De Minimis Reset, 301 Relief, and Enforcement Heat
NEWSLETTER | Trade Insight AI
2025 Trade Recap: China De Minimis Ends, 232 Tariff Risks
STR Trade Report • November 27, 2025
A year-end roundup flags 2025 shifts that will shape 2026: de minimis treatment for imports from China ends May 2, Section 232 actions could extend tariffs to semiconductors, pharmaceuticals, and critical minerals, and a court ruling reaffirmed the finality of entry liquidation. Importers and brokers should reassess low-value shipment strategies, model tariff exposure in targeted sectors, tighten post-entry compliance, and monitor executive-driven changes to payment processes and potential repeals of unlawful regulations alongside broader policy recommendations on tariffs, China, and trade deals.
Tariffs & Cost Exposure: 301 relief, Brazil rollback, and reporting changes
USTR extends China 301 exclusions, preserving relief for select imports
USTR Press Releases •November 26, 2025
The U.S. Trade Representative has extended certain product-specific exclusions from Section 301 tariffs tied to the China forced technology transfer investigation, keeping duty-free treatment in place for covered items. The extension averts immediate cost increases and provides planning certainty; importers should verify whether their HTS lines remain covered on the updated exclusion lists and adjust customs entries, pricing, and contracts accordingly.
U.S. Ends 40% Tariff on Brazilian Agricultural Goods; Retroactive Refunds
STR Trade Report •November 25, 2025
A Nov. 20 executive order terminates the additional 40% tariff on more than 200 HTSUS agricultural lines from Brazil, retroactive to entries on or after 12:01 a.m. EST Nov. 13. CBP will process refunds under standard procedures; surcharges on other Brazilian goods remain in effect, with the rollback tied to progress in bilateral negotiations. The move aligns treatment of these products with recent U.S. removals of “reciprocal” tariffs and immediately lowers landed costs for U.S. importers.
Comments Open on Section 232, FTZ, HMF, and CBP Forms
STR Trade Report •November 27, 2025
BIS, ITA, and CBP are seeking public input on new, revised, or reinstated information collections, including Section 232 inclusion/offset processes (with autos and parts), FTZ admissions and activity permits (Forms 214/216), bonded warehouses and drawback, harbor maintenance fee filings, and a revision to CBP Form 6059B. Importers, FTZ operators, carriers, and brokers should review the notices to weigh in on reporting burdens and prepare for potential adjustments to documentation and compliance workflows.
Tariff Windfall Shrinks; U.S.-EU: Digital for Steel; Taiwan Tightens Exports
STR Trade Report •November 26, 2025
The CBO now projects the Trump tariffs will reduce U.S. budget deficits by $1 trillion less than previously estimated, reflecting new data and recent tariff policy changes—tempering expectations of tariff-driven fiscal relief. Washington is conditioning potential cuts to steel tariffs on more balanced EU digital rules as Brussels presses for progress on steel and aluminum, keeping transatlantic market access in flux. Canada signaled readiness to resume trade talks when the U.S. is willing, and Taiwan plans tighter dual‑use export controls requiring government approval, adding compliance complexity for tech supply chains once implemented.
Enforcement & Risk: FDA/CBP/IPR actions to watch
DOJ Secures First Felony Plea for FDA Food Prior Notice Violations
STR Trade Report •November 26, 2025
A U.S. company pleaded guilty to smuggling European infant formula and evading FDA prior notice requirements, admitting it used false commodity descriptions to avoid detection despite import alerts for labeling and nutrient deficiencies. DOJ said this marks the first felony plea tied to failure to provide FDA prior notice; the plea includes $304,640 in forfeiture and an estimated $2.3 million total federal recovery. The case signals heightened criminal risk for food importers that circumvent FDA/CBP screening and may drive stricter compliance reviews across the sector.
ITC Launches 337 IPR Cases Targeting LCDs, Wearables, Appliances and Beauty Devices
STR Trade Report •November 27, 2025
The U.S. ITC has instituted Section 337 patent investigations into microcurrent facial toning devices (337-TA-1463; ZIIP/The Beauty Tech Group) and liquid crystal display devices (337-TA-1462; BH Innovations), while new complaints were filed covering low-profile microwave-hood combinations (Whirlpool) and smart wearables (Ouraring). Named and proposed respondents span the U.S., China, Hong Kong, Vietnam, Korea, Canada, Sweden, the UK/Scotland, the Netherlands, and India. Importers in these categories face potential exclusion and cease-and-desist orders that could disrupt supply; map exposure now and prepare design-around, licensing, or sourcing contingencies as cases advance.
FDA Updates Import Alerts Covering Foods, Condoms, Medical Devices
STR Trade Report •November 26, 2025
The FDA issued or modified import alerts in the past week covering baked horse mackerel (Japan), black matpe beans (Burma/Myanmar), condoms (Thailand), medical devices (Pakistan), mini fruit jelly bites (Costa Rica), multivitamin powder (Mexico), skin care masks (Spain), and white musli whole (India). Products on an alert’s red list may be detained without physical examination (DWPE), so importers should verify supplier status and be prepared to provide compliance evidence or risk refusal of entry.
CBP Seized $7.3B in Counterfeits in FY2025; Holiday E‑Commerce Risks
CBP Media Releases •November 24, 2025
CBP warned holiday shoppers about counterfeit goods and reported FY2025 seizures of nearly 79 million items valued at over $7.3 billion MSRP nationwide, including $187 million at the Houston/Galveston seaport. Officials highlighted e‑commerce as a major vector for illicit goods and reminded that importing counterfeit merchandise is illegal and can trigger penalties even for individual buyers. Importers, marketplaces, and logistics partners should tighten due diligence and IP controls on electronics, toys, apparel, medications, and auto parts to avoid enforcement actions.
CBP Blocks $776K in Counterfeit Kids’ Toys Bound for West Virginia
CBP Media Releases •November 24, 2025
CBP officers at the Norfolk–Newport News Area Port seized 17,634 counterfeit children’s items—plush toys, backpacks, music boxes, snow globes and more—arriving from China and destined for Wood County, WV, appraised at $776,562 MSRP. Detained in September and seized October 29, 2025 after CEE and rights-holder verification, the goods infringed brands including Despicable Me, Harry Potter, Hello Kitty, Mario, Mickey Mouse and Pikachu. With CBP reporting 32 million counterfeit goods seized in FY2024 ($5.4B MSRP), importers should expect heightened holiday-season scrutiny on character-branded kids’ merchandise and ensure airtight IPR compliance.
USMCA Labor Watch: Facility-specific risks and policy signals
U.S. Initiates USMCA Labor Review of Freixenet Facility in Mexico
USTR Press Releases •November 26, 2025
The United States has requested that Mexico review alleged denials of workers’ rights at a Freixenet facility under USMCA’s Rapid Response Labor Mechanism. Under the mechanism, Mexico typically has 10 days to accept the request and 45 days to investigate; outcomes can include suspension of preferential tariff treatment for shipments from the facility. Importers and distributors should monitor the case closely for potential supply disruptions and ensure labor due-diligence documentation is in order.
U.S. Triggers USMCA Labor Review at Corporación de Occidente Plant
USTR Press Releases •November 26, 2025
The United States has asked Mexico to review alleged violations of workers’ rights at the Corporación de Occidente facility under the USMCA Rapid Response Labor Mechanism. If a denial of rights is confirmed, the U.S. could impose facility-specific trade measures that restrict shipments until remediation. Importers sourcing from the plant should assess exposure and prepare for potential delays as Mexico moves through the mechanism’s investigation timelines.
Week Ahead: China Phase I Comments Dec. 1; USMCA Hearing Dec. 3
STR Trade Report •November 27, 2025
USTR will accept public comments through Dec. 1 on China’s compliance with the Phase I trade deal, giving stakeholders a window to influence the agency’s assessment and next steps. On Dec. 3, USTR will hold a hearing on the USMCA that could shape oversight priorities and implementation across North America. Companies exposed to China or North American trade should file inputs and monitor outcomes for potential shifts in enforcement and market access focus.
CBP Programs & Operations: Trusted trader, staffing, and FTZ updates
CBP Tests Expanded CTPAT Eligibility for Asset and Non-Asset 3PLs
STR Trade Report •November 26, 2025
CBP will pilot expanded CTPAT participation for 20 third-party logistics providers—10 asset-based and 10 non-asset-based—beginning no earlier than Dec. 1 for up to five years. The initiative could extend trusted trader benefits (lower ATS risk scores, fewer exams, priority searches, faster release) beyond currently limited categories like IACs, NVOCCs, and customs brokers. Participants must meet strict criteria, including involvement in international cargo, limited subcontracting, required licensure/bonding, no unresolved CBP debt, and a staffed office in the U.S., Canada, or Mexico.
CBP adds 26 partners to boost hours at ports of entry
CBP Media Releases •November 26, 2025
U.S. Customs and Border Protection named 26 tentative partners under its Reimbursable Services Program, enabling expanded customs, immigration and agriculture inspections—and extended operating hours—at selected airports and seaports nationwide. For shippers, carriers and airport/port operators, the agreements promise added capacity and faster clearances at participating locations; since 2013, the program has delivered 1.65 million extra processing hours supporting 21.8 million travelers and 2.4 million vehicles, with cost-recovery parameters set by statute based on airport size.
FTZ Board Approves Multi-Sector Production; Denies Logitech Electronics Request
STR Trade Report •November 26, 2025
The FTZ Board approved new or limited production authority across multiple sectors—including pharmaceuticals (AstraZeneca, Merck, Pfizer, Piramal), electronics components (Eagle Electronics, Rincon Power), crop protection (Corteva), watches (Philip Stein), renewable fuels (Phillips 66 in CA/NJ/LA), and aircraft parts (Rohr). It denied Logitech’s request for audio/visual and gaming equipment production in FTZs in Kentucky and California; approved facilities can now leverage duty deferral/inversion and streamlined customs.
CBP targets cabotage at Nogales; drivers returned, border crossing cards at risk
CBP Media Releases •November 25, 2025
CBP Border Patrol at the I‑19 checkpoint near Nogales, AZ intercepted two tractor‑trailers in separate incidents, finding Mexican drivers in violation of cabotage and immigration rules. The drivers were returned to Mexico, their Border Crossing Cards moved toward revocation, and the vehicles towed—underscoring active cabotage enforcement in the Arizona corridor. Cross‑border carriers should audit routing and paperwork to avoid U.S.-to‑U.S. domestic hauls that trigger penalties and credential loss.
WTO Rules & Disputes: Transparency moves and remedy battles
WTO GPA Committee Expands Public Access to Deliberations and Documents
WTO Latest News •November 25, 2025
At its year-end meeting, the WTO’s Government Procurement Committee approved a transparency measure broadening which materials are publicly available, including annotated agendas and written summaries of informal sessions, either immediately or after a set delay. The move gives non-GPA members and the public greater visibility into work programs—such as sustainable procurement—helping companies and governments better anticipate policy shifts and market-opening opportunities as the WTO pursues practical institutional reforms.
WTO Plastics Dialogue advances draft MC14 statement, updates technical deliverables
WTO Latest News •November 24, 2025
WTO members in the Plastics Dialogue unveiled a draft ministerial statement for MC14 (March 2026) and circulated revised, non‑prescriptive technical documents on measuring embedded plastics trade, regulating single‑use plastics, waste‑management services and technologies, and non‑plastic substitutes. Members were invited to submit written comments by 28 November 2025, with a follow‑up meeting expected in December. With 83 co‑sponsors representing nearly 90% of global plastics trade, the initiative could shape forthcoming national measures and market access conditions for plastics and substitutes.
WTO adopts frozen fries compliance report; EU appeals Indonesia steel ruling
WTO Latest News •November 23, 2025
The WTO Dispute Settlement Body adopted a compliance panel report confirming Colombia has not fully implemented rulings against its anti-dumping duties on frozen fries from Belgium, Germany and the Netherlands; Colombia said it will comply. The EU appealed the panel decision in DS616 on its AD/CVD measures on Indonesian stainless steel, halting adoption while the Appellate Body remains inactive; Indonesia criticized the move but signaled openness to Article 25 arbitration as the EU urged joining the MPIA. With 130 members again pushing—unsuccessfully—to launch Appellate Body appointments and the U.S. maintaining its block, uncertainty persists over timelines for resolving trade remedy disputes.
WTO Agriculture Committee Wraps TRQ Review, Tightens Transparency, Flags Food Security Risks
WTO Latest News •November 23, 2025
The WTO Committee on Agriculture concluded the second triennial review of the Bali TRQ Decision, advancing transparency on in- and out-of-quota tariffs and origin-specific allocations; absent objections by 2 December 2025, the draft report will be adopted. Members ran a robust peer review with 115 questions—18 new (12 from India)—scrutinizing supports, safeguards, stockholding and other measures, while revisiting implementation gaps in notifications. UN agencies reported persistent hunger pressures (WFP: 318 million facing acute food insecurity in 2026) despite generally good grain supplies, underscoring continued policy and market vigilance for agri-trade.
Register by 28 Nov for WTO–World Bank Services Trade Conference
WTO Latest News •November 23, 2025
The WTO Secretariat and the World Bank will host the Trade in Services for Development Conference in Geneva on 3–4 December; registration closes 28 November. The event will debut capacity-building tools—the Trade in Services Competitiveness Dashboard and a handbook on good regulatory practices—and convene senior officials, international organizations, and business, with opening remarks by DG Ngozi Okonjo-Iweala and World Bank VP Pablo Saavedra. For trade professionals, this is a timely chance to access new tools and engage counterparts shaping services policy and market access for developing economies.
