TradeLane

On June 3, 2026, the White House issued a sweeping Executive Order titled “Strengthening Customs Enforcement,” directing the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) to implement significant reforms that will materially reshape importer obligations, enforcement standards, and supply chain transparency requirements. While the changes will roll out over the coming months, and the specifics are unknown, the direction is clear: heightened scrutiny, stricter eligibility standards, and reduced flexibility in enforcement outcomes.

In 2010, the United States Congress passed the Dodd-Frank Act, directing the Securities and Exchange Commission (SEC) to require certain companies to disclose their use of conflict minerals when those minerals are essential to the functionality or production of a manufactured product. Since then, the connection between SEC reporting and supply chain compliance has become increasingly evident, starting with conflict minerals and expanding into the broader discussion on supply chain security, ethical sourcing, and responsible operations. Ultimately, these practices deliver significant benefits for both companies and their stakeholders.

On October 30, 2025, the White House suspended the implementation of the BIS 50% rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities for one year, starting on November 10, 2025. This delay is due to a reciprocal agreement with China. The rule would have extended export-licensing requirements to companies' majority-owned by parties on the Entity List, Military End-User List, or certain OFAC Specially Designated Nationals. The delay in implementation of this rule has generated a mixed reaction from the export industry.

U.S. importers of steel, aluminum, and certain derivative products continue to face heightened scrutiny under Section 232. While the tariffs themselves are well established, recent clarification from U.S. Customs and Border Protection (CBP)—particularly from the Base Metals Center of Excellence and Expertise (CEE)—has reinforced how steel and aluminum content must be valued and reported for duty purposes. 

Recent clarification from U.S. Customs and Border Protection (CBP), including guidance from the Base Metals Center of Excellence and Expertise (CEE), has reinforced how steel and aluminum content must be valued and reported for Section 232 duty purposes, with important implications for importer compliance and reasonable care