, 2026; over 300 previously duty‑free items will now be taxed across autos, textiles, metals, plastics, electronics, furniture, and more. Framed within a broader customs‑law reform linked to the 2026 USMCA review and U.S. tariff concerns, the measure reportedly excludes IMMEX maquiladoras, but an official notice has not yet been published.
CAFTA-DR Short Supply Bid Could Enable Duty-Free Faux Leather Apparel
STR Trade Report •December 19, 2025
The Committee for the Implementation of Textile Agreements received a short supply request for a polyurethane-coated polyester knit fabric bonded to sherpa pile (HTSUS 6001.92.00). If added to Annex 3.25 in unrestricted quantities, apparel made in CAFTA-DR countries using this fabric could enter duty-free regardless of fabric origin; suppliers able to produce the fabric should submit offers by Dec. 26.
HTSUS Amended: 15% Floor on Swiss, Liechtenstein Tariffs Retroactive Nov. 14
STR Trade Report •December 18, 2025
The Department of Commerce amended the HTSUS to implement a trade framework with Switzerland and Liechtenstein, setting a 15% minimum tariff (or MFN if higher) on originating goods and adjusting rates for select categories including agriculture, certain natural resources, aircraft and parts, and generic pharmaceuticals/precursors. The changes apply to goods entered or withdrawn for consumption on or after 12:01 a.m. EST Nov. 14, 2025, with CBP processing any applicable duty refunds—importers should review impacted entries. If a full agreement is not concluded by March 31, 2026, the U.S. may reconsider these measures.
USTR Updates Congress on USMCA Implementation and Enforcement Priorities
USTR Press Releases •December 17, 2025
Ambassador Greer delivered a report to Congress on the operation of the United States‑Mexico‑Canada Agreement, outlining implementation status and enforcement priorities under the pact. For trade professionals, the update signals U.S. focus areas in North American trade policy and compliance, informing supply‑chain planning, market access strategies, and risk management across the U.S., Mexico, and Canada.
Strategy & Year‑End Outlook
2025 Trade Review: Enforcement Tightens, Tariffs Escalate, CTPAT Pilot Planned
STR Trade Report •December 19, 2025
A year-end roundup highlights sharper U.S. enforcement and rising cost pressures: more False Claims Act cases and a criminal undervaluation sentence, a Section 301 probe into China’s Phase I commitments, and new Section 232 tariffs on timber/lumber and on trucks and buses effective Nov. 1, alongside additional China tariffs and modified ship fees. Market access moved both ways as the U.S. announced trade agreements with four Southeast Asian countries while tariff preferences for Africa and Haiti programs expired. CBP’s plan to pilot CTPAT access for 3PLs signals evolving trusted trader models into 2026, prompting importers to recalibrate compliance and tariff mitigation strategies now.
ITC Invites Proposals to Shape Next Global HS Review, Target Oct. 2027
STR Trade Report •December 18, 2025
The USITC is soliciting proposals to amend the global Harmonized System for the WCO’s eighth review cycle, with submissions suggested by Oct. 1, 2027; ITC, CBP, and USTR will vet entries. The request targets 4- and 6-digit codes and section/chapter notes to delete low‑volume categories, create codes for commercially significant but poorly classified products, and simplify or clarify provisions to improve uniform classification, especially for U.S. exports. Proposals should include specific HS text and supporting trade data; U.S.-only 8- and 10-digit provisions and duty rates are out of scope, and any U.S. implementation would be tariff‑neutral.
WTO maps MC14 agenda: reform leads, e-commerce moratorium in play
WTO Latest News •December 15, 2025
WTO members used a three-day General Council to narrow MC14 deliverables, putting institutional reform—especially dispute settlement—at the center, alongside text-based work on the e-commerce Work Programme and whether to extend the moratorium on customs duties for electronic transmissions. Agriculture, fisheries, TRIPS/environment, and services are slated for ministerial guidance rather than negotiated outcomes, and a minimalist declaration is being explored to avoid divisions. Annex 4 bids stalled again for the Investment Facilitation for Development pact (128 co-sponsors, Egypt newly joined) and the E-Commerce Agreement (72 co-sponsors; seven concerns), while LDC graduation measures and SPS/TBT S&D enhancements remain live; watch for any MC14 pledge to avoid “appeals into the void.”
WTO report: GVCs resilient but rewiring favors incumbents amid new rules
WTO Latest News •December 14, 2025
A new WTO-backed GVC Development Report finds global value chains holding up, with GVC trade slipping only slightly from 48% of global trade in 2022 to 46.3% in 2024 and growth remaining robust into late 2025. Rewiring is unfolding across geography, digitalization/automation, governance (industrial policy and targeted agreements), and environmental measures, but higher policy-driven costs, rising uncertainty, and a >$1 trillion annual trade finance gap are concentrating gains in established supplier economies. For trade professionals, more issue-specific deals—over 180 focused on digital trade and critical minerals as of 2024—will shape rules and opportunities, while diversification into newer locations will require creative risk and finance solutions.
