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Mayer Brown's July 2026 US-China Trade Monthly consolidates the month's most consequential developments affecting cross-border commerce between the two economies. The publication typically covers new or proposed Section 301 tariff actions, BIS export-control rule changes, OFAC sanctions updates, customs enforcement priorities, and any bilateral dialogue outcomes. In-house counsel at manufacturers, retailers, and technology firms should review the digest to identify goods classifications, license requirements, and origin documentation that may have shifted. The monthly format makes it a useful compliance checkpoint for trade-compliance teams updating internal tariff schedules, restricted-party screening protocols, and supplier-contract flow-down provisions ahead of the next reporting cycle.

President Trump's upcoming visit to China is expected to produce an extension of the bilateral trade truce, providing short-term predictability for tariffs, export controls, and customs enforcement. However, structural disagreements over industrial subsidies, technology transfer, agricultural purchases, and semiconductor restrictions remain unresolved and could resurface as new friction points. Companies should reassess tariff classification strategies, review supply-chain contingencies, and monitor any side agreements on export controls. The truce extension reduces immediate risk but does not eliminate exposure to sudden policy reversals if negotiations stall or if enforcement actions target specific sectors or entities.

The EU's revised Foreign Direct Investment Screening Regulation, set to apply in 2028, broadens the range of transactions subject to review and tightens cooperation among member states. The reform introduces harmonized minimum standards for risk assessment, expands covered sectors to include emerging technologies, critical infrastructure, and sensitive personal data, and mandates earlier notification triggers. National screening authorities gain enhanced information-sharing powers, and the European Commission may issue binding opinions on transactions affecting security or competitiveness across more than one member state. In-house counsel should reassess deal pipelines, update FDI risk matrices, and engage local counsel early in cross-border structuring. Companies with EU operations or targets should prepare for longer pre-signing review windows and document readiness for expanded information requests.

U.S. Customs and Border Protection has formally eliminated the informal, low-friction entry pathway previously available for low-value international mail shipments arriving in the United States. Under the updated rules, all such shipments must complete formal entry processes, including mandatory advance electronic filing of full shipment data, payment of all applicable duties and fees, and compliance with CBP admissibility review requirements. Affected importers, logistics providers, and e-commerce operators should update shipping workflows to integrate required data submission steps, verify all shipments meet admissibility standards, and build buffer time for potential CBP review to avoid unexpected cost overruns and shipment delays.

The DOJ has significantly ramped up trade enforcement following the 2025 creation of its Market, Government, and Consumer Fraud Unit and cross-agency Trade Task Force, highlighted by a $549.5 million False Claims Act (FCA) settlement with aluminum importers accused of evading antidumping and countervailing duties via falsified CBP entry documentation. This marks a sharp shift from prior customs enforcement led solely by CBP, as DOJ now frames duty evasion as fraud against the U.S. government, triggering treble damages, statutory penalties, and broader investigatory powers. Importers must audit core customs controls including tariff classification, valuation, country of origin, and AD/CVD compliance, ensure all government-facing import documents are accurate, and review UFLPA forced labor representations for consistency, as inaccuracies can support FCA claims.

A new Trump administration executive order directs DHS and CBP to implement a broad overhaul of U.S. import rules within 180 days, with 45- and 90-day interim milestones for legislative recommendations and preliminary documentation requirements. Key provisions include barring most foreign importers of record from filing informal entries or using continuous bonds, requiring all importers to maintain minimum domestic tangible assets or higher bond coverage, mandating expanded beneficial ownership, affiliate, and import volume disclosures, and tying import eligibility to the good compliance standing of both the importer and all its affiliates. The order also establishes a 50% minimum penalty floor for customs violations and loosens rules for seizing and disposing of noncompliant goods. Frequent importers should review their entity structuring, bond levels, and group-wide customs compliance history immediately, even before final implementing rules are issued, to mitigate supply chain disruption and enforcement risk.

The final installment of this customs enforcement series details 10 high-risk, often unlawful tariff-saving tactics importers pursue to cut landed costs, including misclassification to avoid Section 232/301 duties, underreporting dutiable assists and royalties, and unbundling costs to lower declared value. CBP now uses cross-entry data analytics to flag anomalous patterns like sudden classification shifts or outlier valuation compared to peer importers. Importers should conduct regular, product-focused classification and valuation reviews led by legal counsel, avoid outcome-driven customs planning, and ensure cross-functional teams (procurement, engineering) disclose all relevant costs to customs staff to reduce enforcement exposure.

Foley & Lardner’s guidance outlines five proactive best practices for U.S. importers navigating ongoing tariff volatility that drives unpredictable landed costs and supply chain disruptions. The recommended steps include auditing core customs determinations (tariff classification, valuation, country of origin) for accuracy, identifying the most tariff-sensitive products and supplier relationships, evaluating eligibility for duty-saving programs such as foreign-trade zones or duty drawback, reviewing commercial contracts for clear tariff cost allocation terms, and building a cross-functional escalation process for new tariff announcements. These measures help companies shift from reactive tariff response to deliberate risk reduction, minimizing exposure to overpaid duties, unexpected cost increases, and customs audit penalties.

Brazil’s Foreign Trade Chamber (GECEX) issued Resolution No. 938/2026 in July 2026, formalizing the continuation of the 12% export tax rate for crude petroleum oils and bituminous minerals. The resolution does not adjust the existing rate but confirms its ongoing applicability following a scheduled review period for these commodity export taxes. In-house counsel for Brazilian entities exporting these goods, as well as cross-border trade teams supporting such clients, must verify that customs filings, tax reporting, and supply chain documentation reflect the maintained rate to avoid compliance gaps, penalties, or shipment delays for post-resolution exports.

Recent amendments to Mexico’s judicial reform framework modify the scope of protections available to foreign investors under bilateral investment treaties, including new restrictions on local court jurisdiction and admissibility requirements for treaty-based dispute claims. These changes undermine the reliability of existing treaty recourse for investors facing regulatory actions, expropriation, or contract breaches tied to Mexican operations. In-house counsel for companies with current or planned Mexican investments should review existing investment structures, update treaty election clauses in cross-border agreements, and assess supplemental risk mitigation tools such as political risk insurance to address gaps in protection left by the reform.

The EU Carbon Border Adjustment Mechanism, in force since January 2026, is moving toward significant expansion. The Commission proposed in December 2025 to extend CBAM to downstream products, add anti-circumvention measures, and create a Temporary Decarbonisation Fund. The Council adopted its position in June, adding roughly 200 metal-intensive goods (forklifts, conveyor machinery, electric motor components) to the Commission's 180-product list. The European Parliament's ENVI committee voted in July to expand scope further to 457 products, including solar panels, heat pumps, and washing machine components, with a plenary vote expected in September. Trilogue negotiations will follow, with final adoption likely late 2026 or early 2027. The Q2 2026 CBAM certificate price was set at EUR 75.28. Importers should map supply chains now, secure third-party emissions verification, and prepare for expanded reporting obligations effective 2028.

On June 24, 2026, MOFCOM issued Announcement No. 24, operationalizing the State Council's March 2026 Regulation on Industrial and Supply Chain Security. The Measures create a formal investigation mechanism targeting two categories of conduct: discriminatory or restrictive measures imposed by foreign governments or international organizations on Chinese supply chains, and actions by foreign organizations or individuals that disrupt transactions with Chinese entities or adopt discriminatory practices causing substantial harm. MOFCOM may initiate investigations ex officio or based on stakeholder submissions, assessing impacts on critical materials, technology, capital, data, personnel, logistics, finance, and information flows. A cross-departmental coordination mechanism led by the State Council—spanning MOFA, NDRC, MIIT, Customs, and the Cyberspace Administration—signals a whole-of-government enforcement posture. Companies with significant China-based operations, suppliers, or customers should assess contractual exposure, document supply chain dependencies, and prepare for potential in

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