North America: International Law

On August 10, 2026, the Department of Justice filed its opening brief in the consolidated Federal Circuit appeal challenging the Court of International Trade’s universal injunctions governing IEEPA duty refunds. The government’s own brief concedes that those injunctions now matter to exactly one group: importers with finally liquidated entries who have not filed suit. If the Federal Circuit vacates, that group has no administrative path to a refund, because CBP has told the court it lacks statutory authority to reliquidate finally liquidated entries on its own initiative.

On August 13, 2026, President Trump issued a new proclamation under Section 232 of the Trade Expansion Act imposing tariffs on certain imported unmanned aircraft systems (UAS) and their components. The Administration concluded that the United States’ dependence on foreign-manufactured UAS and critical UAS components threatens to impair national security by limiting the domestic industrial base and creating vulnerabilities in critical supply chains.

CBP published a federal register notice on August 19, 2026 announcing that, beginning September 18, 2026, it will immediately void importer of record numbers when the information on CBP Form 5106 is inaccurate or incomplete. A voided IOR number is invalid for every purpose, including making entry, which means cargo stops at the port with no advance warning. This article explains what CBP is verifying, why several long-accepted industry practices are now defects, and the corrective steps importers and brokers should take before the enforcement date.