---
title: What US Importers Should Read About China | China Agent
description: "A library for US importers buying from China: what CBP, USTR and the White House changed in 2025 and 2026, by topic, each with a short note from us."
---

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# What US importers buying from China should read

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*Last updated: 12 October 2026*

This is a reading list for US importers buying from China, and every link on it comes with a short note from us on what the piece says and what it leaves open on the China side. China Agent has worked on the client side in China since 2009. Today it is a Hong Kong company with people in Guangzhou, Foshan, Yiwu, Shenzhen and Jinan.

We start with the official record, newest first, then go topic by topic: importer identity, forced labor, factory or trading company, tariffs, de minimis, transshipment and contracts.

## Latest additions

New items appear here first, with the date we added them, before they move into their section. The library opened on 27 September 2026.

**Added 12 October 2026**

- **8 October 2026. CBP proposes earlier filing and bond coverage for shipments of $2,500 or less.** [CBP proposed rule: Low-Value Shipments](https://www.federalregister.gov/documents/2026/10/08/2026-20650/low-value-shipments) (Federal Register, docket USCBP-2026-0298, comments due 7 December 2026) CBP proposes that informal entries of $2,500 or less be filed electronically on or before arrival, instead of within 15 days after. The entry would also name the final deliver-to party when it differs from the consignee. CBP also proposes a new electronic mail entry type. Type 11 informal entries and that new mail entry type would need a bond or a cash deposit, with a new $1,000 minimum for liquidated damages. A consignee that doesn't own or buy the goods, such as a forwarder, carrier or postal operator, would use a licensed broker as importer of record. It's a proposal, not a rule yet. If your supplier in China ships small orders or samples to you or your customers, now is a good time to find out who files those entries and whether the value and description on the factory's invoice would hold up. Your customs broker or counsel can tell you how it would apply to you.
- **7 October 2026. The original 2018 China Section 301 tariffs stay in place while USTR reviews them.** [USTR notice: Continuation of Actions, China Section 301 (technology transfer, IP and innovation)](https://www.federalregister.gov/documents/2026/10/07/2026-20510/continuation-of-actions-chinas-acts-policies-and-practices-related-to-technology-transfer) (Federal Register) USTR received continuation requests from domestic producers and trade associations for both 2018 actions, so the tariffs did not lapse on their July and August anniversaries and stay in effect. USTR will now run the full four-year review and says a separate notice will describe it, so rates could still change later. For now, plan next year's prices with the 301 duty included, and make sure the HTS code on your entries matches what the actual factory makes, since that code decides which list your goods fall on.
- **[Justice Department: civil suit against a kitchen and bath products importer over transshipped, undervalued goods from China](https://www.justice.gov/opa/pr/united-states-files-civil-suit-recover-customs-duties-and-fraud-penalties-exceeding-280m)** (U.S. Department of Justice, 7 October 2026) The government has sued an importer of cabinets, vanities, quartz and ceramic tile from China, and its chief executive personally, at the Court of International Trade. It alleges that across 503 entries the goods were transshipped, undervalued and misdescribed through shell companies. DOJ notes these are allegations and no liability has been decided. The case turns on facts we help you pin down in China: which factory really made the goods, which legal entity sold them, and what was actually paid.

## What changed for US importers in 2025 and 2026: the official record

Official documents only, from CBP, the Federal Register, DHS, the Justice Department, USTR, the White House and the Supreme Court. They run newest first, after one standing CBP page at the top.

- **Standing reference: the importer identity form.** [CBP: Create/Update Importer Identity Form (CBP Form 5106)](https://www.cbp.gov/trade/programs-administration/entry-summary/cbp-form-5106) (U.S. Customs and Border Protection, page last modified 25 August 2025) This is CBP's home page for the form that sets up your importer record, and it now links CBP's FAQs and system messages on voided importer numbers. CBP says it is revising the form and will post the changes here, so start on this page before you file or update. The form only covers you, so who actually makes your goods is still a question you settle on the China side.
- **27 September 2026. The US and China name goods that may get lower tariffs.** [White House: U.S.-China Board of Trade product lists](https://www.whitehouse.gov/releases/2026/09/u-s-china-board-of-trade/) (The White House, with the terms of reference and both product lists attached) The White House posted the lists of goods the US and China will consider for lower tariffs. The US list of Chinese goods includes toys, bed and table linen, and small kitchen appliances like toasters and coffee makers. The terms of reference posted with it say any cut goes through each side's own legal process, so no rate or date is set and today's duties still apply. Some lines cover only part of a tariff code (the toy line leaves out toys with Wi-Fi or Bluetooth, for example), so ask your factory exactly what goes into the product before you count on a lower rate.
- **2 September 2026. CBP asks for comments on wider supply chain disclosures.** [CBP press release: advance notice on supply chain visibility](https://www.cbp.gov/newsroom/national-media-release/cbp-announces-advance-notice-proposed-rulemaking-enhance-supply) (U.S. Customs an Border Protection) CBP says it may ask importers to identify key parties in the import chain, use better business identifiers and collect or keep foreign export documents, with comments due 1 December 2026 under docket USCBP-2026-1058. Nothing is a rule yet, and our note on the proposal itself is in the factory or trading company section below. The China-side question is whether you could produce your supplier's export paperwork today, and whether it names the same company as your invoice.
- **August 2026. The White House publishes a report on illegal transshipment.** [White House: The Great Transshipment Scam (PDF)](https://www.whitehouse.gov/wp-content/uploads/2026/08/The-Great-Transshipment-Scam.pdf) (White House Office of Trade and Manufacturing Policy) The report ties more than 40 countries to a higher risk of illegal transshipment and says relabeling, repackaging, re-invoicing and minor processing can fake a new origin. It separates real manufacturing and substantial transformation from pass-through trade, and that distinction is what matters on your entries. If your goods now ship from Vietnam, Malaysia or Mexico, ask where they are actually made and by which company.
- **31 July 2026. DHS adds 43 companies to the UFLPA Entity List.** [DHS: 43 companies added to the UFLPA Entity List](https://www.dhs.gov/news/2026/07/31/dhs-announces-addition-43-companies-uflpa-entity-list) (U.S. Department of Homeland Security) From 3 August 2026, CBP presumes goods made by these companies are barred from entry, and DHS calls it the largest single expansion of the list, which now has 187 entities. The new names include companies in aluminum, apparel, copper, cotton and tomato products. A list like this only helps if you know the Chinese legal name of every company that makes your goods, and the one that sends the invoice may not be one of them.
- **28 July 2026. New Section 301 tariffs, at 12.5 percent for goods from China.** [USTR notice: Section 301 actions on forced labor import bans in 60 economies](https://www.federalregister.gov/documents/2026/07/28/2026-15181/notice-of-actions-in-section-301-investigations-of-acts-policies-and-practices-of-various-economies) (Federal Register, effective 24 July 2026) USTR imposed tariffs on products of 60 economies it found had failed to impose and enforce a ban on forced labor imports, with China and Hong Kong at 12.5 percent from 24 July 2026 and goods under Section 232 tariffs exempt. Vietnam and Thailand are also at 12.5 percent, so moving final assembly there doesn't lower this particular rate. What sets your rate is the country of origin, which comes back to where your goods are really made and what the factory there actually does.
- **14 July 2026. CBP starts marking unused importer numbers inactive.** [CSMS 69241265: new "Inactive for Entry Purposes" status](https://content.govdelivery.com/bulletins/gd/USDHSCBP-42089b1) (CBP Cargo Systems Messaging Service) From 16 July 2026, ACE can automatically deactivate an importer number that hasn't been used to file an entry in 366 days. If you import once a year or less, a number that worked last season may not work now, and a related CSMS message explains how your broker can reactivate it with full Form 5106 data. It's a good moment to confirm that the details on your record are yours, and not your supplier's or your forwarder's.
- **24 June 2026. CBP writes the de minimis suspension into its regulations.** [CBP rule: indefinite suspension of de minimis for all modes other than mail](https://www.federalregister.gov/documents/2026/06/24/2026-12670/indefinite-suspension-of-the-de-minimis-exemption-for-merchandise-arriving-through-all-modes-other) (Federal Register, effective 24 June 2026) Shipments valued at $800 or less that arrive any way other than by mail now need a formal or informal entry, with Entry Type 11 as the main informal route, and a companion rule set up a postal entry process from 24 July 2026. CBP also notes that Congress has ended the exemption by statute from 1 July 2027. For a small order or samples from China, someone now has to declare classification, value and origin, and those numbers start with your supplier's invoice.
- **10 June 2026. Executive Order 14411, Strengthening Customs Enforcement.** [Executive Order 14411: Strengthening Customs Enforcement](https://www.federalregister.gov/documents/2026/06/10/2026-11595/strengthening-customs-enforcement) (Federal Register, signed 3 June 2026) The order tells DHS to tighten who can act as importer of record, with asset or bond minimums, ownership disclosures, a "good standing" test and stricter terms for foreign importers, and to collect more data, including foreign business identifiers, manufacturer product details and the documents the foreign exporter filed with its own customs. It also tells DHS to keep mitigated penalties at no less than 50 percent of the assessed amount in most cases, and to put forced labor, misclassification, undervaluation and transshipment cases first. If your Chinese supplier acts as importer of record for you, or files export papers you have never seen, this order makes those your questions.
- **6 May 2026. USTR opens the second four-year review of the original China Section 301 tariffs.** [USTR notice: second four-year review of the China Section 301 actions](https://www.federalregister.gov/documents/2026/05/06/2026-08806/initiation-of-second-four-year-review-process-chinas-acts-policies-and-practices-related-to) (Federal Register) The 2018 tariffs on Chinese goods lapse unless domestic industries ask for them to continue, and the request windows ran to 5 July and 22 August 2026. If any request came in, the review moves to a second phase with public comments, so don't assume the 2018 rates end this year. Before you price next year's orders, know your HTS codes, and for that you need an accurate description of what the factory really makes.
- **13 April 2026. CBP sets up CAPE to refund IEEPA duties.** [CSMS 68340863: CAPE for IEEPA refunds, Phase 1](https://content.govdelivery.com/bulletins/gd/USDHSCBP-412cc7f) (CBP Cargo Systems Messaging Service) After court orders to refund IEEPA duties, CBP built CAPE in ACE, and Phase 1 opened on 20 April 2026 for unliquidated entries and entries within 80 days of liquidation. Only the importer of record, or the broker that filed the entries, can submit a CAPE Declaration. If your Chinese supplier was importer of record on delivered-duty-paid terms, the refund would go to them, so read what your contract says about it now.
- **9 April 2026. Section 232 metal tariffs move to the full value of the product.** [Proclamation 11021: strengthening the aluminum, steel and copper tariffs](https://www.federalregister.gov/documents/2026/04/09/2026-06960/strengthening-actions-taken-to-adjust-imports-of-aluminum-steel-and-copper-into-the-united-states) (Federal Register, effective 6 April 2026) From 6 April 2026, Section 232 duties on covered aluminum, steel and copper articles and their derivatives apply to the full customs value regardless of metal content, at 50 percent for most listed articles and 25 percent for others, and a June 2026 proclamation adjusted the regime again. Goods under Section 232 are exempt from the new 12.5 percent Section 301 tariff, so classification decides which regime you pay. Getting that right starts with the factory describing the product accurately.
- **17 March 2026. USTR opens Section 301 investigations into excess capacity, China included.** [USTR notice: Section 301 investigations on structural excess capacity](https://www.federalregister.gov/documents/2026/03/17/2026-05214/initiation-of-section-301-investigations-acts-policies-and-practices-of-certain-economies-relating) (Federal Register, initiated 11 March 2026) USTR is investigating 15 economies plus the EU, including China, Vietnam, Malaysia, Thailand, Cambodia and Mexico, over manufacturing capacity it says runs ahead of demand. As of Greenberg Traurig's 24 July alert, the results were still to come, and the firm notes they could add duties on top of the new Section 301 tariffs. Keep that in mind before you move production to another covered country, and know where each part of your product is made.
- **25 February 2026. A temporary 10 percent import surcharge under Section 122.** [Proclamation 11012: temporary import surcharge](https://www.federalregister.gov/documents/2026/02/25/2026-03824/imposing-a-temporary-import-surcharge-to-address-fundamental-international-payments-problems) (Federal Register, effective 24 February 2026) The President imposed a 10 percent surcharge on most imports for 150 days from 24 February 2026, the longest Section 122 allows without an Act of Congress. It lapsed on 24 July 2026, the same minute the new Section 301 tariffs started, so the new layer on most goods from China went from 10 percent to 12.5 percent, on top of any older China Section 301 duties. Whichever tariff applies, it attaches to the country of origin on your entry, and your supplier's paperwork has to back that up.
- **25 February 2026. The IEEPA tariffs end.** [Executive Order 14389: Ending Certain Tariff Actions](https://www.federalregister.gov/documents/2026/02/25/2026-03832/ending-certain-tariff-actions) (Federal Register, signed 20 February 2026) The order ends the additional duties imposed under IEEPA, including the synthetic opioid duties on China and the reciprocal tariffs, and says collection stops as soon as practicable. It leaves Section 232 and Section 301 duties, the de minimis suspension and the Section 122 surcharge untouched. The duties that remain still depend on origin, so for China your entries have to name the right country and the right maker.
- **20 February 2026. The Supreme Court rules that IEEPA does not authorize tariffs.** [Supreme Court: Learning Resources, Inc. v. Trump (PDF)](https://www.supremecourt.gov/opinions/25pdf/24-1287_4gcj.pdf) (Supreme Court of the United States) The Court held that IEEPA does not give the President the power to impose tariffs, a holding that covered both the 2025 duties on most Chinese imports and the reciprocal tariffs. The ruling led to the order ending those duties and to CBP's refund process, both listed above. It doesn't touch Section 301 and Section 232 duties, so the origin and classification of your goods matter as much as before.
- **2 January 2026. CBP moves refunds to electronic payment.** [CBP rule: Electronic Refunds](https://www.federalregister.gov/documents/2026/01/02/2025-24171/electronic-refunds) (Federal Register, effective 6 February 2026) With limited exceptions, CBP now issues refunds only electronically, which means an ACE Portal account with ACH refund details, or a CBP Form 4811 naming another party to receive them. This is the payment route behind the IEEPA refunds, so set it up before you need it. If a forwarder or your supplier set up your import account, find out whose bank details CBP has on file.
- **29 December 2025. USTR acts on Chinese semiconductors, at 0 percent for now.** [USTR notice: action on China's targeting of the semiconductor industry](https://www.federalregister.gov/documents/2025/12/29/2025-23912/notice-of-action-chinas-acts-policies-and-practices-related-to-targeting-of-the-semiconductor) (Federal Register, effective 23 December 2025) USTR found China's semiconductor practices actionable and imposed a tariff that starts at 0 percent and rises on 23 June 2027, to a rate it will announce at least 30 days before. If you import semiconductors from China, or goods your broker says this action reaches, plan for a change in mid-2027. Ask your factory for the part numbers and makers of the chips it uses, so your broker can tell whether the action applies.
- **1 December 2025. 178 China Section 301 exclusions extended to 9 November 2026.** [USTR notice: China Section 301 product exclusion extensions](https://www.federalregister.gov/documents/2025/12/01/2025-21671/notice-of-product-exclusion-extensions-chinas-acts-policies-and-practices-related-to-technology) (Federal Register) USTR extended the 178 current exclusions from the original China Section 301 tariffs through 9 November 2026, and a September 2026 notice made conforming amendments to four of them after HTS changes. If an exclusion covers your goods, that date is close. Exclusions turn on exact product descriptions, so your broker needs specs from the factory itself, and a catalog page won't do.
- **13 November 2025. USTR suspends the maritime Section 301 actions for one year.** [USTR notice: suspension of the maritime, logistics and shipbuilding Section 301 actions](https://www.federalregister.gov/documents/2025/11/13/2025-19873/notice-of-modification-of-section-301-action-chinas-targeting-of-the-maritime-logistics-and) (Federal Register) Following the US-China deal announced on 1 November 2025, USTR suspended the actions in this investigation into China's maritime, logistics and shipbuilding sectors from 10 November 2025 through 9 November 2026. Watch what happens in November before you lock in freight terms for next year. This one sits more with your forwarder than your factory, but ask your supplier which shipping terms it quotes on and who books the vessel.
- **2 September 2025. De minimis ends for goods from every country.** [CBP notice: implementing Executive Order 14324 on de minimis](https://www.federalregister.gov/documents/2025/09/02/2025-16802/notice-of-implementation-of-the-presidents-executive-order-14324-suspending-duty-free-de-minimis) (Federal Register, effective 29 August 2025) From 29 August 2025, goods valued at $800 or less lost duty-free de minimis treatment whatever their country of origin, and shipments other than mail need an entry in ACE filed by a party qualified to make entry. CBP also suspended the Entry Type 86 test for low-value shipments. If your supplier sends samples or small top-up orders by courier, agree who files the entry and what value goes on the invoice.
- **29 August 2025. DOJ and DHS launch a Trade Fraud Task Force.** [DOJ: Departments of Justice and Homeland Security Partnering on Cross-Agency Trade Fraud Task Force](https://www.justice.gov/opa/pr/departments-justice-and-homeland-security-partnering-cross-agency-trade-fraud-task-force) (U.S. Department of Justice) The Justice Department set up a task force with CBP and Homeland Security Investigations to pursue importers and others who evade tariffs and duties, using Tariff Act penalty actions, the False Claims Act and, where it fits, criminal charges. It invites referrals from domestic industries and whistleblowers, and it encourages importers to audit their own practices and self-disclose problems. When you review your own entries, start with whether the origin and value you declared match what your factory can actually document.
- **28 April 2025. De minimis ends first for goods from China and Hong Kong.** [CBP notice: additional duties on low-value imports from China](https://www.federalregister.gov/documents/2025/04/28/2025-07325/notice-of-implementation-of-additional-duties-on-products-of-the-peoples-republic-of-china-pursuant) (Federal Register, effective 2 May 2025) This notice put Executive Order 14256 into effect, ending the de minimis exemption for products of China, including Hong Kong, from 2 May 2025 and setting new duty rates for postal packages. Goods from China lost it about four months before goods from everywhere else. The origin test is the same as for any entry: where the goods were made, whatever the parcel's return address says.

Not legal advice. Confirm how any of these apply to your goods with your customs broker or counsel.

If you're not sure how any of this touches the companies you buy from in China, [talk to us about what these changes mean for your suppliers](https://www.china-agent.com/booking?hsLang=en).

*Last reviewed: 12 October 2026*

## CBP Form 5106 and importer identity

- **[CBP notice: Accuracy of Importer of Record Data Submitted to CBP](https://www.federalregister.gov/documents/2026/08/19/2026-16911/accuracy-of-importer-of-record-data-submitted-to-cbp)** (Federal Register, 19 August 2026) This is CBP's own notice: from 18 September 2026, CBP can void an importer number right away if the Form 5106 details are wrong or incomplete, and you have to ask to get it back afterward. It covers who you are as an importer. Who made your goods is a separate question, and that one lives in China.
- **[Clark Hill: CBP to void importer numbers for inaccurate Form 5106 data](https://www.clarkhill.com/news-events/news/cbp-form-5106-importer-number-enforcement-2026/)** (Clark Hill, 20 August 2026) A law firm's plain list of what CBP says it won't take as the importer's own address, email or phone, such as a broker's address, a forwarder's email or a P.O. box. If someone else set up your importer record years ago, read this before your next shipment. Once your own details are right, ask whether the company named on your supplier's invoices is the actual factory that makes your goods.
- **[Livingston International: Form 5106 accuracy, what importers need to know](https://www.livingstonintl.com/cbp-form-5106-accuracy-what-importers-need-to-know/)** (Livingston International, 19 August 2026) A customs broker walks through the six data points on the form and how the void notice works, including the copy CBP sends to the broker who last filed for you. It also reminds you that your broker needs a power of attorney signed with you directly, not through a forwarder. None of it touches your supplier, so keep the name, legal entity and address of the actual factory that makes your goods in the same folder.
- **[Western Overseas: has your importer of record number been voided by CBP?](https://www.westernoverseas.com/has-your-importer-of-record-number-been-voided-by-cbp/)** (Western Overseas, 18 September 2026) A customs broker and forwarder explains that voiding is immediate when the address, email, phone or tax ID on your record fails CBP's requirements, most often because a broker's, forwarder's or agent's details were used, and that written notice goes to the email on file after the fact. Until the number is reinstated you can't file entries, and with no published turnaround time from CBP, storage and demurrage keep running. If your supplier or its agent set up the record, the email on file may not even be yours.
- **[FreightWaves: what the importer number crackdown means for cargo](https://www.freightwaves.com/news/cbp-importer-crackdown-puts-thousands-of-cross-border-freight-shipments-at-risk)** (FreightWaves, 21 September 2026) Trade press on the first days of voiding: cargo can wait while an importer asks CBP to restore its number, and CBP hadn't said how many numbers it had voided. Citing Diaz Trade Law, it lists the setups most at risk, including foreign sellers acting as importer of record on delivered-duty-paid terms. If your Chinese supplier is the importer of record on your goods, ask them today whose details sit on that record.

Not legal advice. Confirm your Form 5106 steps with your customs broker or counsel.

Your importer record is your side of the paper. For the China side, [find out who really makes your goods](https://www.china-agent.com/supplier-reality-check?hsLang=en).

*Last reviewed: 27 September 2026*

## UFLPA and forced labor

- **[CBP: Forced Labor Enforcement Operational Guidance for Importers](https://www.cbp.gov/document/guidance/cbp-forced-labor-enforcement-operational-guidance-importers)** (U.S. Customs and Border Protection, guidance dated 12 June 2026) CBP's own guidance puts UFLPA, CAATSA and withhold release orders in one document, with process maps and appendices on the supply chain documents it wants for high-priority sectors. The page tells importers to do due diligence on suppliers before goods get detained. In practice, most of those documents have to come from China, starting with the name and legal entity of the actual factory that makes your goods.
- **[DHS: UFLPA Entity List](https://www.dhs.gov/uflpa-entity-list)** (U.S. Department of Homeland Security, latest additions effective 3 August 2026) The official list of companies whose goods fall under the UFLPA presumption, with their aliases and the date each one was added. Not every company on it is in Xinjiang, so screening by region alone will miss names. You can only screen a supplier against this list if you know its real Chinese legal name, and a trading company's name tells you nothing about the factory behind it.
- **[DHS: 2025 updates to the UFLPA strategy](https://www.dhs.gov/2025-updates-strategy-prevent-importation-goods-mined-produced-or-manufactured-forced-labor-peoples)** (U.S. Department of Homeland Security, 19 August 2025) The annual strategy update added caustic soda, copper, lithium, red dates and steel as high-priority sectors for enforcement, alongside aluminum, apparel, cotton, PVC, seafood, polysilicon and other silica-based products, and tomatoes. DHS says a high-priority label means a higher risk of forced labor or state labor transfers, and those sectors get reviewed first. If your goods contain any of these materials, ask your factory who supplies them, because the answer may sit several companies back.
- **[Miller & Chevalier: forced labor due diligence is part of reasonable care](https://www.millerchevalier.com/publication/trade-compliance-flash-updated-cbp-guidance-forced-labor-due-diligence-not-just-nice)** (Miller & Chevalier, 10 July 2026) The firm's read: under CBP's new guidance, forced labor due diligence is part of the importer's reasonable care duty. It walks through CBP's case study, which traces a supply chain down to raw materials with records from each tier. You can't trace the tiers if you haven't pinned down tier one, the actual factory that makes your goods.
- **[Holland & Knight: what CBP's new forced labor guidance changes](https://www.hklaw.com/en/insights/publications/2026/07/new-compliance-tools-cbp-issues-comprehensive-forced-labor-guidance)** (Holland & Knight, 8 July 2026) A clear map of the new guidance: potential-input versus direct-input UFLPA cases, the response windows, and what goes into an evidence package. The warning to remember: missing records for a single supplier can weaken a whole exception request. Ask yourself whether your supplier would hand over its own sub-supplier records, and whether you would know if they were real.
- **[Troutman Pepper Locke: August list additions reach beyond Xinjiang](https://www.troutman.com/insights/august-expansion-of-uflpa-list-signals-increased-focus-on-companies-outside-of-xinjiang-experts-say/)** (Troutman Pepper Locke, 15 September 2026) This is a short excerpt of an International Trade Today story, posted on Troutman's site, so don't expect a full analysis. A Troutman lawyer notes that the August additions include companies in Shandong, Jiangsu, Henan and other provinces, which as he reads it makes the law more about who made the goods than where, and he also points to China's countermeasures against some audit and tracing organizations. For a US buyer, that makes the name and ownership of each company in your chain the real question, starting with the actual factory that makes your goods.

Not legal advice. Talk to your customs broker or counsel about your own UFLPA exposure.

If you want someone keeping that China-side record for you, see our [monthly supplier file support](https://www.china-agent.com/monthly-support-packages?hsLang=en).

*Last reviewed: 27 September 2026*

## Factory or trading company?

- **[CBP proposal: Heightened Import Disclosures for Supply Chain Visibility](https://www.federalregister.gov/documents/2026/09/02/2026-17926/heightened-import-disclosures-for-supply-chain-visibility)** (Federal Register, 2 September 2026, comments open to 1 December 2026) CBP's advance notice asks whether the manufacturer ID code on entries is enough, and says the code does not always identify the party CBP actually cares about. It asks whether importers should give full legal names and addresses for the manufacturer, shipper and exporter instead. Nothing here is a rule yet, but if you buy through a trading company and the actual factory was never named on paper, this is the question to settle now.
- **[CBP notice: Global Business Identifier Test](https://www.federalregister.gov/documents/2025/08/08/2025-15060/modification-of-the-national-customs-automation-program-test-concerning-the-submission-of-global)** (Federal Register, 8 August 2025, test runs to 23 February 2027) CBP says the manufacturer ID code on entries isn't always consistent or unique, and in this voluntary test importers send global identifiers such as the LEI, D-U-N-S or GLN for the manufacturer, shipper and seller. CBP defines the manufacturer as the party that last makes, assembles or produces the goods, or supplies the finished goods in the country they leave from. If your invoice comes from a trading company, those three roles may belong to three different companies, and you should know all of them.
- **[Morgan Lewis: CBP seeks broad expansion of importer supply chain disclosure](https://www.morganlewis.com/pubs/2026/09/cbp-seeks-broad-expansion-of-importer-supply-chain-disclosure-requirements)** (Morgan Lewis, 3 September 2026) A readable breakdown of the same proposal, including the idea that importers might have to give CBP the export documents their suppliers file with customs at home. The firm tells importers to take stock of what they know about manufacturers, exporters and sellers, and to compare foreign export data with US entry data. For a China buyer, that comparison starts with one question: does the exporter on the Chinese declaration match the company on your invoice and the actual factory that makes your goods?
- **[Harris Sliwoski: The Hong Kong intermediary trap](https://harris-sliwoski.com/chinalawblog/the-hong-kong-intermediary-trap-do-not-bind-the-wrong-china-company/)** (Harris Sliwoski, 29 June 2026) Dan Harris explains how a clean Hong Kong invoice can leave you with a contract against the one company that can't fix anything, while the mainland factory holding your molds and files signed nothing. His fix is to identify the mainland company by its Chinese legal name and get it to sign, sometimes in a three-party deal. That starts with knowing which factory it is, and a trader won't always tell you.

Not legal advice. Confirm anything about entry data with your customs broker or counsel.

Before the next deposit, [find out who really makes your goods](https://www.china-agent.com/supplier-reality-check?hsLang=en).

*Last reviewed: 27 September 2026*

## Tariffs and duties on goods from China

- **[CBP: IEEPA duty refunds](https://www.cbp.gov/trade/programs-administration/trade-remedies/ieepa-duty-refunds)** (U.S. Customs and Border Protection, page last modified 2 September 2026) CBP's running page on refunds of IEEPA duties through CAPE covers who can file and the usual 60 to 90 days after a declaration is accepted, and it warns that CBP charges no fees and that scammers are posing as CBP. Refunds are netted against anything else owed on the entry and can be offset against debts to the government. They follow the importer of record, so if your Chinese supplier imported for you, the money goes to them and only your contract can bring it back to you.
- **[TRIO Customs Brokers: new Section 301 tariffs replace much of the Section 122 surcharge](https://www.triocb.com/post/new-section-301-tariffs-replace-much-of-the-expired-section-122-exposure)** (TRIO Customs Brokers, 27 July 2026) A customs broker explains why the end of the 10 percent surcharge on 24 July didn't cut duties for many importers: new Section 301 tariffs of 10 or 12.5 percent started the same minute, and China sits at 12.5 percent on top of the older China Section 301 duties. It also covers the in-transit exception, the Section 232 carve-out and foreign-trade zone rules. The math depends on classification and origin, entry by entry, so start with where your goods are actually made.
- **[Thompson Hine: U.S.-China Board of Trade "30-for-30" names products recommended for lower tariffs](https://www.thompsonhinesmartrade.com/2026/09/u-s-china-board-of-trade-30-for-30-identifies-products-recommended-for-reduced-tariffs/)** (Thompson Hine SmarTrade, 29 September 2026) A short summary from the law firm. The US list covers 77 tariff lines of Chinese goods, like toys, electrical goods and other consumer products, and China's list covers 1,619 lines going the other way. There's no official rate until USTR announces one, and the firm says the lists aren't likely to change more than once a year. Before you plan prices around a cut, make sure the HTS code on your entries matches what the factory actually makes. That code decides if your goods are in or out.
- **[Thompson Hine: CBP confirms 6 October launch of CAPE Phase 3](https://www.thompsonhinesmartrade.com/2026/09/cbp-confirms-october-6-2026-launch-of-phase-3-of-the-ieepa-tariff-refund-process/)** (Thompson Hine SmarTrade, 16 September 2026) According to a CBP declaration filed in the Court of International Trade, Phase 3 opened on 6 October 2026 for entries liquidated more than 80 days ago, but only for importers with a refund case pending at the court, starting with those that gave CBP their importer number by 30 July 2026. Whether importers who didn't sue can get those older refunds is still being fought on appeal. Ask your broker which of your entries fall in which phase, and if a supplier was importer of record on some of them, find out now whether it plans to claim.
- **[Greenberg Traurig: USTR imposes new Section 301 forced labor tariffs on 60 economies](https://www.gtlaw.com/en/insights/2026/7/ustr-imposes-new-section-301-forced-labor-tariffs-on-imports-from-60-economies)** (Greenberg Traurig, 24 July 2026) A law firm's full breakdown of the new tariffs: who pays 10 percent, who pays 12.5, the carve-outs for Section 232 and USMCA goods, and the long list of exempt raw materials and commodities. It notes the new duties stack on ordinary duties, antidumping and countervailing duties, and existing China Section 301 duties. Since the exemption lists run by country and HTS code, the country of origin you declare has to be one your factory's records can support.
- **[FreightWaves: importers sue over the forced labor tariffs](https://www.freightwaves.com/news/forced-labor-tariffs-lawsuits)** (FreightWaves, Thomas Wasson, 28 July 2026) Trade press on two suits filed at the Court of International Trade on 24 July, one by the toy company that won the IEEPA case, arguing that USTR skipped the country-by-country findings Section 301 requires. It also explains how the new duty layers on top of others and why classification, not origin alone, decides exposure. No court has ruled, so plan on paying for now, and keep your entry records by importer of record with an origin claim your factory can back up.

Not legal advice. Confirm duty rates, refunds and classification with your customs broker or counsel.

Tariffs follow origin, and the origin paperwork comes from China. If you want someone keeping that file current, see our [monthly supplier file support](https://www.china-agent.com/monthly-support-packages?hsLang=en).

*Last reviewed: 12 October 2026*

## The end of the de minimis exemption

- **[Executive Order 14388: continuing the suspension of de minimis for all countries](https://www.federalregister.gov/documents/2026/02/25/2026-03829/continuing-the-suspension-of-duty-free-de-minimis-treatment-for-all-countries)** (Federal Register, 25 February 2026) Signed the same day as the order ending the IEEPA tariffs, this keeps duty-free de minimis off for every shipment regardless of value, origin, mode or method of entry, and sets postal duty rates until CBP's new postal entry process takes effect. The Supreme Court ruling did not bring de minimis back. For goods from China, even a small courier shipment now carries a declared value and origin, and your supplier's invoice is where both start.
- **[Greenberg Traurig: de minimis suspension and IEEPA refund updates](https://www.gtlaw.com/en/insights/2026/6/us-trade-developments-ieepa-refund-processing-de-minimis-suspension-and-section-301-investigation-against-germany)** (Greenberg Traurig, 25 June 2026) A short alert on CBP's two June rules: shipments of $800 or less that don't come by mail now use formal entry or Entry Type 11, mail moves to a new postal process from 24 July 2026 with a later compliance date of 20 January 2027 for some goods, and the statutory end of de minimis follows on 1 July 2027. It names foreign manufacturers selling direct to US consumers among those with immediate obligations. If a Chinese supplier ships small orders to your customers for you, find out who is filing those entries now.
- **[Troutman Pepper Locke: CBP's new international mail entry process](https://www.troutman.com/insights/no-more-free-ride-navigating-cbps-new-international-mail-entry-process/)** (Troutman Pepper Locke, 15 July 2026) The practical detail on mail: only owners, purchasers or licensed brokers can file, the monthly worksheet needs 10-digit HTS codes, origin and value, duty is due by the 7th of the following month, and a continuous bond will generally be needed for regular volume. Foreign postal operators and other non-broker third parties can no longer file for you. If your supplier in China mails parts or samples, somebody on your side now owns those declarations.

Not legal advice. Confirm entry types and who files with your customs broker or counsel.

Small parcels still need the right maker and value on paper. If you want that paperwork kept current for each supplier, see our [ongoing help with your supplier paperwork](https://www.china-agent.com/monthly-support-packages?hsLang=en).

*Last reviewed: 27 September 2026*

## Transshipment, country of origin and customs fraud cases

- **[CBP: Enforce and Protect Act (EAPA)](https://www.cbp.gov/trade/eapa)** (U.S. Customs and Border Protection, page last modified 2 July 2026) EAPA lets a competitor or other interested party accuse an importer of evading antidumping and countervailing duties, and CBP can then collect information from the importer, the foreign manufacturer or exporter, and even the foreign government. CBP's own spotlight case is a $300 million evasion scheme involving Chinese mattresses. If your goods fall under an antidumping or countervailing order, your factory's production records are what an investigation can ask for.
- **[CBP: Strengthening Customs Enforcement](https://www.cbp.gov/trade/strengthening-customs-enforcement)** (U.S. Customs and Border Protection, page last modified 7 October 2026) CBP's hub for Executive Order 14411 now leads with the low-value shipments proposal, and it still carries FAQs on a minimum level for penalty mitigation and heavier broker due diligence. CBP says the reforms raise the consequences for transshipment, undervaluation and misdeclaration. Your broker is likely to ask more of you, and much of what it asks for, such as who made the goods and at what price, has to come from China.
- **[CBP: Norfolk seizures of counterfeit, unsafe and identity-theft shipments](https://www.cbp.gov/newsroom/local-media-release/cbp-hits-trade-transgression-trifecta-seizures-counterfeit-unsafe-and)** (U.S. Customs and Border Protection, 28 September 2026) CBP's Norfolk port lists five recent seizures worth nearly $856,000. They include 1,000 sinks from China with fake UPC plumbing certification marks, and carpet with fake OEKO-TEX labels whose certificate number had expired. Another shipment from China came in under a stolen importer identity. If your supplier hands you a test certificate, confirm it with whoever issued it. And know whose importer number your goods enter under.
- **[DOJ: Perfectus Aluminum and related companies agree to pay $549.5M to settle False Claims Act allegations](https://www.justice.gov/opa/pr/perfectus-aluminum-inc-and-related-companies-agree-pay-5495m-settle-false-claims-act)** (U.S. Department of Justice, 12 May 2026) DOJ says the companies avoided antidumping and countervailing duties on more than 2.2 million Chinese aluminum extrusions from 2011 to 2014 by spot-welding them together and declaring them to CBP as finished "pallets" that were never sold. The civil settlement resolves whistleblower suits from two individuals and an aluminum industry group and came through the Trade Fraud Task Force, after a 2021 criminal conviction, so entries from more than a decade ago still came back to bite. Ask yourself whether the description on your entries matches what your factory really ships, or only what your supplier prefers to call it.
- **[Cooley: White House steps up trade fraud enforcement with AI](https://www.cooley.com/news/insight/2026/2026-09-03-white-house-steps-up-trade-fraud-enforcement-with-ai)** (Cooley, 3 September 2026) A law firm's summary of the White House transshipment report and a DOJ memo from the same day, including CBP's planned AI tool to flag unusual routing, suspicious bills of lading, false origin claims and value mismatches. Its advice if you get an inquiry: retain counsel, preserve shipping records, customs filings and supplier agreements, and consider an internal review. Supplier agreements and origin records only help if they name the actual factory that makes your goods.
- **[Hogan Lovells Cadwalader: trade enforcement for China and Vietnam supply chains](https://www.hlc.com/en/publications/trade-enforcement-in-the-spotlight-what-vietnamese-and-chinese-companies-need-to-know)** (Hogan Lovells Cadwalader, 23 September 2025) Written after the DOJ and DHS Trade Fraud Task Force launched, it explains why Vietnam draws scrutiny as a possible pass-through for Chinese goods and why repackaging or limited assembly outside China is generally not enough to change origin. It says investigators have asked China-based manufacturers and raw material suppliers for records, often reaching tier two or three suppliers. Factories in Vietnam or Malaysia can run on Chinese inputs, so the question is the same wherever the invoice comes from: who makes it, and from what.
- **[Sidley: DOJ's $5.15 million False Claims Act settlement over Chinese-origin LEDs](https://fcablog.sidley.com/2026/08/11/dojs-5-15-million-fca-settlement-reinforces-focus-on-tariff-and-customs-compliance/)** (Sidley Austin, False Claims Act Blog, 11 August 2026) DOJ settled with a Taiwanese LED maker and its US subsidiary over claims that Chinese-made LEDs were routed through Taiwan and declared Taiwanese to avoid Section 301 tariffs, and that later imports mixed Chinese and Taiwanese dies. The companies didn't admit liability, and the case began with a former employee's whistleblower suit. Origin can turn on a single component, so ask your factory where the key parts are made, not only where final assembly happens.

Not legal advice. Talk to counsel before you answer any CBP or DOJ inquiry.

Origin claims start with the factory, so [find out who really makes your goods](https://www.china-agent.com/supplier-reality-check?hsLang=en).

*Last reviewed: 12 October 2026*

## Contracts and disputes with Chinese suppliers

- **[CIETAC: Model Arbitration Clause](https://www.cietac.org/en/articles/25117)** (China International Economic and Trade Arbitration Commission, 16 January 2023) CIETAC publishes its standard clause in English: disputes go to CIETAC under the rules in force when you file, and the award is final and binding. What a US buyer should take from it: a dispute clause needs a named institution, and a loose promise to arbitrate somewhere won't do that job. The clause only binds the company that signed it, so decide which Chinese company that should be before you copy it.
- **[CIETAC: Awards Enforcement](https://www.cietac.org/en/articles/25129)** (China International Economic and Trade Arbitration Commission, 17 January 2023) CIETAC's own page on what happens after you win: if the other side doesn't pay, you apply to the Intermediate People's Court where it is based or holds property, and outside China you can rely on the New York Convention, in force for China since 1987. An award is only worth something against a company with assets you can find, and a trading office with a desk and a bank account may not have many. That's why the name on your contract should be the actual factory that makes your goods.
- **[Harris Sliwoski: China NNN agreement or manufacturing agreement? Usually both](https://harris-sliwoski.com/chinalawblog/china-nnn-agreement-vs-manufacturing-agreement/)** (Harris Sliwoski, 27 August 2026) It explains when you need an NNN agreement (before you share drawings with factories you're weighing) and when you need a manufacturing agreement (after you pick one, before tooling or deposits). It starts where we would start: identify the mainland company by its registered Chinese name and credit code, and get its company chop on the paper. How the factory reacts when you ask for those details tells you a lot.
- **[Harris Sliwoski: How to sue a Chinese company](https://harris-sliwoski.com/chinalawblog/how-to-sue-a-chinese-company/)** (Harris Sliwoski, 4 October 2026) Dan Harris walks through what it takes to sue a mainland Chinese company. Mainland courts don't enforce US judgments. Serving the papers through China's Ministry of Justice under the Hague Convention usually takes six to nine months, and depositions in China aren't allowed. He also says to find out where the company is really based, since mainland China, Hong Kong, Taiwan and Macao are separate jurisdictions. A case is only as strong as the company you name, so know the legal entity of the actual factory that makes your goods and where its assets are.

Not legal advice. Have a lawyer who works on China contracts review yours.

When you're ready to put it on paper, here's [how we draft contracts that hold up in China](https://www.china-agent.com/contracts?hsLang=en).

*Last reviewed: 12 October 2026*

**About this list.** We read every piece here ourselves before adding it. We have no relationship with any firm or publisher on this page, and nobody paid to be listed. Nothing here is legal advice.

## Questions about this list

### Who is this reading list for?

US importers who already buy from China and want the rules and the China-side questions in one place. Every link has a short note from us on what it says and what it leaves open.

### Does China Agent file Form 5106 or deal with CBP for me?

No. Your customs broker files, and you certify as the importer. We work on the China side: we find out who really makes your goods and whether that company's legal entity matches the names on your paperwork.

### Is this page legal advice?

No. It is our reading of public material, written for buyers. Confirm anything legal or customs-related with your customs broker or counsel.

### How often is this list updated?

Whenever something important lands. New items go into "Latest additions" at the top first, and each section shows the date it was last reviewed.

### What changed for US importers buying from China in 2026?

The biggest changes were the end of the IEEPA tariffs after the Supreme Court's February 2026 ruling, new Section 301 tariffs of 12.5 percent on goods from China from 24 July 2026, the continued suspension of de minimis, and CBP's power to void importer numbers with inaccurate Form 5106 data. CBP is also refunding IEEPA duties through CAPE and has proposed wider supply chain disclosures. Each item is in the official record at the top of this page, with its date and link.

Most of our work is face to face with your factories in China. If you already have a supplier and something on this list worries you, [book a 30-minute call](https://www.china-agent.com/booking?hsLang=en). We work on the client side only. No sourcing, no commissions.

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*Fixed fees. No commissions. We work only for the importer.* 

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