Trade Compliance Monthly · October 2026
NORTH AMERICA TRADE COMPLIANCE BRIEF
Solar IV Injury Finding, China Trailer Orders and Shifting Canadian Surtax Scope
This issue covers October 1 to October 31, 2026. In the United States, the USITC issued a final affirmative injury determination in the Solar IV investigation into crystalline silicon photovoltaic cells, whether or not assembled into modules, from India, Indonesia and Laos, and made final injury determinations on van-type trailers and subassemblies from China in Investigation Nos. 701-TA-781 and 731-TA-1768 (Final). Commerce is issuing antidumping and countervailing duty orders on van-type trailers and subassemblies from China applicable October 28, 2026. The CIT upheld a Commerce scope ruling on an off-grid solar charging module from China. On Canada, CBP stated in CSMS # 70314289 that, effective 12:01 a.m. eastern time on October 30, 2026, 21 listed HTSUS classifications are no longer subject to the 50% Section 338 duty and 100 more are added, and Proclamation 11076 of October 23, 2026 modified the scope of the 50% additional duties on certain Canadian motor vehicle products. CBP proposed earlier filing deadlines and additional data elements for low-cost imports, extended the Entry Type 13 compliance date for international mail to January 20, 2027, and issued Harmonized System Updates 2625 and 2626 and ACE error code 336. In Canada, CBSA made final dumping and subsidy determinations on unarmoured building cables from China under SIMA.
Solar IV injury finding and China trailer orders
Section summaryThe USITC issued a final affirmative injury determination in its Solar IV investigation into crystalline silicon photovoltaic cells, whether or not assembled into modules, from India, Indonesia and Laos, finding that dumped and subsidized imports materially injure a U.S. industry. The USITC also determined in Investigation Nos. 701-TA-781 and 731-TA-1768 (Final) that a U.S. industry is materially injured by reason of imports of van-type trailers and subassemblies from China. Commerce is then issuing antidumping and countervailing duty orders on those trailers and subassemblies from China, applicable October 28, 2026, after affirmative final determinations by Commerce and the ITC. Separately, the CIT denied GameChange Solar Corp.'s motion for judgment on the agency record in Court No. 24-00174, upholding Commerce's final scope ruling that its off-grid solar charging module is within the scope of the 2012 antidumping order on China.
pv magazine USA10.16USITC finds material injury in Solar IV case on cells and modules from India, Indonesia and Laos
The USITC issued a final affirmative injury determination in its Solar IV investigation into crystalline silicon photovoltaic cells, whether or not assembled into modules, from India, Indonesia and Laos, finding that dumped and subsidized imports materially injure domestic solar manufacturers. Commerce is scheduled to issue AD and CVD orders in early November 2026, with combined rates as high as 249% for India, 268% for Indonesia and 219% for Laos. Final dumping margins are 123.04% for all Indian producers with a 126.09% countervailing rate, 94.36% for all Indonesian exporters with countervailing rates of 73.2% to 173.7%, and 65.43% for all Laotian exporters with countervailing rates of 82.03% to 153.67%.
Federal Register · Commerce ITA (AD/CVD)Official10.27Commerce issues AD/CVD orders on van-type trailers and subassemblies from China
Commerce is issuing antidumping and countervailing duty orders on van-type trailers and subassemblies thereof from China, applicable October 28, 2026, after affirmative final determinations by Commerce and the ITC. The China-wide entity's weighted-average dumping margin is 130.86%, with a cash deposit rate of 129.73% adjusted for the export subsidy offset, and the CVD subsidy rate is 134.75% for all listed companies and all others. Antidumping duties apply to unliquidated entries on or after June 15, 2026, and countervailing duties to entries on or after June 5, 2026, excluding entries after the provisional measures period and before publication of the ITC's final injury determination.
Federal Register · USITCOfficial10.19USITC makes final injury determinations on van-type trailers and subassemblies from China
The U.S. International Trade Commission determined in Investigation Nos. 701-TA-781 and 731-TA-1768 (Final) that a U.S. industry is materially injured by reason of imports of van-type trailers and subassemblies from China provided for in HTS subheadings 8716.39.00 and 8716.90.50, found by Commerce to be sold at less than fair value and subsidized by the government of China. The Commission filed its determinations on October 15, 2026, and its views are in USITC Publication 5797 (October 2026). The countervailing duty investigation on imports from Canada was terminated on June 17, 2026 (91 FR 36615), and the investigations regarding Mexico and Canada remain ongoing.
CIT · Slip OpinionsOfficial10.13CIT denies GameChange Solar challenge to scope ruling on off-grid solar charging modules from China
The U.S. Court of International Trade denied GameChange Solar Corp.'s motion for judgment on the agency record in Court No. 24-00174, upholding Commerce's final scope ruling that the company's off-grid solar charging module is within the scope of the 2012 antidumping and countervailing duty orders on crystalline silicon photovoltaic cells from China. In Slip Op. 26-125, Judge Timothy C. Stanceu found the plain scope language dispositive and rejected GameChange's arguments that Commerce failed to identify specific scope language and that the consumer good and off-grid CSPV panel exclusions applied.
Canadian surtax orders on steel and aluminum goods
Section summaryThe items list the Steel Goods and Aluminum Goods Surtax Order and the China Surtax Order (2024) – Steel and Aluminum as measures in this issue. No further details on their terms, rates or effective dates are provided in the source items.
Steel Goods and Aluminum Goods Surtax Order
China Surtax Order (2024) – Steel and Aluminum
Section 338 Canada duty scope changes
Section summaryCBP states in CSMS # 70314289 that, effective 12:01 a.m. eastern time on October 30, 2026, products of Canada classifiable in 21 listed HTSUS classifications, including 1212.21.00, 3920.20.00, 4412.33.06 and 8433.60.00, are no longer subject to the 50% ad valorem Section 338 duty, and 100 more classifications are added. Proclamation 11076 of October 23, 2026 removes certain products of Canada listed in Annex I, Part A from the 50% additional ad valorem duty imposed under Proclamation 11048, as amended, and adds certain products of Canada listed in Annex I, Part B to that duty.
CBP: Section 338 Canada duties end for 21 HTS classifications and extend to 100 more from October 30
CBP states in CSMS # 70314289 that, effective 12:01 a.m. eastern time on October 30, 2026, products of Canada classifiable in 21 listed HTSUS classifications, including 1212.21.00, 3920.20.00, 4412.33.06 and 8433.60.00, are no longer subject to the 50% ad valorem Section 338 duties under HTSUS 9903.03.14, and 100 additional HTSUS classifications become subject to 9903.03.14. The change implements the October 23, 2026 Presidential Proclamation further modifying the scope of Canadian products subject to the motor vehicle duties under Proclamation 11048.
Federal Register · Presidential DocumentsOfficial10.29Trump modifies scope of Canadian motor vehicle products subject to 50% additional duties
Proclamation 11076 of October 23, 2026 removes certain products of Canada listed in Annex I, Part A from the 50% additional ad valorem duty imposed under Proclamation 11048, as amended, and adds certain products of Canada listed in Annex I, Part B to that duty, effective for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on October 30, 2026. The duties apply in addition to duties imposed under section 232 of the Trade Expansion Act of 1962.
White House · Presidential ActionsOfficial10.23Trump proclamation modifies scope of 50% Section 338 duties on certain Canadian motor vehicle products
President Trump issued a proclamation modifying the scope of the 50% additional ad valorem duties imposed under Proclamation 11048, as amended, on certain products of Canada: products listed in Annex I, Part A are no longer subject to the duty, and products listed in Annex I, Part B become subject to it, effective for goods entered for consumption or withdrawn from warehouse for consumption on or after 12:01 a.m. eastern time on October 30, 2026. The duties apply in addition to duties imposed under section 232 of the Trade Expansion Act of 1962, and the HTSUS is modified as provided in Annex II on the same effective date.
CBP low-cost import filing and system updates
Section summaryCBP proposes in a Federal Register filing published October 8 to require earlier filing deadlines and additional data elements for entry type 11, the informal entry process for shipments valued at $2,500 or less, and entry type 13. CBP then extended the compliance date for the new informal entry procedures for international mail from October 22, 2026, to January 20, 2027, a 90-day extension; beginning January 20, 2027, international postal shipments subject to Section 201, 232 or 301 duties, or within the stated scope, fall under the new procedures. CBP issued Harmonized System Update 2625, created September 29, 2026, with 57 harmonized tariff records and 304 ABI records, including Section 232 pharmaceutical updates, and HSU 2626, created October 9, 2026, with 4 harmonized tariff records and 14 ABI records, including Section 232 updates and PGA HTS flagging updates. CBP added ACE cargo release error code 336, INVOICE/MERCH DESC REQUIRED FOR ET13, applying to the Commercial Invoice Description in the SE40 record.
Supply Chain Dive10.14CBP proposes earlier filing deadlines and more data elements for low-cost imports
CBP proposes in a Federal Register filing published Oct. 8 to require earlier filing deadlines and additional data elements for entry type 11, the informal entry process for shipments valued at $2,500 or less, and entry type 13, its processing approach for international mail shipments valued at $2,500 or less. Entry type 11 filings would be due upon or prior to the shipment's arrival instead of within 15 days of arrival, and would add the final deliver-to party as a required data element if different from the consignee.
CBP extends mandatory Entry Type 13 date for international mail to Jan. 20, 2027
CBP extended the compliance date for the new informal entry procedures for international mail from Oct. 22, 2026, to Jan. 20, 2027, a 90-day extension. Beginning Jan. 20, 2027, international postal shipments subject to Section 201, 232 or 301 duties, or within the jurisdiction of a Partner Government Agency, must be filed electronically in the Automated Commercial Environment through the new Entry Type 13 process for informal entry; otherwise formal entry is required. There are no changes to international mail entry procedures before that date, and CBP encourages filers to use the optional Entry Type 13 process during the transition.
CBP issues Harmonized System Update 2626 with Section 232 and NMFS flagging changes
CBP states in CSMS # 70197855 that Harmonized System Update (HSU) 2626, created on October 9, 2026, contains 4 harmonized tariff records and 14 ABI records, including Section 232 updates and PGA HTS flagging updates. The NM8 flag has been removed for National Marine Fisheries Service (NMFS) HTS 0301.19.000. The notice does not state which Section 232 measures or tariff lines the update covers.
CBP issues Harmonized System Update 2625 with Section 232 pharmaceutical changes and CPSC flag updates
CBP states in CSMS # 70220191 that Harmonized System Update (HSU) 2625, created on September 29, 2026, contains 57 harmonized tariff records and 304 ABI records, including Section 232 pharmaceutical updates and corrections to assessment reduction rates for live porcine animals and pork products under the Pork Promotion, Research, and Consumer Information Order. The update changes the CPSC HTS flag from CP2 to CP1 on HTS codes 2404120510, 2404120590, 2404121010, 2404121090, 3604109010, 8506100010, 8506401010, 8506500010, 8506600010, 8506800010, 9613200000, 9404210095, 9404291095 and 9404299095, and removes flag CP2 on HTS code 9613802010. CBP directs Section 232 pharmaceutical questions to traderemedy@cbp.dhs.gov and CPSC flagging questions to itdssupport@cbp.dhs.gov.
CBP adds ACE cargo release error code 336 for ET13 invoice description
CBP states in CSMS # 70188060 that error code 336, INVOICE/MERCH DESC REQUIRED FOR ET13, has been added to the Cargo Release Condition Codes document posted to cbp.gov. The validation rule applies to the Commercial Invoice Description in the SE40 record and will be deployed to the Cargo Release Automated Commercial Environment (ACE) Production environment on October 15, 2026. The document is available in the Supporting Documents section on cbp.gov; filing issues go to a CBP Client Representative or the ACE Help Desk, and Cargo Control and Release questions to CREM@cbp.dhs.gov.
CBSA cable determinations and CARM transition
Section summaryCBSA states that on October 27, 2026, under paragraph 41(1)(b) of SIMA, it made a final determination of dumping and a final determination of subsidizing for unarmoured building cables originating in or exported from China, and under paragraph 41(1)(a) terminated part of the proceeding. Under CARM, CBSA states in Customs Notice 24-37 that, effective October 21, 2024, its commercial processing systems will not accept exporter "RM" program accounts to obtain release of imported goods, and the CARM system will not accept a Commercial Accounting Declaration on that basis. CBSA states in Customs Notice 25-02 that, between October 21, 2024 and January 30, 2026, it will not issue late payment penalties or late payment interest as a CARM transition measure, and that effective January 31, 2026, all accounts with overdue balances are subject to them.
CBSA makes final dumping and subsidy determinations on unarmoured building cables from China
CBSA states that on October 27, 2026, under paragraph 41(1)(b) of SIMA, it made a final determination of dumping and a final determination of subsidizing for unarmoured building cables originating in or exported from China, and under paragraph 41(1)(a) terminated the subsidy investigation for goods exported by Tianjin Feiya Fengda Wire & Cable Technology Co., Ltd. because the subsidy amount was insignificant (less than 1%). The subject goods are usually imported under tariff classification numbers 8544.49.00.19 and 8544.49.00.90, and may also be imported under 7408.11.10.00, 7408.19.00.10, 7605.29.00.00 and 7614.90.00.00, in particular as conductors to be further processed into UBC.
CARM: End of Release Prior to Payment (RPP) Transition Period
CBSA to resume late payment penalties and interest on overdue CARM accounts from January 31, 2026
The Canada Border Services Agency states in Customs Notice 25-02 that, between October 21, 2024 and January 30, 2026, it will not issue late payment penalties or late payment interest as a CARM transition measure. Effective January 31, 2026, all accounts with an overdue balance from the January 2026 statement of account will be subject to late payment penalties, and late payment interest will start accruing on overdue balances and appear on the statement of account issued February 25, 2026. Accounts not paid by the specified due date will be subject to collection measures by the Canada Revenue Agency.
CBSA stops accepting exporter BN15 accounts for release and accounting under CARM
CBSA states in Customs Notice 24-37 that, effective October 21, 2024, its commercial processing systems will not accept exporter "RM" program accounts to obtain release of imported goods, and the CARM system will not accept a Commercial Accounting Declaration quoting an exporter BN15. Only BN15s set up with an importer or importer/exporter "RM" account profile can obtain release and account for goods.