Tariff Watch: Canadian Import Bans to Begin, Secondary Tariff Authority Becomes Law, CBP Pushes for New Rules 

Welcome to Tariff Watch, the weekly series from J.M. Rodgers that is designed to keep busy importers, manufacturers, and supply chain leaders on top of rapidly changing US trade policies.

As Q3 ‘26 winds down, a historic prohibition on targeted Canadian goods will take effect on Tuesday. Meanwhile, President Donald Trump has gained new statutory authority for secondary tariffs, and CBP has proposed a new rule that could increase importers’ administrative burden.

Here’s what you need to know this week:

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What’s New

• Canadian import bans set: Effective at 12:01 am EDT on Tuesday of this week, September 29, the US will enforce an outright import ban on specified Canadian products. Presidential Proclamations 11061, 11062, and 11063 mandated this action, converting the previous 50% Section 338 duties into a complete import prohibition on specific Canadian-origin alcoholic beverages, dairy products, molasses, non-alcoholic beer, and motor vehicle and motorcycle products.
• President gains secondary tariff authority: Following the signing of the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 a little over a week ago, President Trump now has statutory authority to raise duties of up to 500% on Russian goods. The law also gives the President the authority to impose secondary tariffs of up to 100% on all imports from countries that rank among the top five purchasers of Russian oil or natural gas, or that facilitate sanctions evasion. The law, named in honor of the late US Senator, requires the President to implement any sanctions, tariffs, or other restrictions by October 18, though the legislation provides some flexibility through exceptions and waiver clauses.
• CBP advances new rulemaking effort: US Customs and Border Protection (CBP) has proposed a new rule, titled Heightened Import Disclosures for Supply Chain Visibility. CBP recently filed an Advance Notice of Proposed Rulemaking (ANPRM) and is accepting public comment on the proposal through December 1. If it becomes a final rule, US importers of record would be required to obtain and submit expanded supply chain tracing data before shipment and present, at the point of entry, the official filings submitted by the exporter to their country’s customs authority.

Who’s Impacted

Here’s who is most affected by this week’s news:

• Food, beverage, and automotive importers: US businesses who previously imported specific Canadian dairy, alcohol, and motor vehicle products can no longer bring those goods across the border starting Tuesday.
• Importers sourcing from major Asian and Eurasian hubs: Because the new secondary tariff authority targets the top five buyers of Russian energy and top facilitators of sanctions evasion, importers sourcing from major manufacturing hubs — potentially including China, India, Turkey, and the UAE — face new geopolitical tariff exposure of up to 100%.
• Cross-border shippers: With the new Entry Type 13 (ET13) now live in the ACE Production environment for a full week, consignees who are not the owner or purchaser of international mail shipments must utilize a licensed customs broker acting as the importer of record under an obligated bond.

What We’re Seeing

The supply chain never sits still, and neither do the business leaders who react to the constant change. Here’s what we’re seeing them do this week:

• Leveraging the Section 338 arrival transition rule: Under CBP’s Section 338 filing guidance, the September 29 prohibition hinges on the date of importation rather than the date of entry filing. Importers with covered Canadian inventory that arrived in the US or entered a bonded warehouse before Tuesday are coordinating closely with their brokers, as those goods remain eligible for withdrawal for consumption at the 50% duty rate rather than falling under the ban.
• Preparing for the CAPE Phase 3 launch: Qualifying importers who have secured specific reliquidation orders from the Court of International Trade (CIT) are finalizing their entry data reconciliations ahead of next week’s October 6 opening of CAPE Phase 3 to claim IEEPA refunds on entries liquidated for more than 80 days.
• Onboarding for ET13 data validation: Postal consolidators and cross-border e-commerce platforms are running live sample data tests in ACE to ensure ET13’s mandatory tracking numbers and sender name and address fields transmit without error.

What We’re Monitoring

The J.M. Rodgers team is keeping a close watch on these important happenings:

• The secondary tariff review period: Now that the Graham Sanctions Act is law, we’re tracking the administration’s initial 30-day review period to see if the White House moves toward invoking secondary tariffs on third-party trading partners or exercises national security waivers.
• The CAPE Phase 3 rollout: We’re anticipating next Tuesday’s launch of CAPE Phase 3 and closely watching how smoothly ACE processes refund applications for finally liquidated IEEPA entries. We also continue to monitor CIT filings to see whether non-litigating importers may one day be granted access to Phase 3.

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Sources

• New US Bans to Take Effect Tuesday, Global News
• President Trump Signs Graham Sanctions Act, JD Supra
• Heightened Import Disclosures for Supply Chain Visibility, Regulations.gov
• Modifying Section 338 Additional Duties on Certain Goods, CBP