
October 9, 2026 · Trade and customs update
U.S. Content Guidance Filed; Mexico Auto Parts Entries Put on Hold
A new Commerce filing clarifies how U.S. content is counted for a narrow metals tariff rule affecting qualifying Canadian and Mexican goods; it is scheduled to take effect October 14. USTR has suspended liquidation of unliquidated entries from one Mexican auto-parts plant. OFAC expanded Iran-related shipping sanctions, while a Korean steel review changes two company-specific cash deposit rates today.
Commerce defines U.S. content for a limited Section 232 rule
The Bureau of Industry and Security filed guidance for public inspection at 8:45 a.m. EDT on October 9; Federal Register publication is scheduled for October 14. For covered products of Canada or Mexico that qualify for USMCA preferential treatment under Proclamation 11032, “U.S. content” includes the value of parts wholly obtained, entirely produced, or substantially transformed in the United States. It also includes, to the extent not already counted, U.S.-melted-and-poured steel and U.S.-smelted-and-cast aluminum or copper. Commerce notice; Proclamation 11032.
Effective date and limit: The guidance applies to covered goods entered for consumption, or withdrawn from warehouse for consumption, at or after 12:01 a.m. Eastern time on October 14, 2026, assuming the scheduled publication occurs. The proclamation already set a 25% duty on non-U.S. content, subject to a 15% minimum effective duty on the imported product. Today’s filing defines a valuation component; it does not announce a new tariff rate for all USMCA goods. Guidance; Underlying tariff provision.
USTR suspends liquidation at a Puebla auto-parts facility
On October 8, USTR requested a USMCA Rapid Response Labor Mechanism review of alleged interference with freedom of association and collective bargaining at GLM Components México in Puebla. USTR directed Treasury to suspend liquidation of all unliquidated entries of goods from that facility. Mexico has 10 days to say whether it will review the matter and, if it agrees, 45 days from October 8 to complete the review. The allegations have not yet been finally resolved. USTR announcement; Request to Mexico; Liquidation directive.
Entry consequence: Suspension delays final liquidation of affected entries; the notice does not impose a new tariff or a blanket import ban on Mexican auto parts. Importers should identify whether goods came from this named facility and preserve entry records. USTR directive.
OFAC expands Iran shipping sanctions and issues limited licenses
On October 8, OFAC added people, shipping and trading companies, and vessels associated with Iranian petroleum and petrochemical transport to its SDN List, including Samudra Marine Services Private Limited and named tankers. The designations are effective now; U.S. persons must screen counterparties, vessels, and entities covered by the 50% ownership rule. OFAC also removed two named container ships from the list. Complete OFAC list update.
Iran General License EE allows only ordinarily necessary wind-down transactions involving Samudra or entities it owns at least 50%, through 12:01 a.m. EDT on October 23, 2026, with payments to blocked persons going into a blocked U.S. account. Separately, Russia General License 13S replaces 13R effective October 8 and permits certain routine taxes, fees, import duties and licenses needed for U.S.-person operations in Russia through 12:01 a.m. EST on January 9, 2027, subject to its exclusions. Iran GL EE; Russia GL 13S.
Korean hot-rolled steel: two company-specific CVD deposits change today
Commerce published its final 2023 review of Korean hot-rolled steel flat products on October 9. The final subsidy rates are Hyundai Steel 1.28% and POSCO 3.68%. Commerce says these rates apply as estimated CVD cash deposits to subject shipments entered, or withdrawn from warehouse for consumption, on or after today’s publication. Other companies retain their most recent applicable company-specific or all-others rate. Historical assessment of 2023 entries follows separate CBP instructions. 91 FR 64635.
Two other October 9 publications report preliminary AD review margins: Cambodia paper shopping bags — Nice Packaging 20.08%, UUPak 73.30%, Brandart and TB Packaging 20.08%; Thai passenger and light-truck tires — Sumitomo Rubber (Thailand) and the listed non-examined companies 1.14%. These preliminary figures do not replace current cash deposit rates; Commerce says new deposit requirements follow final review results. Cambodia notice; Thailand notice.
Advance notice and Section 337 status
A Vietnam welded stainless steel pressure-pipe AD review was filed for public inspection on October 9 and is scheduled for October 13 publication. Commerce preliminarily assigns the Vietnam-wide entity a 90.80% dumping margin and proposes to rescind reviews for seven named companies. It is not a new current cash deposit rate; interested parties may comment after publication. Commerce public-inspection PDF.
In Section 337 investigation 337-TA-1472 concerning certain DRAM devices and products, the USITC accepted termination following settlement; the October 9 notice records a Commission decision made October 6. The case ended without an exclusion order. It is a separate investigation from 337-TA-1523. 91 FR 64678.
Three FTZ production proposals open for comment
October 9 notices invite comments through November 18, 2026 on proposed production activity at Norman Noble (implantable medical devices, FTZ 40, Ohio), Sanyo Denki America (cooling, servo and power systems, FTZ 50, California), and Yazaki North America (stamped copper terminals, FTZ 16, Michigan). These are applications, not production approvals. Their notices specify that any inputs already subject to Section 232 or 301 duties must be admitted in privileged foreign status under the cited rules. Norman Noble; Sanyo Denki; Yazaki.
Common questions
Does the new U.S.-content guidance apply to every Canadian or Mexican import?
No. It addresses the specific USMCA-qualifying products and metals tariff clause identified in Proclamation 11032. Commerce guidance; Proclamation.
Are GLM Components goods banned from import?
No blanket import ban is announced. USTR directed suspension of liquidation for unliquidated entries from the named Puebla facility. USTR announcement.
Can the preliminary paper-bag and tire margins be filed as new deposit rates?
No. They are preliminary review results; new deposits depend on final results and the applicable entry instructions. Cambodia; Thailand.
When does the Samudra wind-down license end?
At 12:01 a.m. Eastern daylight time on October 23, 2026, subject to the license’s conditions and exclusions. General License EE.
Are the three FTZ production applications approved?
No. They are proposed activities open for comment through November 18, 2026. Norman Noble; Sanyo Denki; Yazaki.
Primary sources and dates
- BIS notice, filed October 9; scheduled October 14
- Proclamation 11032, June 1
- USTR, October 8
- USMCA review request
- Liquidation suspension letter
- OFAC action, October 8
- Iran General License EE
- Russia General License 13S
- Commerce final CVD review, October 9
- Commerce preliminary AD review, October 9
- Commerce preliminary AD review, October 9
- Vietnam review public inspection, October 9
- USITC Section 337 termination, October 9
- FTZ 40 proposed activity, October 9
- FTZ 50 proposed activity, October 9
- FTZ 16 proposed activity, October 9
Research cutoff: October 9, 2026, around 8 a.m. Central. Public-inspection filings are distinguished from later Federal Register publication and from effective dates. The independent USITC HTS Modifications page and complete CBP CSMS list were access-restricted; the available HTS archive and public CBP bulletins were checked.
