October 6, 2026 · U.S. trade and customs update
USTR confirms China Section 301 actions will continue and corrects a product exclusion
Two USTR notices filed for public inspection on October 6 clarify the status of existing China Section 301 measures. The 2018 actions survived their statutory review dates, while a separate amendment preserves one exclusion across a July 1 statistical-code change. Neither notice announces a new tariff rate. OFAC also issued Iran banking-risk guidance and revised sanctions lists; Commerce released preliminary paper-bag review results for three countries.
Two China Section 301 actions did not expire
USTR said the Section 301 actions originally taken on July 6 and August 23, 2018, as subsequently modified, did not terminate on July 6 and August 23, 2026. Domestic industry representatives submitted timely continuation requests. The actions therefore remain in force while USTR conducts a further statutory four-year review. USTR will announce a separate process for public comments on effectiveness, other possible actions and economic effects. The notice was filed at 8:45 a.m. EDT on October 6 and is scheduled for Federal Register publication on October 7. USTR continuation notice.
Entry consequence: Do not remove an applicable China Section 301 Chapter 99 line on the assumption that either reviewed action expired. The continuation notice itself does not add a new duty rate or change a product list; apply the currently operative HTS and CBP instructions to each entry. Official notice.
One exclusion is aligned with a revised statistical number
A second USTR notice amends Additional U.S. Note 20(vvv)(i)(20) in HTSUS Chapter 99 so an existing exclusion continues to match a ten-digit statistical reporting category changed by USITC. The annex inserts a reference to statistical reporting number 8479.90.9591 effective July 1, 2026. It applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Standard Time on that date, as the annex states. This is a conforming description change, not a newly granted exclusion or a general tariff cut. CBP entry guidance is still to come. USTR amendment and annex.
Importers reviewing affected July 1 or later entries should match the written exclusion terms and statistical number to their goods, keep the underlying classification support, and wait for CBP's filing instructions before making a claim or correction. A ten-digit number alone does not establish eligibility. USTR notice.
OFAC updates Iran banking guidance and sanctions screening
Foreign financial institutions face an explicit Iran risk warning
On October 5, OFAC warned foreign financial institutions that continue doing business with sanctioned Iranian banks or Iran's financial sector that they could be sanctioned without advance notice. Its amended FAQ 156 explains how a specific Treasury decision imposing U.S. correspondent-account conditions or prohibitions would be published or placed on the CAPTA List. The alert warns of potential action; it does not itself impose a blanket new prohibition on every foreign bank. Firms using banks for trade payments should review Iranian-bank and third-country branch exposure. OFAC alert · FAQ 156.
Sanctions list removals and record updates
Also on October 5, Treasury said OFAC removed 125 individuals and entities from its sanctions lists and updated 22 list entries in a modernization review. This changes screening results for the affected names and identifiers. Parties should refresh sanctions-screening data and verify each counterparty against current lists; removal of one listing does not by itself resolve any other applicable restriction. Treasury announcement · OFAC list changes.
Paper shopping bag margins are preliminary
Commerce filed three antidumping administrative-review notices at 8:45 a.m. EDT on October 6 for scheduled publication on October 7. For the 2024–25 review period, its preliminary dumping margins are:
- Colombia: Ditar S.A., 6.47%. Commerce notice.
- India: Ckaari Packaging, 1.23%; Velvin entities, 3.01%; companies listed as not individually examined, 2.44%. The review is rescinded for seven other companies. Commerce notice.
- Malaysia: Hexachase Packaging, 2.16%; Commerce preliminarily found no review-period shipments by SBBP and rescinded the review for two other companies. Commerce notice.
These percentages are preliminary review margins, not new cash-deposit instructions. The notices tie any revised deposits for reviewed firms to later final results. Check the applicable existing company-specific deposit instruction for current entries. Parties may file case briefs within 21 days of Federal Register publication, subject to the notices' filing rules. Colombia · India · Malaysia.
Practical steps for importers and brokers
- Retain current Section 301 entry treatment while monitoring USTR's separate four-year review notice. USTR.
- For the affected existing exclusion, identify July 1-or-later entries and await CBP instructions on how to claim the amended statistical description. USTR annex.
- Refresh OFAC screening data and review payment-bank relationships with Iran exposure. OFAC.
- Do not replace current paper-bag cash deposits with preliminary review margins; track final results and any resulting CBP directions. Colombia · India · Malaysia.
Questions import teams are asking
Did USTR impose a new China Section 301 tariff?
No. The October 6 notice confirms that two existing actions did not terminate at their 2026 review dates. It announces no new rate or product list. USTR notice.
Is the 8479.90.9591 reference a new exclusion?
No. It aligns one pre-existing exclusion's text with a July 1 statistical reporting change. The written exclusion conditions still govern, and CBP said it will issue entry guidance. USTR annex.
Do the paper-bag percentages change deposits today?
No. They are preliminary margins in administrative reviews. Commerce states that new review-based deposit rates would follow final results, not these preliminary notices. Colombia · India · Malaysia.
Does the OFAC alert automatically bar every bank handling Iran transactions?
No. It warns of sanctions risk. FAQ 156 says a specific correspondent-account condition or prohibition would be issued and publicized through the stated process. OFAC alert · FAQ 156.
Primary sources and dates
- USTR, Continuation of Actions, filed October 6, 2026; scheduled publication October 7.
- USTR, Conforming Amendment to Product Exclusion, filed October 6, 2026; applies to entries from July 1.
- OFAC, October 5 list update, Iran alert, and FAQ 156.
- Commerce, paper shopping bag preliminary results for Colombia, India and Malaysia, filed October 6, 2026; scheduled publication October 7.