Tariff Watch: China Deadlines Loom, USTR Proposes Extension, CBP Continues ACAS Phased Enforcement

Welcome to the latest edition of Tariff Watch, the weekly series from J.M. Rodgers that keeps busy importers, manufacturers, and supply chain leaders up to date on rapidly changing US trade policy.

The final week of October quietly wrapped up what was otherwise a consequential month for North American supply chains. Instead of new tariffs and major policy shifts, federal agencies made moves to maintain the current status quo, including CBP extending its phased enforcement of new air cargo data requirements. But as we head into November, the trade community is holding its collective breath as key trade deals are set to expire early in the new year. Here’s what you need to know this week:

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What’s New

• USTR proposes extending Section 301 suspension: Early last week, the Office of the US Trade Representative (USTR) proposed a two-month extension to the suspension of Section 301 actions against China. Last year, the USTR mandated significant port fees on Chinese-origin vessels, along with related duties, following a Section 301 investigation into China’s maritime, logistics, and shipbuilding practices. However, a US-China trade deal suspended these measures until 11:59 pm Eastern on November 9, 2026. On Monday, October 26, the USTR proposed extending the suspension through January 9, 2027. A brief public comment period expired on Friday, and the USTR is expected to issue a Federal Register notice soon to make the extension official.
• More China deadlines loom: The USTR’s Section 301 actions are set to be suspended until early January, around the time other stopgap trade deals between the US and China will expire. The November 2025 Kuala Lumpur Joint Arrangement has kept the White House’s base reciprocal tariff rate against China at 10%, but that agreement’s current extension expires on January 10, 2027. That’s the same day the “30-for-30” framework expires, which includes $30 billion worth of tariff relief on everyday consumer goods and agricultural imports. The two nations continue trade negotiations, but without a long-term deal or further extensions, US importers could face stacked tariffs on China exceeding 100% in January.
• CBP extends ACAS phased enforcement period: US Customs and Border Protection (CBP) has extended the phased enforcement period for the Enhanced Air Cargo Advance Screening (ACAS) Interim Final Rule. Originally set for November 21, the full enforcement deadline has been pushed back to May 1, 2027. The ACAS rule requires air carriers and forwarders to submit more granular shipment data — including precise cargo descriptions and contact information for both shippers and consignees — to CBP for security screening before loading cargo onto US-bound aircraft.

Who’s Impacted

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

• Importers sourcing from China: The USTR’s proposed suspension of Section 301 actions for another couple of months is welcome news to importers of Chinese goods, who were potentially facing additional duties on November 10.
• Air cargo shippers: While CBP has extended the Enhanced ACAS enforcement deadline to May 2027, major air cargo carriers such as FedEx are requiring data consistent with the new rules starting this month, meaning shippers must adapt their data transmission processes sooner rather than later.
• Importers of Canadian goods: The latest scope modifications to the Section 338 import bans and 50% tariffs on Canadian-origin goods went into effect last Friday, October 30. As usual, this round of updates adds and removes specific HTSUS classifications from the tariff lists, triggering a flurry of updates to importer databases.

What We’re Seeing

Supply chain leaders are keeping busy with:

• Updating air carrier data: Although the timeline for phased Enhanced ACAS enforcement has been extended, large express carriers like FedEx and UPS are already tightening their requirements, forcing some shippers to update their automated data feeds this month.
• Navigating Section 338’s moving target: ”Update fatigue” is setting in as compliance teams process the October 30 scope modifications to the Section 338 Canadian tariffs. Because these duties apply regardless of USMCA eligibility and stack on top of Section 232, the constant addition and removal of HTS codes has led to weeks of what seems like persistent updates to internal systems.

What We’re Monitoring

The J.M. Rodgers team is keeping a watch on these upcoming milestones:

• US-China negotiations: The trade community is on high alert for White House or USTR announcements about extending the US-China trade agreements. While the proposed extended suspension of Section 301 actions should keep things as-is until January, we’re closely monitoring negotiations between the two nations for signs of a long-term deal.
• Public comments on new disclosure rules: The deadline for public comments on CBP’s Advance Notice of Proposed Rulemaking for Heightened Import Disclosures for Supply Chain Visibility is December 1. We’ve been closely watching industry response to the proposal, which would require foreign export documentation and granular origin data to be included with imports at the time of entry.

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That wraps up another week in US trade policy news. To stay ahead of this always-changing landscape, subscribe to Tariff Watch here. See you next week!

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Sources

• USTR Proposes 2-Month Extension of Section 301 Actions, Holland & Knight
• US-China Truce Extension: Why Compliance Teams Can’t Wait, Thomson Reuters
• “30-for-30” Identifies Products Recommended for Reduced Tariffs, SmarTrade
• CBP Announces Extension of Enhanced ACAS Full Enforcement Phase, CBP
• Navigating US Tariffs and Customs Regulations, FedEx
• Further Modifying the Scope of Products of Canada Subject to Duties, Federal Register