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U.S. Compliance Advisory: August 24, 2026
CSMS # 69606660- GUIDANCE: Section 338 Additional Duties on Certain Goods of Canada: The temporary suspension of the Section 338 duties on certain Canadian goods ends August 22, 2026.
The attached Section 338 Canada HTS LIST contains the complete list of Chapter 1-97 tariff numbers covered by HTS headings 9903.03.12, 9903.03.13, and 9903.03.14, along with the exclusions under 9903.03.15 and 9903.03.16
Verifying Accuracy of Data on 5106 filing
CBP Enhanced Enforcement of Importer of Record (IOR) Data Accuracy
The Department of Homeland Security's U.S. Customs and Border Protection (CBP) is announcing stricter enforcement of Importer of Record (IOR) registration requirements under Executive Order 14411, "Strengthening Customs Enforcement." 2026-16911.pdf
Key Changes
- CBP will begin verifying the accuracy of information submitted on CBP Form 5106, the form used to obtain or update an Importer of Record number.
- Starting 30 days after publication in the Federal Register, CBP may immediately void an IOR number if it determines the information on file is inaccurate or incomplete.
- A voided IOR number cannot be used to import merchandise into the United States.
Information That Must Be Accurate:
Importers and customs brokers must ensure that the following information belongs directly to the importer and is current:
- Physical business address
- Email address
- Phone number
- EIN, SSN, or CBP-assigned identification number
CBP specifically states that:
- The physical address must be the actual location of the business or individual.
- Addresses of customs brokers, freight forwarders, registered agents, PO boxes, business service centers, or unrelated entities are not acceptable as the importer's physical address.
- Email addresses and phone numbers must belong to the importer, not to a broker or third party.
If inaccurate data is found, CBP may:
- Void the IOR number immediately.
- Take additional enforcement actions.
- Pursue penalties under customs laws.
- Refer cases involving intentional false statements for criminal or civil liability, including potential exposure under:
- 18 U.S.C. § 1001 (false statements)
- False Claims Act (31 U.S.C. § 3729 et seq.)
Reestablishing a Voided IOR Number
If CBP voids an IOR number:
- CBP will send notice to the importer's most recently reported email address.
- CBP may copy the last filing broker.
- The notice will explain how the importer may request reestablishment and what supporting information must be provided.
IEEPA Refund Processing Services
Email your request to: Customs_Compliance_Group@am.kwe.com and a member of our IEEPA Refund processing team will reach out to you.
ADVISORY SIGN UP – ONE FORWARDER, ONE BROKER = OVERALL COMPLIANCE
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