GettyImages-2213384286-2.png

09/25/2026

Commerce Department Issues Guidance on New Tariff Adjustments for Specialty Pharmaceuticals

Check out this week's Customs Corner to read about Commerce Department Issues Guidance on New Tariff Adjustments for Specialty Pharmaceuticals, and more!

Trade and Customs Updates

Commerce Department Issues Guidance on New Tariff Adjustments for Specialty Pharmaceuticals

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Federal Register notice dated September 21, outlining new guidance and procedures for tariff adjustments on specialty pharmaceuticals and their associated ingredients. These changes stem from Presidential Proclamation 11020, which was enacted on April 2, 2026, and include technical updates to the Harmonized Tariff Schedule of the United States (HTSUS).

 

The new tariff adjustments will take effect at 12:01 a.m. Eastern Time on September 29, 2026. Annexes 1 and 2 of the Federal Register notice list the impacted HTSUS numbers and the affected countries.

 

The pharmaceuticals covered by this adjustment include drugs and ingredients designated as orphan products, nuclear medicines, plasma-derived therapies, fertility drugs, cell and gene therapy products, antibody drug conjugates, medical countermeasures for chemical, biological, radiological, and nuclear threats, as well as products for animal health. These items will qualify for a Section 232 zero tariff rate if they originate from jurisdictions with a current or impending trade and security framework agreement with the U.S., or if they are determined to meet an urgent U.S. health need.

 

The notice also details procedures for submitting information to the Commerce Department to demonstrate that specific pharmaceutical imports fulfill an urgent health requirement in the United States.

 

Additionally, the Commerce Department’s announcement includes five technical corrections to Annex I and one correction to Annex IV of Presidential Proclamation 11020.

 

Reference:

Federal Register :: Guidance and Procedures for Implementing Tariff Adjustments for Specialty Pharmaceuticals and Associated Pharmaceutical Ingredients and Technical Corrections to the Harmonized Tariff Schedule of the United States for Duties Imposed Under Proclamation 11020

U.S. Issues Temporary Import Ban on Certain Polysilicon Products Following Presidential Proclamation

The U.S. Department of Commerce will publish a Temporary Final Rule (TFR) on September 24, 2026, establishing new procedures for an import ban on specific polysilicon products, as mandated by Presidential Proclamation 11052 “Adjusting Imports of Polysilicon and Its Derivatives Into the United States” (91 FR 51975, August 6, 2026).

 

Under the new rule, if Commerce notifies CBP that an IOR is bringing in polysilicon products at volumes significantly higher than their historical averages or if a new IOR exceeds designated weekly quantity limits, that importer will be prohibited from making further entries of certain polysilicon products into the U.S. before December 4, 2026. During this period, affected importers may transfer goods to a bonded warehouse, but are barred from entering these goods for consumption until after the restriction lifts.

 

Importers subject to these restrictions may apply to Commerce for a waiver of the prohibition. For further guidance or questions, members of the importing community are encouraged to contact Commerce at [email protected].

 

Reference:

CSMS # 69994928 - GUIDANCE: Import Ban of Certain Polysilicon Products Under Proclamation 11052

Federal Register :: Measures To Restrict Stockpiling of Polysilicon and Polysilicon Derivatives Under Proclamation 11052

USTR Issues Amendments to Section 301 China Tariff Exclusions to Align with Updated HTSUS Codes

On September 2, 2026, the Office of the U.S. Trade Representative (USTR) published a Federal Register Notice (91 FR 56538) announcing conforming amendments to four product exclusions under the Section 301 China tariffs, in response to changes in the ten-digit statistical reporting categories of the Harmonized Tariff Schedule of the United States (HTSUS) that take effect July 1, 2026.

 

These changes clarify that, for goods imported on or after July 1, 2026, the relevant exclusions now reference statistical reporting numbers 8413.91.9039, 8413.91.9046, 8413.91.9059, 8413.91.9099 (for notes (i)(4)-(6)), and 3926.90.9915 or 3926.90.9920 (for note (iv)(4)), instead of the previous HTSUS codes.

 

ACE will support these amendments as of noon on September 23, 2026. 

 

Reference:

CSMS # 69990649 - GUIDANCE: Section 301 China Conforming Amendment

Customs Brokers Reminded to Complete Mandatory Continuing Education and File Triennial Status Report by Early 2027

CBP is reminding all individually licensed customs brokers to complete their mandatory 20 hours of Continuing Education (CE) by January 31, 2027, and to certify these credits when filing the required Triennial Status Report (TSR). The TSR filing period will open in mid-December 2026 and close on February 28, 2027, with the exact portal opening date to be announced via CSMS. As per 19 CFR 111.30(d) and 19 CFR 111.102, failure to complete the CE requirement or file the TSR will result in license revocation.

 

To maintain active licensure for the current triennial period, brokers must earn 20 CE credits between January 1, 2025, and January 31, 2027, by completing accredited training—identifiable by the CE logo—from CBP-selected accreditors or the federal government. Proof of course completion should be retained for at least three years for potential audits.

 

When filing the TSR, brokers must certify CE compliance, pay the $100 triennial fee, and update their contact information. TSR submissions are required from all brokers, but only those with active individual licenses must fulfill the CE credits. All filings must be completed electronically via the eCBP portal at https://e.cbp.dhs.gov/ecbp/#/main.

 

Reference:

CSMS # 69990316 - MANDATORY: Complete Broker Continuing Education Requirements by January 31, 2027

NCSD Launches New Webinar Series on Innovation and Emerging Technology in Trade

The National Commodity Specialist Division (NCSD), part of the Office of Trade, has announced the next round of approximately 30 educational webinars aimed at supporting both internal and external stakeholders. This year’s series, themed “The Future of Trade: Innovation and Emerging Technology,” will spotlight rapidly evolving technological trends while continuing to offer essential classification guidance to promote legitimate trade.

 

Scheduled from May through September 2026, most webinars will begin at 1:30 p.m. Eastern Time and run for about an hour, with exceptions on September 22, 24, and 25, which will start at 11:00 a.m. ET. Registration is now open for the September sessions.

 

Interested participants can register at Trade Outreach Webinars | U.S. Customs and Border Protection

 

The September schedule is below: 

 

Reference:

 

CSMS # 69733635 - National Commodity Specialist Division (NCSD) September 2026 Webinars

Get expert advice on customs and foreign trade, direct from our comprehensive customs brokerage and trade services teams. 

Contact an expert