The international trade environment continues to evolve at an unusually fast pace. Importers and exporters are currently navigating a combination of heightened U.S. Customs enforcement, increasing customs bond requirements, major tariff developments, port congestion, rising transportation costs, and continued geopolitical disruption.
While each of these developments presents its own challenges, together they point toward a broader trend: companies involved in international trade should expect increased compliance scrutiny, higher costs, and continued supply-chain volatility through the remainder of 2026.
Krenz & Hannan International continues to monitor these developments closely. Below, we have summarized several of the most important issues currently affecting our customers and the international trade community, with some key dates upcoming this September.
1. CBP Strengthening Customs Enforcement
2. Rising Customs Bond & Collateral Requirements
3. IEEPA Tariff Refunds – CAPE Processing Continues
4. Canada Announces New Retaliatory Tariffs on U.S. Goods
5. Ocean Freight Rates & Asian Port Congestion
6. Strait of Hormuz & Middle East Shipping Disruption
1. CBP Strengthening Customs Enforcement
U.S. Customs and Border Protection (CBP) continues to move toward a more aggressive enforcement environment focused on ensuring that importers are properly identified, financially responsible, and compliant with U.S. customs laws.
The Administration’s Strengthening Customs Enforcement initiative directs CBP to increase scrutiny throughout the import process, with particular attention being paid to importer identity, foreign Importers of Record, classification, valuation, country of origin, transshipment, forced labor, and overall supply-chain transparency.
Importers should expect CBP to increasingly focus on the accuracy and completeness of information provided when establishing and maintaining an Importer of Record (IOR).
This includes information reported on CBP Form 5106 – Create/Update Importer Identity Form and information concerning an importer’s business operations and identity.
The broader enforcement initiative also calls for enhanced vetting of importers and other parties participating in U.S. trade. Depending on implementation, this may include greater scrutiny of ownership and beneficial ownership, business affiliations, expected import activity, and the financial resources available to satisfy potential customs liabilities.
Foreign Importers of Record
Foreign Importers of Record are an area of particular focus.
The Administration has directed CBP to establish additional requirements for foreign IORs, including restrictions involving informal entries, formal entry bonds, and the circumstances under which foreign entities may act as the Importer of Record.
These changes could significantly affect foreign companies that currently import directly into the United States without an established U.S. entity.
Classification, Valuation & Country of Origin
CBP has also been directed to increase enforcement targeting:
- Incorrect HTS classifications
- Undervaluation of imported merchandise
- Improper country-of-origin declarations
- Illegal transshipment
- Evasion of tariffs and trade remedies
- Forced-labor violations
- Inaccurate or incomplete supply-chain information
Importers should be prepared to demonstrate how classifications, values, and countries of origin were determined rather than relying solely on information supplied by a foreign vendor.
With tariffs now representing a much larger percentage of the landed cost of many imported products, CBP has a greater financial incentive to scrutinize declarations that reduce duty exposure.
What Importers Should Do
Importers should review their CBP Form 5106 information and ensure their legal name, address, tax identification information, and other IOR information remain accurate.
Companies should also maintain documentation supporting HTS classifications, declared values, countries of origin, free-trade-agreement claims, and other duty-saving programs.
Import compliance should increasingly be viewed as an ongoing internal control—not simply something handled when a shipment reaches the border.
2. Rising Customs Bond & Collateral Requirements
One of the less visible consequences of today’s higher tariff environment is the impact on continuous customs bonds.
Most regular U.S. importers maintain a continuous bond that allows them to make entries throughout a twelve-month period.
CBP generally calculates the required continuous importer bond based on approximately 10% of the duties, taxes, and fees paid or payable during the preceding twelve months, subject to minimum requirements and applicable rounding rules.
The standard minimum continuous importer bond remains $50,000.
The important point for importers is that bond sufficiency is tied primarily to duties, taxes, and fees—not simply the value or number of shipments imported.
As a result, an importer can maintain essentially the same purchasing and shipment volume as the previous year while requiring a substantially larger customs bond because tariff rates have increased.
IEEPA-related duties, Section 301 tariffs, Section 232 tariffs, antidumping and countervailing duties, and other trade remedies can all materially increase an importer’s duty exposure.
Surety Companies Are Also Increasing Scrutiny
CBP’s minimum bond requirement is only one part of the equation.
The private surety companies issuing customs bonds are also evaluating their potential exposure more conservatively.
Depending upon the importer and its trade profile, a surety may consider:
- Financial strength and working capital
- Current and projected duty exposure
- Unliquidated entries
- Antidumping and countervailing duty exposure
- Section 232 and Section 301 exposure
- Classification, valuation, and country-of-origin complexity
- Prior customs claims or compliance issues
- Open audits, investigations, or reconciliations
- Sourcing concentration and geopolitical risk
As bond amounts and potential customs liabilities increase, some importers are being asked to provide additional financial information, corporate or personal indemnification, letters of credit or cash collateral.
This can turn what historically was a relatively routine customs requirement into a meaningful cash-flow and capital-management issue.
What Importers Should Do
Importers should periodically review their rolling twelve-month duties, taxes, and fees rather than waiting to receive a bond insufficiency notice from CBP.
Companies experiencing significant tariff increases should also consider their projected duty exposure, particularly if current bond capacity is approaching its limit.
Being proactive can reduce the risk of an insufficient bond creating an unexpected interruption in future customs entries.
3. IEEPA Tariff Refunds – CAPE Processing Continues
CBP continues processing IEEPA tariff refunds through its Consolidated Administration and Processing of Entries (CAPE) system.
As of August 21, approximately 26.4 million entries representing $132.5 billion in potential and certified refunds had been accepted for CAPE processing.
Of that amount, approximately $106.6 billion had been completed, certified by CBP, and sent to the U.S. Treasury for disbursement.
One particularly important issue remains ACH banking information.
CBP reported that 22,170 refunds totaling approximately $1.7 billion had not been transmitted to Treasury because the Importer of Record or its authorized CBP Form 4811 designee had not provided the necessary ACH information.
Importers expecting refunds should therefore confirm that the appropriate ACH refund information is established and accurate.
Reconciliation Entries
CBP expanded CAPE functionality on June 29 to accommodate certain entries flagged for reconciliation where a Reconciliation Entry (Type 09) had not yet been filed.
As of August 21, approximately 2.3 million reconciliation-flagged entries had successfully been filed through CAPE and were positioned for processing.
CAPE Phase 3 Delayed
CBP has temporarily delayed deployment of CAPE Phase 3.
Phase 3 is intended to address certain finally liquidated entries filed by plaintiffs for which the U.S. Court of International Trade has ordered reliquidation.
CBP has indicated that additional system validations are necessary to ensure that the reliquidation process adjusts the applicable IEEPA duties without inadvertently changing other duties associated with the original entry.
Importantly, CAPE Phases 1 and 2 remain operational and are not affected by the Phase 3 delay.
What Importers Should Do
Importers with IEEPA refund exposure should continue monitoring affected entries and ensure that their ACH refund information is properly established.
Importers should also recognize that eligibility and procedures can differ depending upon an entry’s liquidation status. Finally liquidated entries in particular may involve additional legal and procedural considerations.
KHI will continue monitoring developments from CBP and the Court of International Trade as the refund process progresses.
4. Canada Announces New Retaliatory Tariffs on U.S. Goods
The Canadian government has announced another significant round of retaliatory tariffs on U.S.-origin goods.
Effective 12:01 a.m. September 8, 2026, Canada will impose tariffs of 15%, 25%, or 50% on approximately $27.6 billion of products imported from the United States.
The measures are Canada’s response to the United States’ recently imposed tariffs on Canadian merchandise under Sections 338 and 232.
The new Canadian tariffs are concentrated in sectors including:
- Steel and aluminum
- Dairy products
- Appliances
- Agricultural equipment
- Pulp and paper
- Plastics
- Electronics
- Various other manufactured and consumer products
For certain products, including steel and aluminum, existing Canadian counter-tariffs are increasing from 25% to 50%.
Other existing Canadian countermeasures, including those affecting certain U.S. automobiles, will continue to apply.
Country of Origin Matters
Importantly, the new counter-tariffs apply to qualifying U.S.-origin goods, not simply merchandise shipped from the United States.
Canada has stated that U.S. goods already in transit to Canada when the measures take effect will not be subject to the new counter-tariffs.
U.S. exporters should therefore review the Canadian tariff classification and origin of their products before accepting or pricing upcoming Canadian orders.
What Exporters Should Do
Companies selling into Canada should determine whether their products appear on Canada’s updated counter-tariff list and understand the applicable tariff rate.
Depending upon the commercial terms of sale, these tariffs could materially affect either the Canadian customer’s landed cost or the U.S. exporter’s profitability.
Exporters should also review Incoterms and customer agreements to clearly understand which party is responsible for Canadian import duties and taxes.
5. Ocean Freight Rates & Asian Port Congestion
Ocean transportation costs are again experiencing upward pressure as carriers contend with a combination of weather disruption, port congestion, equipment constraints, strong cargo demand, and geopolitical instability.
A series of typhoons has disrupted operations at major Chinese ports, including Shanghai and Ningbo, creating significant delays throughout Asian carrier networks.
Recent disruptions have resulted in port closures, skipped vessel calls, rolled cargo, schedule changes, and reduced effective vessel capacity.
Shanghai has experienced particularly significant congestion, with reported vessel waiting times reaching approximately 10 to 12 days during periods of severe disruption.
Rates Have Responded Quickly
The effect has been particularly visible in the intra-Asia market, but vessel availability and container schedules are certainly being affected globally. When major Asian ports experience prolonged congestion, vessel schedules become less reliable, equipment becomes displaced, transshipment connections are missed, and carriers effectively have less usable capacity across their global networks.
Those conditions can ultimately place upward pressure on other trade lanes as well.
What Shippers Should Expect
We recommend that customers continue to anticipate freight-rate volatility and less predictable transit times as the industry moves through peak shipping season.
Historical freight rates should not automatically be used to budget upcoming shipments.
Providing KHI with additional lead time allows our team and overseas partners to evaluate carrier options, alternate routings, equipment availability, and current market pricing before cargo becomes urgent.
6. Strait of Hormuz & Middle East Shipping Disruption
Geopolitical disruption surrounding the Strait of Hormuz and the broader Middle East continues to have consequences far beyond cargo moving directly into or out of the Persian Gulf. Carriers have been forced to modify routings and utilize alternative ports and inland transportation networks for certain Gulf cargo.
Those changes come at a substantial cost. Hapag-Lloyd reported that the Middle East conflict resulted in approximately $600 million in additional costs during the second quarter alone, including increased bunker fuel, insurance, storage, service rerouting, and inland transportation expenses.
Maersk has similarly rerouted Gulf-bound cargo through alternative ports and inland transportation networks.
Why This Matters Outside the Middle East
Shipping networks are interconnected. When vessels are rerouted or services require additional transit time, the amount of effective capacity available to the global market declines. Containers and vessels are also more likely to be positioned somewhere other than where the next shipment requires them.
The result can be:
- Reduced effective vessel capacity
- Equipment imbalances
- Longer transit times
- Increased fuel and insurance costs
- Port and transshipment congestion
- Additional inland transportation requirements
- Higher freight rates and surcharges
At the same time, strong cargo demand has allowed carriers to recover some of these additional costs through higher freight rates.
The current situation illustrates why geopolitical events occurring thousands of miles away can ultimately affect transportation pricing and service reliability for U.S. importers and exporters.
What Importers & Exporters Should Be Doing Now
Although these developments involve different parts of the international trade process, several common themes emerge.
1. Review your Importer of Record information.
Ensure CBP Form 5106 information and other importer records remain complete and accurate as CBP increases importer vetting and enforcement.
2. Revisit customs classifications, values, and countries of origin.
With tariff exposure substantially higher than in previous years, relatively small compliance errors can now create significant duty and penalty exposure.
3. Monitor your continuous customs bond.
Higher duties can cause bond requirements to increase even when import volume remains unchanged. Importers should monitor rolling twelve-month duty exposure and plan ahead for potential bond increases.
4. Confirm ACH refund information.
Importers expecting IEEPA refunds should verify that appropriate ACH information has been established to prevent otherwise eligible refunds from being delayed.
5. Review U.S.-Canada trade exposure.
U.S. exporters should determine whether their merchandise is included in Canada’s September 8 counter-tariff measures and understand who bears those additional costs under their terms of sale.
6. Build additional time into international transportation planning.
Weather, congestion, equipment availability, Middle East disruption, and peak-season demand are creating a transportation market where both pricing and schedules can change quickly.
7. Communicate early.
Whether the concern involves classification, tariffs, bonds, routing, or freight pricing, identifying the issue before cargo moves generally provides significantly more options than attempting to correct it after arrival.
Looking Ahead
The remainder of 2026 is likely to remain an active period for both customs compliance and international transportation.
The common thread across many of these developments is increased volatility.
Tariff policy can quickly change landed costs. Higher duties can unexpectedly affect customs bond requirements. Increased enforcement raises the importance of accurate import data and documentation. Meanwhile, weather and geopolitical events continue to affect vessel capacity, transit times, and freight pricing.
Krenz & Hannan International will continue monitoring these developments and communicating significant changes to our customers.
Customers with questions regarding their customs bond, tariff exposure, IEEPA refunds, Canadian exports, or upcoming international transportation requirements are encouraged to contact their Krenz & Hannan International representative.
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Strengthening Customs Enforcement
Complete List of U.S. Products Subject to Counter-Tariffs
Intra-Asia Rates Continue Upward Climb on Storm Disruption, Strong Peak
Hormuz Disruption Cuts Both Ways for Maersk and Hapag-Lloyd