Pharma tariffs reach a new filing date

Section 232 pharmaceuticals: match the product to the right Chapter 99 heading

CBP issued CSMS #70054007 at 5:42 p.m. EDT on September 28. It implements Proclamation 11020 and Commerce’s September 23 technical notice for entries or warehouse withdrawals from 12:01 a.m. EDT September 29 for companies not in the proclamation’s Annex III. Annex III companies entered this regime on July 31. If more than one proclamation rate applies, CBP says to use the lowest applicable rate. USITC posted 2026 HTS Revision 20 on September 28 and lists Commerce’s notice as its modification source. CBP filing guidance · HTS Revision 20 and Modification Source · Commerce notice

The temporary 9903.04.61 provision is no longer available for covered September 29 entries. Commerce added 9903.04.70 for noncommercial research use, clarified that generic pharmaceuticals include unpatented animal-health products, and removed five overlapping codes from an earlier annex. An ordinary free-trade-agreement preference does not itself erase the Section 232 charge; applicable AD/CVD remains separate. CBP detail · Commerce technical corrections

USTR releases Akwel Juárez entries from its liquidation hold

USTR announced on September 28 that the U.S.–Mexico rapid-response labor matter at Akwel Juárez México had been remediated. Its letter to Treasury says it is no longer directing suspension of liquidation for unliquidated entries of goods from that specific Ciudad Juárez facility and asks Treasury to inform CBP. This changes the handling of affected entries; it does not create a Mexico-wide tariff preference or resolve unrelated holds. USTR announcement · Letter to Treasury

OFAC expressly adds methanol to three Venezuela petrochemical annexes

OFAC issued General Licenses 46E, 48D and 49B on September 28. Their annexes now expressly include methanol under HS lines 2905.11.1000, 2905.11.2010, 2905.11.2015, 2905.11.2085 and 9817.29.0200 in the defined petrochemical-product category. GL 46E covers specified Venezuelan-origin oil or petrochemical activity; GL 48D covers specified supplies and services; GL 49B permits negotiating and entering contingent investment contracts. OFAC release · GL 46E · GL 48D · GL 49B

The annex addition is a sanctions-license clarification, not a customs duty exemption. Under GL 49B, performance of a contingent contract still requires separate OFAC authorization. The licenses retain other party, vessel and agency restrictions. GL 49B conditions

Cuba payments rule is available for inspection but not yet in force

OFAC filed a final amendment to 31 CFR Part 515 at 8:45 a.m. EDT September 29, scheduled for publication September 30. The rule says it becomes effective on the date of publication. It would extend the Cuba Restricted List transaction prohibition to specified indirect financial transfers, remove the general authorization for U.S. banks to process qualifying “U-turn” payments that begin and end abroad, and narrow several travel authorizations. The existing direct-transaction prohibition remains. Public-inspection rule

A separate Cuba sanctions rule was also filed for September 30 publication under 31 CFR Part 516; it establishes a separate regulatory framework and should not be confused with an immediate new SDN designation. Part 516 filing

India and China graphite-electrode investigations flag possible retroactive holds

Commerce’s preliminary antidumping notices for large-diameter graphite electrodes from India and China were filed for public inspection on September 29 at 8:45 a.m. EDT, with publication scheduled for September 30. Preliminary weighted-average dumping margins are 12.22% for Graphite India, 4.97% for HEG and 6.95% for India’s all-others group; the China-wide margin is 98.79%. The notices separately show subsidy-adjusted deposit figures. India preliminary notice · China preliminary notice

Commerce preliminarily found critical circumstances for the named Indian groups and the China-wide entity, instructing suspension for qualifying unliquidated entries made up to 90 days before publication. These are preliminary findings, not final duty liability, and the percentages should not be treated as September 29 cash-deposit instructions. India suspension language · China suspension language

Steel pipe court amendments have different deposit consequences

In a Korean welded-line-pipe case, Commerce filed a court-amended determination listing SeAH at 4.55% and all others at 5.39%. It says SeAH has a superseding rate, so its current deposit rate does not change; Commerce intends to issue revised instructions for the all-others group. The notice says applicable September 25 and is scheduled for publication September 30. Korean line-pipe notice

In a separate Mexican light-walled rectangular-pipe review covering August 2020–July 2021, amended historical margins are 10.67% for Maquilacero/TEFLU and 6.06% for Perfiles and Productos Laminados. Commerce explicitly says current deposit rates will not change; specified old entries remain under a court injunction. This notice also was filed September 29 for September 30 publication. Mexican pipe notice

What to do next

1. Run September 29 pharmaceutical entries through the new Chapter 99 and U.S. note 40 tests before filing.
2. Review Akwel Juárez entries held under the USMCA labor matter for resumed liquidation instructions.
3. Update Venezuela methanol sanctions-license reviews without assuming tariff relief.
4. Prepare for the September 30 Cuba and graphite-electrode publications; verify final texts and CBP instructions before changing payment or deposit settings.

FAQ

Primary sources

• CBP CSMS #70054007 · USITC 2026 HTS Revision 20 and Modification Source · Commerce pharmaceutical notice
• USTR Akwel release · USTR Treasury letter
• OFAC September 28 license release · GL 46E · GL 48D · GL 49B
• OFAC Cuba Part 515 public-inspection filing · Part 516 filing
• India graphite preliminary notice · China graphite preliminary notice
• Korean line pipe court notice · Mexican pipe court notice