Podcast - A Midyear Road Map for U.S. Trade Policy and Enforcement

Molly O'Casey: Thank you for joining us for this episode of "Global Markets Policy & Power," a podcast exploring how geopolitical shifts, market volatility and regulatory forces converge to shape today's business landscape. We're joined today by my colleagues Ashley Akers, Pat Childress, Liz Cordova and Peter Tabor, who are partners with our regulatory practice group here at Holland & Knight. In this episode, we'll provide a lightning-round-style overview of the current tariff landscape, pending investigations by the [Office of the] U.S. Trade Representative and the current status of negotiations of trade agreements. But first, I'll let the team introduce themselves.

Ashley Akers: Hi, everyone, my name is Ashley Akers, and I'm a partner in the trade litigation section and help to run Holland & Knight's trade litigation team. We collectively represent hundreds of clients who are dealing with various tariff issues, including the hot topic of IEEPA (International Emergency Economic Powers Act) tariffs. We also practice and help our clients in trade enforcement areas, and happy to provide updates about that today.

Patrick Childress: Thanks, and I'm Pat Childress. I'm also a partner at Holland & Knight in the D.C. office. I'm part of the international trade team here. I joined the firm about a year ago from the Office of the U.S. Trade Representative, and when I was working for the government, I worked on some of the same issues that we'll be discussing today, namely Section 301 investigations and USMCA (United States-Mexico-Canada Agreement). Now that I'm in the private sector, my practice is pretty varied. I work a lot on trade policy issues, tariff mitigation and trade-related lobbying. Happy to be here, thanks.

Lizeth Cordova Solis: Hi, everyone, this is Liz Cordova from Mexico City. After spending 10 years myself in Washington, D.C., this is a pleasure for me to be sharing this forum with my D.C. colleagues. I'm currently leading the government affairs team in Mexico City, and we're very excited about this conversation, especially on USMCA. Here in Mexico, we're working very closely with our clients, representing them in different meetings related to these negotiations, and also on other topics related to trade and regulatory agendas in the country. So excited to have a conversation with my D.C. colleagues as well.

Peter Tabor: Hey everyone, this is Pete Tabor. I'm a senior policy advisor with Holland & Knight. I joined the firm about four and a half years ago. I've been working on regulatory and trade issues here in Washington, D.C., for 20-plus years, close to 25 years, including 13 or 14 at the U.S. Department of Agriculture, working specifically on trade and regulatory matters. Currently, I'm a registered lobbyist advocating for our clients, both on Capitol Hill and with the current or any administration that's guiding our trade policy.

Molly O'Casey: And I'm your host, Molly O'Casey, a trade associate, also in a regulatory practice. So let's get into it. For our first topic, the current tariff landscape, we'll be discussing the status of the global tariff under Section 122, refunds of the IEEPA tariffs following the Supreme Court's ruling on their illegality and sector-specific tariffs under Section 232. So what are our thoughts?

Patrick Childress: To put this in context, this all goes back to the Supreme Court's decision in February, which struck down the tariffs that were put in place under the International Emergency Economic Powers Act. And since that decision, the Trump Administration has been looking for a way to recreate the IEEPA tariffs with alternative tariffs under different statutory authority. And the Section 122 tariffs are the first step in that process. Now, if you remember, the Section 122 tariffs also came into force in February. So we had the Supreme Court decision that morning, the Section 122 tariffs were put in place that afternoon. And the Section 122 tariffs covered largely the same goods as the IEEPA tariffs. So that is most goods from all trading partners. Two important limitations to flag on Section 122. The first is that there's a rate limitation. So unlike IEEPA, under Section 122, the tariff rate can only go up to 15 percent. It's at 10 percent now, but it can only go up to 15 percent. The second limitation is a timing limitation. And this is also very important because these Section 122 tariffs will expire on July 24. And on that July 24 date, we expect the administration to replace the 122 tariffs with new tariffs under Section 301, which is an issue we'll be discussing a little bit later.

Ashley Akers: And on the IEEPA tariff refund front, as Pat mentioned, after the Supreme Court struck down the IEEPA tariffs back in February of 2026, there's been really extensive litigation at the Court of International Trade, as well as movement at Customs and Border Protection, CBP, to help effectuate refunds to the hundreds of thousands of importers that paid nearly $200 billion in IEEPA tariffs. Currently, there are two avenues by which importers of record are able to pursue refunds. One at Customs, directly from Customs, there are different phases that Customs has laid out for importers to seek refunds and file for those. However, those only cover about 60 percent of the refunds available. The other avenue that the Department of Justice insists that importers of record must take is by pursuing the refunds in an active litigation at the Court of International Trade. There are currently over 4,000 lawsuits by importers of record and a pending class action of importers who are actually seeking to get full recovery by filing those lawsuits at the CIT or Court of International Trade.

Just recently, there was a big update at that court posture whereby the Department of Justice actually appealed to the Federal Circuit, arguing that unless importers of record do file at the CIT, they will not be entitled to full relief. And so, what we're seeing here is importers of record having to take, sort of, the dual tracks to actually effectuate or receive a full refund. We have the Department of Justice arguing against full refunds unless that litigation is initiated. And then from the Court of International Trade's perspective, there's an administrative nightmare in essence because thousands and thousands of lawsuits are being filed and administering those and getting those into a state of recovery is really unprecedented. And so, what we can look forward to in the near future is receiving the Department of Justice's briefing on what exactly they argue are the legal limits of providing refunds in full to importers of record. And we'll also be watching how importers who have filed at the CIT are actually preferred over importers who don't. Just recently, the government said that there will be a preference towards importers that have initiated lawsuits, which puts some companies in a better position to receive refunds than others. So we'll continually watch what the Department of Justice's view on that is and help to advise clients on which avenue to take, if not both, so that full recovery can be received.

Peter Tabor: And on the 232 front, so Section 232 is a trade law under, it's actually Section 232 of the Trade Expansion Act of 1962. This is administered by the Department of Commerce. It's kind of familiar territory for those who work in tariff land, whereas IEEPA and [Section] 122 are kind of novel uses of trade law by the Trump Administration. The Trump Administration, dating back to the first Trump Administration, has been using 232 to impose tariffs based on a national security concern. And so we've seen broad utilization of 232s. We'll talk in a bit about the investigations that are pending, where tariffs haven't been announced – those are coming, we expect. But right now, the ones that most folks are aware of and are focused on relate to tariffs on steel, aluminum and copper and their derivatives, as well as new tariffs coming very soon, and next month, in fact, on pharmaceuticals, as well as tariffs on semiconductors. And so I think it's the key takeaway in all of these tariffs. One is that there's a broad definition by the administration of what constitutes a risk to national security, but two, also the administration has appeared to take a little more nuanced approach as time has progressed with the administration, and they have welcomed input from U.S. stakeholders to modify some of those tariffs. So you've seen 232s being updated this year based on the initial announcements last year to some tariff modifications – in fact, reductions – but they've ended all exclusions. They've suspended the inclusions process, which was to add tariffs. So there's a lot happening in the space of the 232s. We'll get into more on what's coming in a bit.

Molly O'Casey: Looking forward to it. Thanks for that. For our second topic, pending USTR investigations, we'll be discussing the current status of investigations under Section 301 of unreasonable discriminatory or partisan trade practices, as well as investigations under Section 232 of imports that threaten U.S. national security.

Patrick Childress: Thanks, Molly. This relates to the topic I was speaking about earlier, and specifically that the Section 122 tariffs that are in place now are going to expire on July 24. So, as I mentioned, Section 122 is step one of the administration's attempt to recreate the IEEPA tariffs that the Supreme Court struck down. Section 301 is step two of that process. And Section 301 is different from Section 122 in a few different ways. The first is that there's a lot more process involved in order to put in tariffs under Section 301, and I can speak a little bit more about that. The second is that unlike Section 122, there's no cap on the rate of tariffs under Section 301. So they can be quite a bit higher than the Section 122 tariffs, and that's important. Secondly, there's no time restriction on Section 301 tariffs the way we have on the Section 122 tariffs.

So what does that mean in the context of replacing the IEEPA tariffs? Well, the Section 301 tariffs that the administration's hoping to get in place are a better replacement for the IEEPA tariffs than the Section 122 tariffs for a couple of different reasons. Essentially, it helps with the replacement of IEEPA because there's not that upper limit. That means that these tariffs can be adjusted up or down based on how the trading relationship with a given trading partner is going. So what does that mean for the Trump Administration? That means that Section 301 tariffs are a great tool to use for leverage in trade negotiations. And for that reason, the Trump Administration is very keen to get these Section 301 tariffs in place. And the way they've chosen to go about doing this is by opening up a series of new investigations under Section 301. So the first relates to forced labor, and more specifically, these are investigations of 60 different trading partners and their failure to put in place and enforce a ban on goods made with forced labor. This is the investigation that's farthest along right now. So far, the administration has found the acts of these 60 trading partners actionable under Section 301 and has proposed tariffs under Section 301 against each of these trading partners. The level of those tariffs range from 10 to 12.5 percent. And those tariffs, right now, are proposed to cover most goods traded from those countries and imported into the United States.

Right now, there's still an opportunity for stakeholders to weigh in on those tariffs. There's a couple of weeks left to prepare and submit written comments. So that's an important flag there for stakeholders on timing with respect to the forced labor Section 301 investigations. There are a number of other 301s open right now, too, probably the most important of which is the manufacturing excess capacity investigation. And the reason that's important is because that covers a number of our most important trading partners. So that's one to keep an eye on. We expect USTR to issue its findings in that investigation very soon, and there are also open investigations of Brazil, Vietnam, and then just last week we had a new Section 301 investigation that opened related to Germany's pharmaceutical pricing practices. So it does look to me like Section 301 is quickly becoming the administration's tariff tool of choice. And I think the reason that's the case is because it does offer flexibility that some of the other tariff tools don't, specifically with respect to the duration of the tariffs and the level of the tariffs.

Peter Tabor: And on the 232 front, as I noted, there's many 232 tariffs already in place on steel, aluminum, copper and their derivatives, on auto parts, light trucks, timber, lumber and their derivatives. And some recently announced new tariffs on pharmaceuticals and semiconductors. There are also many investigations pending. And I think an important distinction to draw from Pat's comments about the 301s is that 301s are country-specific. And as Pat indicated, they do provide that leverage for negotiation, whereas the 232s are sector-specific, so they apply to imports from all countries. And they are the administration's attempt, as we've seen, to create some opportunity for reshoring of manufacturing here in the United States. So with respect to pending investigations by the Department of Commerce, BIS, the Bureau of Industry and Security, we've got a lot going on. And that includes pending investigations on robotics and industrial machinery, critical minerals, PPE, which is personal protective equipment, medical equipment and medical consumables, as well as commercial aircraft and jet engines, unmanned aircraft systems, more commonly referred to as drones, wind turbines, there's still an outstanding investigation on copper and then also on polysilicon, more commonly refer to as inputs for solar panels. And so those investigations are well underway. In some cases, the expectation is that the investigations and their recommendations have been delivered to the White House, and there is a clock that ticks generally for these investigations to conclude. They should be concluded within 270 days of being announced, and the dates for announcement vary depending on the sector. But then the president has 90 days to determine what action to take based on the investigation. So we would expect as with the 301s that we will see 232 announcements coming as well, but there also remains, as with 301s, opportunities to engage the administration, whether it's USTR or Commerce, and especially the White House, on these topics to try and provide them with further input as they make decisions on some of these tariffs.

Molly O'Casey: Interesting stuff. Thank you for that. For our third topic on negotiations with trading partners, we'll be discussing the current status of the USMCA, which is the free trade agreement between the U.S., Mexico and Canada, as well as agreements with China, India and the EU. What are our thoughts?

Lizeth Cordova Solis: Thank you, Molly. I would like to get started with the USMCA discussion, and before I go into the most recent negotiation topics, I just want to highlight a couple of observations that I made through this process that makes this negotiation very different to the previous ones. The first one is that I consider this to be a more political than a technical discussion at times. And the second observation is that, I think this bilateral negotiation – and emphasizing I'm bilateral because I think most of the discussions have been taken between Mexico and the U.S., sometimes Canada has been left behind – it started a long time before this past month, when it was officially announced that the joint review started. And so I would like to make a few comments on that before getting into topics.

So on the first part, the reason why I think this is highly political compared to previous occasions is that the presidents themselves are taking action into some of the decisions that are taking place. From the Mexican perspective, I can go back to January of 2025 when President Sheinbaum received the first threat to new tariffs that will be impacting USMCA. Probably a lot of us remember that time with stress because it was a lot of work for us trying to decipher how and what will come next. And I remember that I attended a meeting at Palacio Nacional, here in Mexico City, where the president called all of the CEOs from American companies and other companies that are using the framework to come with her to hear a message about the Mexico position, starting since January of 2025. For you to know, I mean, it's very obvious that Mexico, since the beginning, has been wanting some treaty with no or very few changes, but what came next is very interesting because the announcement was that we had postponed at that time, for a few months, any type of tariff that will come on that specific date. That day we saw two things: one, that the president took a cool-headed approach to the negotiations, and for that she was praised by a lot of the private sector. Her popularity actually increased that day, and everybody was happy with the first result of the first negotiations. But the second thing is that we knew from that moment that the president was going to be very involved on everything related to the USMCA.

Nonetheless, the private sector got organized and started to participate in different sections and in different organization chambers, etc., to put together a list of technical difficulties that [included a] couple of recommendations or changes on the treaty itself, but the negotiation quickly changed into a conversation of topics that were not necessarily included on the USMCA. And I'm referring to the second point, which is that the negotiation or the bilateral discussions have also included other topics related to security. There's a very robust agenda on security between the two countries. There's also been several discussions on agriculture. And this is related to many topics, as Peter maybe will tell us more. We also have the problem of the gusano barrenador (screwworm), which is also a topic for the bilateral negotiation. And then we also have all of the tariffs that have been discussed previously here, especially for Mexico. The steel, aluminum and the auto industry tariffs are the ones impacting, primarily, the negotiations.

And finally, I want to arrive to the point of 54 items. After this meeting in Palacio Nacional that I was telling you about, very soon after we started hearing our authorities talk about [it]. Everybody, you know, is curious about what this list contains, and I think for those who are familiarized to the report that the USTR releases every year on non-trade barriers, many of us can identify some of the topics in that list to be included in the requests from the U.S. to Mexico, but there was also some other topics included that were not necessarily sectorial. These were requests specifically from companies affected by policies from the Mexican administration in previous years. And so I think that while Mexico has been able to resolve most of the topics on this list or, you know, have proactive discussions on the agricultural and on the security agendas, there's still a lot to be done. And this is what takes me to my next comment, which is that we're not going to be able to have the treaty signed on the date that we were supposed to sign, because there's a lot of work to work on these issues that are not necessarily part of the USMCA treaty itself, but that are part of the negotiations between the two countries.

And then just to finalize, and I'll let my colleagues complement, the topics that are included in the actual USMCA, and I think they're also going to be important to have a detailed discussion on them as rules of origin. The request that the U.S. is making to Canada and Mexico on this matter is considered to be very tricky because of the way that the companies have already established themselves in Mexico and Canada. But there's also other topics that I think we will be hearing a lot of in the coming months, which is, of course, agriculture, but also how the critical minerals agenda links to the AI agenda in the U.S., as well as the energy discussion between the two countries. As you know, there is a high dependency of gas from Mexico to the U.S. That also plays a role in the leverage points for the negotiation. So I'll stop here, and I would like to hear from my colleagues.

Patrick Childress: Thanks, Liz. I wanted to pick up on something that you mentioned briefly toward the beginning of your comments, and that's this current dynamic that the United States and Mexico are currently negotiating bilaterally very important changes to a trilateral agreement. Right now, Canada does not have a seat at the table, and the U.S. government and the Mexican government negotiators are moving forward with an official cadence of negotiating rounds. This is very interesting and, to my knowledge, a unique turn of events in trade negotiations, and it's potentially a very dangerous spot for Canada to be in. And the specific concern from Canada's perspective, I think, is this: that the United States and Mexico could reach agreement on some very important changes to the treaty. And these aren't changes to bilateral issues that only apply to the U.S. and Mexico. These are changes to some of the core provisions of the treaty, including rules of origin and some of other provisions that Liz touched on. So the U.S. and Mexico could agree on these changes to the treaty and then show up in Ottawa one day, saying that this is the way it's going to be, these are the changes that we've agreed on, you can take it or leave it. And if that happens, I think the Canadian government is going to be under a lot of pressure to accept whatever changes the United States and Mexico have negotiated. And that's the case because Canada, while it's true that it's been very aggressively – over the last six or nine months or so – been looking to diversify its export and import markets around the world, so diversify out of its current reliance on the United States., that's going to be a long process, and as it stands today, the Canadian economy is still very dependent on the U.S. in broader North American markets. So again, I think the Canadian government is going to be under quite a bit of pressure to accept whatever changes are negotiated bilaterally to this trilateral treaty.

Peter Tabor: Yeah, and both Pat and Liz raised some really important issues that I think are relevant for the agriculture discussion within USMCA. You've got general consensus in the United States that USMCA, both Republicans and Democrats are supportive of the agreement, and to varying extents indicate that there could be improvements made to the agreement. But in the ag sector, there is largely support for not only extending the agreement, but perhaps even renewing it as it is. You do have significant pockets or sectors of the U.S. agriculture [industry] that would like to see some changes, mostly around seasonality for produce, that is ensuring that U.S. producers of fresh fruits and vegetables don't have to compete on shoulders of their seasons with imports from Mexico, and as well, you have the U.S. dairy sector that has long complained of Canada's milk supply management system and their allocation of tariff rate quotas for dairy and dairy products. And these, that latter topic in particular, was raised or noted by USTR Greer in his report to Congress on USMCA.

So I get the sense that for any topic that USTR has identified as a priority for USMCA renegotiation, the administration will be under pressure to achieve results in that space. So I think that with Canada dairy, for example, there will be a lot of pressure to secure some changes to the agreement. The last thing I'll note about USMCA and agriculture is, to Liz's point, on the issue of New World screwworm, we have seen live cattle trade has been something that has produced benefits for all three countries. Obviously, with the detection of a disease that has serious implications for the beef industry and live cattle trade in particular, these topics will seep into the negotiations. There's no doubt about it that they will figure prominently in terms of the systems in place to ensure that North American trade not only can grow, but that it can grow safely.

Patrick Childress: Thanks Pete. So I think we can move on from USMCA for now and touch on a couple of other active negotiations that are happening around the world. The first one that I wanted to touch on was the U.S.-China relationship, which we know has long been fraught and is always a dynamic one. Right now, we find ourselves in a bit of a detente with China, where the two governments luckily are no longer trying to one-up each other with respect to tariff rates. And specifically, today I wanted to talk a bit about this new concept of what USTR is calling a proposed China Board of Trade. So this is one of the big outcomes of the Trump-G[7] summit from May. And what the China Board of Trade is designed to do is to identify specific categories of what they're calling nonsensitive goods and agree to lower tariffs on these categories of goods. And right now there are still a lot of unknowns about what the Board of Trade is going to look like, including who actually is going to sit on this Board of Trade. But one thing that we do know is that there is a process in place now where stakeholders can propose to the U.S. government certain types of goods and categories of goods that would be good candidates for tariff reductions under the China Board of Trade. So there is a stakeholder comment process that's open right now. And again, so for stakeholders out there that either export to China or import from China, there's an opportunity right now to submit comments and make your voices heard. And there's a potential path for tariff relief that's open.

Peter Tabor: I'll jump in with respect to India and other countries. So China is kind of its own separate negotiating approach, partly because of the relationship between the two heads of state, but mostly because of the volume, the sheer volume of trade between these countries. But going back to the IEEPA landscape, that provided the impetus, and I think the 301s are going to continue to provide the impetus, for the bilateral negotiations that the Trump Administration favors. They're called ARTs, agreements on reciprocal trade, some are in place already with Malaysia, Cambodia, Indonesia, Taiwan, Ecuador, others at varying states of final agreement. A big one that's getting a lot of attention is India. We're talking to you the week of June 22. And USTR Greer is headed to India this week, and the expectation is that they're very close to a final agreement. All of these ARTs are designed to secure a tariff rate that's going to be below what countries that have not secured an ART with the United States would have to face to get their products into the United States market.

So the ART with India, the negotiation has been going on for several months now. It is very contentious politically in India, particularly in the ag sector. But the expectation is that we could see, sometime this summer, a final agreement there. And even closer on the calendar is the expectation that we'll see a final agreement with the European Union. And this has been termed the Turnberry Agreement named after the resort in Scotland where it was signed. And this agreement will lower tariffs for U.S. products, specifically in the industrial and ag sectors, into Europe. It will reduce those tariffs to zero for many of those products and set a 15 percent tariff for most European products coming into the United States. The expectation is that we'll see that signed – could happen this week or implemented and finally agreed this week by the European member states – which would put it into effect by that deadline that President Trump threatened July 4, where he threatened higher tariffs on European autos if the agreement was not put in place since it was agreed just about a year ago. So that's where things stand on those fronts. And we expect to see, like I said, a lot of movement on these agreements on reciprocal trade. The Trump Administration has a preference for one-on-one negotiations.

Molly O'Casey: Thanks for that. And last but not least, what issues should our listeners keep an eye on? We'll be discussing trends in how Customs is enforcing these changing tariff regimes, as well as a discussion on the recently published guidance on forced labor. Ashley, do you want to take it away?

Ashley Akers: Sure, thanks, I'm happy to wrap this up with some enforcement insights. So the big picture right now is that Customs and Border Protection and the DOJ are in full enforcement mode as these tariff regimes keep evolving as we've talked about here today. So a few things to keep on your radar. The first is that we're seeing a real push on the basic areas of compliance like accurate classification, valuation and country of origin. With all of these tariff changes, there are mistakes that are made or aggressive interpretations that lead to underpayments or misclassifications that are drawing a lot of scrutiny from Customs right now. We've seen an uptick in Customs audits and requests for information, so importers and companies down the supply chain really need to focus on clean records and strong documentation to help rebut those.

We've also seen a recent executive order called "Strengthening Customs Enforcement" executive order, which signals where the enforcement priorities are headed. It's putting a heavier focus on holding importers of record accountable, along with oversight of Customs brokers, which is a new field of enforcement as well. There are penalties that are outlined, and the hot topics that are being looked at are illegal transshipment, undervaluation and misclassification, and, like Molly will talk about in a moment, forced labor violations.

And then finally, the third prong that we're seeing a real dedication of resources to is the Department of Justice Trade Fraud Task Force. This is a cross-agency group that's coordinating both civil and criminal efforts. And treating tariff evasion not only as a revenue generator in the civil space, like it always has, but also as a national security priority in the criminal space. In that realm, we're seeing heavy use of the False Claims Act, particularly on what we call reverse false claims for duties that should have been paid, and we've seen in the last several months multiple multimillion-dollar settlements in cases involving fraud or antidumping evasion, many of which are driven by internal whistleblowers. So seeing that civil side, but we're also seeing parallel criminal enforcement investigations. And so the bottom line for businesses and companies and importers of record going forward is, there needs to be really clean records, very precise documentation, and everything submitted to Customs is going to have an extra look or an extra set of eyes these days.

Molly O'Casey: Thanks, Ashley. On forced labor, earlier this month, CBP published the Forced Labor Enforcement Operational Guidance for Importers. This guidance replaces the 2022 guidance, and unlike the 2022 guidance, which only covered the Uyghur Forced Labor Prevention Act or UFLPA, the 2026 guidance consolidates CBP's key forced labor authorities into one framework. This would be your UFLPA, your Section 321(a) under the Countering America's Adversaries Through Sanctions Act, or CAATSA, and the General Forced Labor Import Prohibition under 19 U.S.C. § 1307, which includes withhold release orders, or WROs, and findings. The 2026 guidance gives importers a clear compliance roadmap, but equally, this specificity means that importers are navigating a more demanding compliance environment.

We'll very briefly review some of the areas subject to the additional guidance. So CBP has provided enforcement process maps for each authority, giving importers a visual roadmap of detention, exclusion, seizure and protest pathways. For UFLPA matters, CBP now distinguishes between potential input cases where goods may have a Xinjiang or Entity List connection, and direct input cases, where CBP has identified such a connection. CBP also provides step-by-step guidance on CAATSA matters, which involve goods produced by North Korean nationals, as well as WROs and findings, which CBP issues when it has reasonable suspicion or probable cause that an import was produced with forced labor. The 2026 guidance identifies benefits for CTPAT (Customs Trade Partnership Against Terrorism) trade compliance members, including front-of-the-line admissibility review, redelivery, flexibility, preliminary hold notification and 48-hour advance notification for new WROs or findings. The guidance also provides expanded appendices that cover high-priority sector supply chain tracing documentation, practical UFLPA due diligence examples, best practices for portal submissions, as well as providing sample documentation for importers to reference.

All this to say, there's a lot covered in the guidance. It's nearly 80 pages long, and unfortunately we are coming up on time. So a key takeaway for importers is that CBP is signaling that it expects importers to engage in more proactive diligence before goods are detained, rather than tolerating reactive responses after shipment has been stopped. The amount of guidance on documentation also indicates that CBP expects a high level of detailed, organized and searchable documentation in importers' compliance programs as well as their submissions. Importers should leverage this new guidance to map their supply chains, build authority-specific response playbooks and make sure their evidence packages are ready before CBP comes calling.

With that, this has been a very interesting and informative time. Thank you all so much for running through these topics so efficiently. And for our listeners, to discuss any of these topics further, please feel free to reach out at the link provided.