Industrial Policy & Trade Monitor· 2674 actions· ✨ 91 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 US Department of Commerce published preliminary affirmative antidumping duty (AD) determinations on April 23, 2026 (Federal Register publication April 28, 2026), finding that crystalline silicon photovoltaic cells (whether or not assembled into modules) from India, Indonesia, and Laos are being sold in the US at less than fair value. Preliminary dumping margins are 123.04% for India, 35.17% for Indonesia, and 22.46% for Laos, with Commerce ordering US Customs and Border Protection to begin collecting AD cash deposits at those rates (107.77% adjusted cash-deposit rate for India; 22.06% for Laos). This runs parallel to, and stacks on top of, the CVD case on the same merchandise and countries (see responds_to), meaning combined AD+CVD cash-deposit burdens on subject imports now exceed 100% for all three origins. Final AD determinations are due July 13, 2026 (India, Indonesia) and September 9, 2026 (Laos).

Presidential Proclamation 11021 of 2 April 2026 (signed by President Trump, effective 6 April 2026 at 12:01 a.m. EDT, published 9 April 2026 at 91 FR 18201) consolidates and restructures the Section 232 tariff architecture for aluminum, steel, and copper. The proclamation modifies Proclamations 9704 (aluminum), 9705 (steel), and 10962 (copper) and applies tiered ad valorem duties to the full customs value of imported articles regardless of metal content: 50% on aluminum/steel articles and most copper articles; 25% on certain copper articles and on derivative articles substantially made of the three metals; 10% on derivative articles produced abroad using entirely US-smelted/cast metals; and 0% supplemental duty where existing tariffs already meet a 15% combined-rate floor. UK products receive preferential rates (25% on primary articles and 15% on certain derivatives) contingent on UK smelting/casting under the US–UK trade framework.

On 13 March 2026 USTR Jamieson Greer and Ecuador's Minister of Production, Foreign Trade and Investment Luis Alberto Jaramillo signed the United States–Ecuador Agreement on Reciprocal Trade in Washington, formalising the framework agreed in November 2025. Ecuador commits to preferential treatment for >90% of its agricultural schedule (including tariff elimination on soybeans, fresh/processed fruit, alcoholic beverages, tea, tree/ground nuts, dairy, beef, pork and poultry), to discontinue applying the Andean Price Band System to US-origin agricultural goods, to accept US remanufactured goods and US motor-vehicle safety/emissions standards, and to commit on digital-trade non-discrimination plus the multilateral moratorium on customs duties on electronic transmissions. The US in return grants MFN tariff treatment to qualifying Ecuadorian goods that "cannot be grown, mined, or naturally produced" in the US, by 1 August 2026 or entry into force (whichever is later). The Agreement enters into force 30 days after both parties notify completion of domestic procedures.

The US Department of Commerce published preliminary affirmative countervailing duty (CVD) determinations on February 26, 2026, finding that producers and exporters of crystalline silicon photovoltaic cells (whether or not assembled into modules) from India, Indonesia, and Laos received countervailable government subsidies. Preliminary subsidy rates are 125.87% for India; 85.99%–143.30% by individual Indonesian producer (104.38% all-others rate); and a uniform 80.67% for Laos. Commerce ordered US Customs and Border Protection to begin collecting cash deposits at these rates on subject imports pending a parallel antidumping investigation and final determinations later in 2026. The case originated from a petition filed in August 2025 by US crystalline silicon PV manufacturers.