Daily Trade Brief · August 28, 2026
CBP Resets Tariff Filing Order
CBP Revises Chapter 98/99 Filing Order as Commerce Reopens Korean Wire Rod Review
New entry-summary sequencing places Section 338 between Section 301 and Section 232. Separate August 28 notices change liquidation or assessment treatment for three steel products, while Treasury updates Venezuela licenses and advances Iran-related sanctions and bank controls.
Today’s six substantive updates
- CBP filing order: CSMS #69668138 gives the current ACE sequence when one entry-summary line carries Chapter 98 or 99 classifications. Within trade remedies, the order is Section 301, Section 338, Section 232, Section 201 duties, then Section 201 quota.
- Korean steel wire rod: Commerce reopened the 2023–2024 antidumping review after receiving new evidence of possible fraud and intends to suspend liquidation while reconsidering the prior 0.00% result.
- China/Vietnam pipe fittings: Commerce now treats fittings formed into rough shapes in China and further processed in Vietnam as subject to the China antidumping order, with suspension of liquidation and cash deposits at the appropriate rate.
- Japanese hot-rolled steel: Commerce amended Nippon Steel’s 2018–2019 review margin from 11.70% to 10.12%. The notice changes assessment treatment for unliquidated review entries but not Nippon Steel’s current cash-deposit rate.
- Venezuela licenses: OFAC issued eight amended general licenses and removed the former U.S.-law choice-of-law requirement from covered contracts; FAQs 1267 and 1268 confirm that an approved dispute-resolution forum remains mandatory.
- Iran/UAE finance: OFAC designated Reza Mohammad Taeedi and Kameng Trading Limited. FinCEN separately proposed to bar U.S. correspondent accounts for Banque Misr UAE and require controls against indirect processing; the restriction is not yet final.
Immediate operational priority: entry writers should align ACE templates and software logic with CBP’s six-step order before filing a line that combines ordinary HTSUS classification with Chapter 98 or Chapter 99 provisions. Importers of the affected steel products should also identify unliquidated entries because the new Commerce notices may alter suspension, deposit, or assessment instructions.
1. CBP publishes a new order for multi-HTS entry lines
CBP released CSMS #69668138 at 9:35 a.m. Eastern on August 27. It applies when an importer claims a Chapter 98 or Chapter 99 provision and must report multiple HTSUS classifications for one article on the same ACE entry-summary line. The message does not announce a delayed implementation date; it presents the sequence as current filing guidance.
| Order | Classification to report | Filing note |
|---|---|---|
| 1 | Chapter 98 classification | Only when applicable. |
| 2 | Chapter 99 classification(s) for additional duties | Report applicable additional-duty provisions before the trade-remedy sequence. |
| 3 | Trade-remedy Chapter 99 classifications | Section 301 → Section 338 → Section 232 → Section 201 duties → Section 201 quota. |
| 4 | Chapter 99 replacement-duty or other-use provisions | CBP cites Miscellaneous Tariff Bill provisions as an example. |
| 5 | Other Chapter 99 quota | For quota not already covered in the trade-remedy sequence. |
| 6 | Chapter 1–97 classification | The ordinary classification closes the sequence. |
CBP directs filers to report entered value on the Chapter 1–97 classification, unless a Chapter 98 reporting provision says otherwise. A filer that encounters an error should contact its CBP client representative or the ACE Help Desk; trade-remedy filing questions may be directed to CBP’s Trade Remedy Branch, according to the same message.
2. Commerce changes the posture of three steel antidumping matters
Korean wire rod review reopened; liquidation suspension is planned
Effective August 28, Commerce reopened the 2023–2024 administrative review of carbon and alloy steel wire rod from Korea after receiving new evidence of possible fraud that may affect the integrity of the final results. The April 7 final results had assigned the sole mandatory respondent, POSCO/POSCO International Corporation, a 0.00% weighted-average dumping margin. Commerce is not requesting submissions yet; it plans a later procedural memorandum. It also intends to tell CBP to suspend liquidation of covered review entries during reconsideration and may issue new assessment instructions after revised results. Federal Register notice, 91 FR 55516.
Chinese rough-shape pipe fittings remain in scope after Vietnam processing
Commerce amended its covered-merchandise determination after a July 29 Court of International Trade judgment. Rough shapes of carbon steel butt-weld pipe fittings formed in China are now treated as unfinished fittings covered by the China antidumping order, and further processing in Vietnam does not remove them from that order. The notice is applicable August 8, 2026. Commerce will instruct CBP to suspend liquidation of finished and unfinished fittings that meet both conditions and require cash deposits at the appropriate rate. Federal Register notice, 91 FR 55518.
Nippon Steel’s historical review margin becomes 10.12%
Commerce amended the final results for the October 1, 2018–September 30, 2019 review of hot-rolled steel flat products from Japan, reducing the Nippon Steel group’s margin from 11.70% to 10.12%. The notice is applicable April 18, 2026. It will affect assessment of appropriate unliquidated entries from that review, but Commerce states that Nippon Steel has a superseding cash-deposit rate, so the notice will not change its current deposit rate. Federal Register notice, 91 FR 55513.
3. OFAC removes a contract choice-of-law condition from Venezuela licenses
On August 27, OFAC issued amended Venezuela-related General Licenses 46D, 47B, 48C, 50C, 51C, 52B, 54B, and 61A, covering specified activities in oil and petrochemicals, U.S.-origin diluents, energy-sector supplies and services, named oil-and-gas entities, minerals including gold, PdVSA, mineral operations, and telecommunications. The complete set is linked from OFAC’s August 27 issuance notice.
New FAQs 1267 and 1268 explain the common contract change. Covered contracts with the Government of Venezuela or specified blocked parties no longer must provide that the agreement be construed under the law of a U.S. state or jurisdiction. They must still require dispute-resolution proceedings to occur in the United States, United Kingdom, France, or Singapore.
4. OFAC designations take effect; Banque Misr UAE restriction is proposed
OFAC’s August 28 list update adds Iranian national Reza Mohammad Taeedi, identified as the manager of Bank Melli’s Dubai branch, and Hong Kong company Kameng Trading Limited to the SDN List. U.S. persons must block covered property and interests in property, and entities owned 50% or more in the aggregate by blocked persons are also blocked under OFAC’s ownership rule.
In a separate action, FinCEN released a Section 311 notice of proposed rulemaking addressing Banque Misr’s five UAE branches. The proposal would prohibit U.S. financial institutions from opening or maintaining correspondent accounts for or on behalf of Banque Misr UAE, require reasonable steps not to process transactions involving it through foreign-bank correspondent accounts, and impose special due diligence. The proposal expressly excludes Banque Misr operations outside the UAE.
5. Practical impact on importers, brokers, and finance teams
| Business function | Immediate consequence | Control point |
|---|---|---|
| Customs brokers and entry writers | Multi-HTS lines involving Chapters 98 or 99 must follow CBP’s current sequence. | Update ABI/ACE templates, tariff stacks, desk procedures, and test cases; keep entered value on the Chapter 1–97 line unless Chapter 98 directs otherwise. |
| Steel importers | Liquidation, deposits, or historical assessments may change depending on product and review. | Map unliquidated entries to the Korean wire rod, China/Vietnam fitting, or Japanese hot-rolled proceeding and preserve entry-level documentation. |
| Venezuela transaction counsel | A U.S. choice-of-law clause is no longer a license condition, but the permitted dispute forum remains required. | Recheck the specific current license, contract forum, counterparty, payment route, reporting obligation, and ownership screening. |
| Sanctions and payments teams | Two new SDN entries require screening updates; Banque Misr UAE creates proposed correspondent-risk controls. | Rescreen names and ownership, identify direct and indirect payment exposure, and distinguish current OFAC blocking from FinCEN’s pending rule. |
6. Action list for today
- Rebuild multi-HTS filing logic. Configure the six CBP layers in order and verify the nested trade-remedy order: 301, 338, 232, 201 duty, then 201 quota.
- Test value placement. Confirm that entered value posts to the Chapter 1–97 classification unless the claimed Chapter 98 provision requires another method.
- Inventory affected steel entries. Separate Korean wire rod review entries, China-formed/Vietnam-processed fittings, and Nippon Steel review entries because each notice produces a different liquidation or deposit result.
- Refresh Venezuela contract templates. Remove any assumption that U.S. governing law is mandatory, preserve an authorized dispute-resolution forum, and revalidate all license-specific conditions.
- Update sanctions and payment screening. Add Taeedi and Kameng Trading Limited, apply the 50% ownership rule, and flag Banque Misr UAE payment paths for enhanced review while the Section 311 proposal proceeds.
7. What to watch next
- Korean wire rod: Commerce’s procedural memorandum, opportunity for submissions, reconsidered results, and any new CBP assessment or cash-deposit instructions.
- China/Vietnam fittings: CBP suspension and cash-deposit instructions implementing the amended covered-merchandise determination, plus any appeal of the CIT judgment.
- Banque Misr UAE: Federal Register publication of the NPRM, the resulting 30-day comment deadline, and any final Section 311 special measure.
- CBP filing sequence: ACE rejection patterns or follow-up technical clarification for software vendors and entry filers applying CSMS #69668138.
8. Frequently asked questions
What is the Chapter 99 trade-remedy order under the new CBP guidance?
Report applicable Section 301 first, then Section 338, Section 232, Section 201 duties, and Section 201 quota. This trade-remedy group comes after Chapter 98 and Chapter 99 additional-duty provisions and before replacement-duty, other-quota, and Chapter 1–97 classifications.
Does the Korean wire rod notice immediately establish a new dumping rate?
No. Commerce reopened the review and intends to suspend liquidation while it reconsiders the 0.00% final result. A revised assessment or cash-deposit rate would require further action described in later results or instructions.
Are Chinese rough-shape pipe fittings outside the order after processing in Vietnam?
No, not when the products meet the conditions in the amended determination. Commerce now treats rough shapes formed in China as unfinished in-scope fittings, and further processing in Vietnam does not remove them from the China antidumping order.
Did OFAC eliminate all contract conditions from the amended Venezuela licenses?
No. The former U.S. choice-of-law requirement was removed, but covered contracts still need dispute resolution in the United States, United Kingdom, France, or Singapore, and every license retains transaction-specific conditions and exclusions.
Has Banque Misr UAE already been cut off from U.S. correspondent banking?
No. FinCEN has proposed the special measure. The OFAC designations of Taeedi and Kameng Trading Limited are effective, but the Banque Misr UAE correspondent-account restriction would require completion of the rulemaking process.
9. Primary sources and publication dates
- CBP CSMS #69668138 — Updated Guidance: Entry Summary Order of Reporting for Multiple HTS when 98 or 99 HTS are Required, August 27, 2026, 9:35 a.m. Eastern.
- Commerce — Korean carbon and alloy steel wire rod review reopening, 91 FR 55516, August 28, 2026.
- Commerce — China butt-weld pipe fittings amended covered-merchandise determination, 91 FR 55518, August 28, 2026.
- Commerce — Japanese hot-rolled steel amended final results, 91 FR 55513, August 28, 2026.
- OFAC — Issuance of amended Venezuela-related general licenses and associated FAQs, August 27, 2026.
- OFAC Venezuela FAQs 1267 and 1268, August 27, 2026.
- OFAC — Iran-related and counterterrorism designations, August 28, 2026.
- FinCEN — Proposed special measure regarding Banque Misr UAE, released August 28, 2026.
- U.S. Treasury — Iran’s Access to UAE Banks Targeted Under Operation Economic Outcast, August 28, 2026.
Compliance note: This report is for general information only and is not legal advice, sanctions advice, customs-brokerage advice, or shipment-specific customs advice. Classification, scope, liquidation, deposit, licensing, and blocking treatment depend on the complete facts and controlling official text. Verify live agency instructions before acting.