Industrial Policy & Trade Monitor· 2670 actions· ✨ 89 recent

President Trump signed an Executive Order on June 3, 2026 restructuring the entire US customs-entry compliance architecture for global importers. Key provisions impose heightened bonding minimums and domestic-asset requirements for foreign importers of record (IORs), require CAATSA-compliance and supply-chain-disclosure certifications, restrict foreign IORs to formal entry only (creating a de facto US-IOR monopoly on informal entry), establish a "good standing" requirement for IOR eligibility, and sharply curtail CBP's mitigation authority while setting enhanced penalty floors. DHS/CBP is directed to implement penalty-floor, export-documentation, and disposal provisions within 90 days (~September 2026) and the IOR structural reforms within 180 days (~November 2026). The EO is structurally distinct from tariff-rate instruments (Section 232 Proclamations 11021/11032), trade-remedy channels (USTR Section 301), statutory forced-labor enforcement (UFLPA), and targeted-sanctions channels (BIS/OFAC) — it reshapes the foundational compliance architecture through which all goods enter the US market.

The Office of the United States Trade Representative released the 2026 Special 301 Report on 30 April 2026, designating Vietnam as a Priority Foreign Country (PFC) — the most severe category under Section 182 of the Trade Act of 1974 (19 U.S.C. § 2242). This is the first PFC designation since Ukraine held the status from 2013 through 2015, a gap of approximately 11 years. The PFC designation triggers a statutory 30-day window (expiring ~30 May 2026) within which USTR must decide whether to initiate a Section 301 investigation under 19 U.S.C. § 2412(b)(2)(A), which could lead to tariffs, withdrawal of trade benefits, or other Section 301 enforcement remedies against Vietnam. Separately, the EU was added to the Watch List for the first time, citing AI training-data, geographical-indications, and customs-enforcement concerns.

The U.S. Department of Commerce published a final rule establishing the Aluminum Import Monitoring and Analysis (AIM) system (19 CFR part 361), modelled on the pre-existing steel monitoring system. Importers, customs brokers, or their agents must obtain an online AIM import license for every entry of covered aluminum products, disclosing the countries where the primary aluminum used was smelted and where the product was most recently cast. The rule was announced 23 December 2020; after a stay and delay of the compliance date, it took full effect 28 June 2021, from which point a license became mandatory for all covered aluminum imports.