Four Friday Analyses: Section 338, CIT, and Drone Tariffs
Open the item tied to an August 19 entry, an August 24 litigation filing, a Canadian parcel, or a drone SKU. Each links to the full analysis and source trail.
Good morning. On Friday, the analysis desk published four reads for customs, sourcing, and litigation files.
As of 7:55 a.m. Eastern on August 17, CBP's public CSMS feed still showed no Section 338 filing instruction naming headings 9903.03.12 through 9903.03.16. Canada Section 338 duties remained scheduled for August 19. Identify the Commissioner instruction or written CBP direction being relied on, then test each filing profile in the named ACE environment before sign-off.
Read it in full: Canada Section 338: No CBP Filing Instructions Found in the Reviewed Public Record.
The CIT intends to proceed first on one representative sample case and anticipates staying the others. Because non-sample plaintiffs are confined to a limited amicus role, counsel need a case-by-claim crosswalk before the August 24 opening brief.
Read it in full: CIT Forced-Labor Tariff Sample Case: Why Claim Coverage Controls.
Canada's Section 338 carveout for accompanied baggage does not extend to a commercial parcel merely because it is under $800 or bought for personal use. Coverage still begins with Canadian origin and a listed HTS provision, followed by exception and entry-route review.