FDA Reminds Food Facilities of Biennial Renewal Requirements:

The FDA is reminding all domestic and foreign food facilities that manufacture, process, pack, or hold food for human or animal consumption in the United States that they must renew their food facility registrations between October 1 and December 31, 2026. Facilities that fail to renew by December 31, 2026, will have expired registrations, which could result in entry processing delays for imported food shipments. Food facilities may submit their renewal information electronically through their FDA Industry Systems(FIS) account, unless FDA has granted them a waiver that allows for registration by mail or by fax. There is no fee associated with registration or renewal.

The U.S. Consumer Product Safety Commission (CPSC) has updated its guidance on Harmonized Tariff Schedule (HTS) codes flagged in CBP's Automated Commercial Environment (ACE).

The revised document lists approximately 600 HTS codes that may contain products subject to mandatory CPSC standards or considered high risk. The codes are now categorized by their assigned flag (CP1 or CP2), making it easier for importers and brokers to determine when product data may be required versus when it is required. The update also includes a Change Log identifying HTS codes whose flags were modified or removed. CPSC notes that the list is not exhaustive, and importers remain responsible for submitting electronic certificates of compliance when required. Additional guidance and the updated HTS list are available through the CPSC eFiling Document Library.

CAPE Phase 3 Deployment (Oct. 6, 2026)

CBP successfully launched Phase 3 of the Consolidated Administration and Processing of Entries (CAPE) refund system on Oct. 6, 2026. This phase is limited to finally liquidated entries for importers that have filed suit at the Court of International Trade and received court-ordered reliquidation. Approximately 6.2 million entries failed validation primarily because they exceeded CBP's 90-day reliquidation authority, lacked the required Chapter 99 HTS number associated with IEEPA duties, or had already been submitted in a prior CAPE declaration. CBP also notified eligible plaintiffs who provided importer of record numbers by July 30, 2026, that they may now file Phase 3 declarations, with separate instructions forthcoming for those who submitted importer information after that date.

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.

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