Enforcement Tightens, Data Rules Expand, and USMCA Automation Advances
NEWSLETTER | Trade Insight AI
Trade Insight AI Rolls Out Automated, Audit-Ready USMCA Origin Engine
Trade Insight AI • November 19, 2025
Trade Insight AI launched a BOM-driven USMCA rules-of-origin engine that ingests product data via file or API and applies version-controlled tariff shift, RVC, de minimis, and set rules. It returns a clear qualify/fail decision with citations, RVC math, flagged data gaps, and an audit-ready memo per SKU, plus actionable remediation guidance to help products qualify. For importers, exporters, brokers, and manufacturers, the tool aims to speed determinations, standardize compliance, reduce audit risk, and unlock duty savings at scale.
Immediate Compliance: New Data and Security Requirements
CBP Expands ACAS: Immediate New Data Requirements for Air Cargo
STR Trade Report •November 21, 2025
CBP issued an interim final rule, effective Nov. 21, expanding ACAS pre-loading data, including making consignee email and phone mandatory and adding conditional fields such as device identifiers, product-listing links, shipping cost, and biographic data. Driven by heightened air cargo security concerns, carriers, forwarders, and e-commerce filers must update systems now to collect and transmit the expanded data prior to loading U.S.-bound cargo; comments are due Jan. 20, 2026.
DHS finalizes biometric entry/exit rule, expanding collection across all modes
CBP Media Releases •November 20, 2025
Effective Dec. 26, 2025, DHS’s final rule authorizes CBP to collect facial biometrics from all noncitizens at air, land, and sea ports of entry and exit, removing exemptions (including diplomats and most Canadian visitors) and extending collection to sea departures, private aircraft, vehicles, and pedestrian crossings. Carriers and port operators should prepare for integration with CBP’s Traveler Verification Service, facility/process updates, and opt-out workflows for U.S. citizens, noting strict data rules (12-hour deletion for U.S. citizens; up to 75-year retention for noncitizens). Public comments close Nov. 26, 2025, with operational impacts expected across airports, seaports, and land borders.
DEA Puts 4-CMC in Schedule I; Import/Export Controls Start Dec. 17
STR Trade Report •November 19, 2025
The DEA issued a final rule effective Dec. 17 placing 4‑chloromethcathinone (4‑CMC) and its salts and isomers in Schedule I of the Controlled Substances Act. This designation triggers full Schedule I controls on importing, exporting, manufacturing, distribution, research, and possession, requiring DEA authorization and exposing violators to administrative, civil, and criminal penalties; affected firms should screen products and update compliance procedures before the effective date.
Enforcement Watch: Forced Labor, Origin, and Penalties
DOJ Targets $86M Duty Evasion via FTA Transshipment, Origin Fraud
STR Trade Report •November 20, 2025
The Justice Department, through the interagency Trade Fraud Task Force, filed charges against a foreign company and employees for allegedly evading more than $86 million in duties on $1.2 billion of imports by transshipping through an FTA partner and falsely claiming origin, and by swapping U.S. scrap for foreign-made goods labeled as U.S.-made. CBP had cautioned the scheme would fail origin verification and that converting U.S. scrap abroad constitutes substantial transformation, yet the defendants proceeded; penalties could reach up to 20 years’ imprisonment and fines up to the greater of $500,000 or twice the gain or loss. For importers, the case underscores intensified criminal enforcement around FTA rules of origin and transshipment and the need for verifiable origin documentation.
CBP Detains Mauritius Apparel Imports Under New Forced Labor WRO
STR Trade Report •November 19, 2025
CBP issued a withhold release order effective Nov. 18 directing detention at all U.S. ports of textiles, apparel, and garments produced in Mauritius by Firemount Group Ltd. The action, citing indicators including abuse of vulnerability, debt bondage, deception, and intimidation, is enforced under 19 U.S.C. §1307; importers must re-export or destroy detained goods or prove they were not made with forced labor. This brings CBP’s active actions to 54 WROs and nine findings, signaling elevated apparel supply chain risk and the need for robust labor due diligence and traceability.
FMC Recovers $1.35M for Carrier Tariff and Publishing Violations
STR Trade Report •November 20, 2025
The Federal Maritime Commission finalized two compromise agreements totaling $1.35 million tied to alleged Shipping Act and FMC rule violations involving tariff compliance in liner services. A vessel-operating common carrier paid $1.3 million for providing services inconsistent with its tariff and for failing to publish complete tariffs over more than a year and numerous shipments; a non-vessel-operating common carrier paid $50,000 for similar issues. The cases signal continued FMC scrutiny of tariff publication and adherence, urging carriers and NVOCCs to audit tariffs and rating practices.
Rising CBP Enforcement: Practical Playbook for CF-28/29 and Penalties
STR Trade Report •November 21, 2025
CBP has intensified trade enforcement in 2025, issuing more and faster CF 28 information requests and CF 29 Notices of Action, applying tougher standards, and escalating penalties—often routing responses to DOJ for potential 19 U.S.C. 1592 actions. Importers should treat every response as litigation-ready: analyze the request’s purpose, preserve evidence, ensure complete and consistent submissions, draft clear, well-supported protests, and set an early defense strategy to influence penalty levels, culpability findings, or settlement outcomes.
ITC 337 IPR actions target DRAMs, antibody-drug conjugates, semiconductors; enforcement opens
STR Trade Report •November 21, 2025
The ITC received new Section 337 complaints covering DRAM devices and products (Netlist), antibody‑drug conjugates (AbbVie, ImmunoGen), and semiconductor devices/computing products (Adeia), naming respondents across the U.S., South Korea, China, Hong Kong, Denmark, and the Netherlands. The Commission also instituted an enforcement proceeding to assess potential violations of existing remedial orders in 337‑TA‑1276 involving light‑based physiological measurement devices. These actions can result in exclusion and cease‑and‑desist orders, posing near‑term import and downstream supply risks for tech and life sciences firms; affected importers and OEMs should assess exposure and monitor fast ITC timelines.
Tariffs and Market Access: Korea, Switzerland/Liechtenstein, Saudi Arabia
U.S., Korea Detail 15% Tariff Framework; Seoul Lifts Auto Cap
STR Trade Report •November 19, 2025
Washington and Seoul released implementation details for their July trade package, anchoring a 15% reciprocal tariff framework. The U.S. will cut Section 232 duties on Korean autos, auto parts, timber and wood products to 15%, remove supplemental reciprocal tariffs for generics, chemical precursors, some natural resources and certain aircraft/parts, and cap any future 232 tariffs on Korean pharmaceuticals at 15% while pledging no‑less‑favorable semiconductor terms. Korea will scrap the 50,000‑unit cap for FMVSS‑compliant U.S. vehicles, streamline emissions and ag‑biotech approvals, commit to nondiscriminatory digital policies and cross‑border data flows, and coordinate with the U.S. on forced‑labor and duty‑evasion enforcement, with implementation talks continuing in December.
U.S., Switzerland, Liechtenstein Outline 15% Tariff Cap, Market Openings
STR Trade Report •November 20, 2025
Washington announced a trade framework with Switzerland and Liechtenstein targeting early 2026 that would set U.S. duties on originating goods at the higher of MFN or 15%—down from 39%—apply MFN-only on select products, and cap combined MFN and Section 232 tariffs on Swiss/Liechtenstein pharmaceuticals and semiconductors at 15%. Switzerland and Liechtenstein would cut tariffs across agriculture and industry, open TRQs for U.S. poultry, beef, and bison, and ease market entry via mutual treatment of conformity assessment bodies plus facilitated recognition of U.S. auto safety standards and FDA-cleared medical devices. The framework also advances digital customs, restraint on digital services taxes, cooperation against transshipment and forced labor, and alignment on export controls and investment screening—promising cost relief and regulatory predictability if finalized.
Saudi Arabia Recognizes U.S. Auto Safety Standards, Easing Market Entry
USTR Press Releases •November 19, 2025
Washington and Riyadh signed an exchange of letters under which Saudi Arabia will recognize U.S. Federal Motor Vehicle Safety Standards as fully meeting its automotive safety requirements. The change removes a key non-tariff barrier by eliminating duplicative testing and certification, accelerating approvals and lowering compliance costs for U.S.-made vehicles entering the Saudi market. Exporters should watch for implementation guidance and any remaining documentation or labeling steps required by Saudi authorities.
U.S. trade frameworks with Korea, Switzerland, Liechtenstein, Latin America boost market access
USTR Press Releases •November 17, 2025
The U.S. announced a joint fact sheet with South Korea and trade frameworks with Switzerland, Liechtenstein, Argentina, Ecuador, El Salvador, and Guatemala aimed at expanding market access and investment. Industry groups highlight prospective commitments to curb discriminatory digital measures (e.g., network usage fees, digital services taxes), enable cross-border data flows, reinforce critical mineral and textile supply chains, and ease non-tariff barriers—especially for dairy and CAFTA-DR–qualified textile/apparel trade with El Salvador and Guatemala. If finalized and implemented, these packages could open new opportunities for manufacturers, ag exporters, and digital service providers, though timelines and enforceability will determine impact.
USMCA and North America: Compliance and SME Growth
U.S. Seeks Mexico Review at Yazaki; Suspends Import Liquidations
USTR Press Releases •November 19, 2025
The United States invoked the USMCA Rapid Response Labor Mechanism to address alleged interference and retaliation against union activity at Yazaki’s León, Guanajuato facility following a petition by independent union SINTTIA. The U.S. has suspended liquidation of unliquidated entries of automotive wire harnesses and related components from the plant; Mexico has 10 days to accept the request and, if it does, 45 days to complete its review. Importers should anticipate delayed final duty assessments and monitor for potential remedial measures depending on the outcome.
USMCA SME Dialogue gathers 250 stakeholders, sets priorities for 2026 review
USTR Press Releases •November 19, 2025
North American trade officials and nearly 250 stakeholders convened in Phoenix for the fourth USMCA SME Dialogue to map small-business opportunities and priorities ahead of the 2026 joint review, with sessions covering AI and technology, sports and tourism, and workforce development. The event featured a cross-border SME matchmaking program led by Arizona partners to connect firms with industry leaders, aiming to translate the SME chapter into concrete deals. With Canada and Mexico as top U.S. SME markets—over 88,000 firms exporting $74B to Canada and 50,000 exporting $107B to Mexico—the dialogue signals intensified government support for SME-led growth across a $1.86T USMCA trade relationship.
Multilateral and WTO Watch
WHO–WIPO–WTO convene AMR forum on IP, access and supply chains
WTO Latest News •November 19, 2025
The three agencies will host a 12th technical symposium on 11 December to address antimicrobial resistance through IP incentives, technology transfer, trade rules, market dynamics, and supply chain strengthening to reduce shortages and improve equitable access. Opening remarks by the Directors‑General and a keynote by Prof. Ramanan Laxminarayan set the stage for sessions spanning public health, IP and trade. Hybrid in Geneva; registration closes 9 December—useful for stakeholders in pharma trade, procurement, and policy planning.
WTO Fish Fund awards $2.9m to 26 projects; next call early 2026
WTO Latest News •November 17, 2025
The WTO Fish Fund approved 26 grants totaling USD 2.9 million to help developing and least-developed members implement the Fisheries Subsidies Agreement, with a second call for proposals slated for early 2026. Backed by over USD 18 million in deposits, commitments and pledges and delivered with FAO, IFAD and World Bank support, the mechanism accelerates implementation for ratifying members; 116 WTO members have accepted the agreement to date.
Germany backs WTO capacity-building with EUR 500,000 for developing members
WTO Latest News •November 16, 2025
On 17 November, Germany committed EUR 500,000 to the WTO Global Trust Fund to support technical assistance and capacity-building for developing economies and LDCs, with Amb. Carmen Heidecke signing the MoU in Geneva. The contribution, part of Germany’s CHF 27.1 million in support since 2001, will fund training that helps officials implement WTO rules and engage more effectively—potentially improving compliance and market access for firms operating in these markets.
Nepal undergoes third WTO trade policy review, 17–19 November 2025
WTO Latest News •November 16, 2025
The WTO Trade Policy Review Body will examine Nepal’s trade and related policies on 17 and 19 November 2025, based on independent Secretariat and Government reports. The review gives trading partners and businesses updated visibility into Nepal’s regulatory framework and implementation of WTO commitments, with chair’s concluding remarks included in the documentation. Stakeholders engaging Nepal should monitor the executive summary and full reports for signals on policy direction and potential market access issues.
Year-End Outlook: What Will Shape 2026
2025 Trade Year-in-Review: Tariff Expansions, ACE Upgrades, Enforcement Shifts
STR Trade Report •November 21, 2025
A year-end roundup highlights developments set to shape 2026: expanded steel and aluminum tariffs, ACE interoperability tests, heightened CBP seizures and enforcement, and a CIT ruling clarifying “part of a part” classifications. DOJ narrowed certain export enforcement work and dissolved its Corporate Enforcement Unit, while the White House curtailed some trade agencies’ regulatory authority and CBP extended e-filing pilots for vessel entrance and clearance. Importers and exporters should reassess duty exposure, classification strategies, and compliance programs, and track ACE and agency rulemaking timelines.
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