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The Month in International Trade—June 2026

Client Alert | 5 min read | 07.10.26

Top Trade Developments

Crowell Webinars

Crowell Speaks

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Anand Sithian or Simeon Yerokun or any member of the International Trade Group.

Top Trade Developments

State Department Proposes ITAR Part 130 Amendments to Reduce Defense Sales Reporting Burden

On June 15, 2026, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published a proposed rule to amend the International Traffic in Arms Regulations (“ITAR”), 22 CFR Part 130, governing disclosure of political contributions and fees or commissions paid in connection with foreign defense sales. The rule is issued in support of Executive Order 14268, which in part directed the State Department to reduce regulatory burdens associated with U.S. arms transfers. The proposed rule applies to applicants, suppliers, and vendors as defined under 22 CFR Part 130. Public comments are due on or before August 14, 2026.

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For more information, contact: Scott Wise, Chandler Leonard, Rachel Ferns, Nate Young

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch.

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For more information, contact: Anand Sithian, Caroline Brown, Scott Wise, Jeremy Iloulian, Kelsey Clinton

USTR Finds Certain Brazilian Practices in Six Issue Areas Actionable Under Section 301; Proposes 25% Tariffs on Brazilian Goods and Invites Comments

The Office of the United States Trade Representative (USTR) has issued a Notice of Determination and Request for Comments, finding that certain of Brazil’s acts, policies, and practices are actionable under Sections 301(b) and 304(a) of the Trade Act of 1974. If adopted as proposed, USTR would impose additional tariffs of 25% on Brazilian-origin goods, subject to specified exemptions.

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For more information, contact: Daniel Cannistra, Pierce Lee

Crowell Webinar

IEEPA – Navigating the U.S. Tariff Landscape After Learning Resources, Inc. v. Trump


View On Demand Here

About This Program
The Supreme Court's landmark decision on IEEPA tariffs has fundamentally reshaped the legal and commercial landscape for importers, exporters, manufacturers, investors, and the companies that serve them. Whether you are seeking refunds on duties already paid, defending against tariff-related litigation, or managing the ripple effects through your supply chain and shareholder base, the strategic calculus has changed — and time is of the essence.

Crowell is the leading firm advising companies on the impact of the tariffs imposed by President Trump, including those under IEEPA. As a result of our representation of hundreds of clients in both IEEPA recovery litigation, follow-on class actions, and related matters, we are able to provide unique insights on the current tariff landscape. Our attorneys bring together cross-disciplinary experience in trade law, class action defense, commercial litigation, claims trading, and vendor contracts to give you a comprehensive picture of the post-ruling environment.

What We Will Cover

  • IEEPA Tariff Recovery–Where Things Stand
    Active litigation in the Court of International Trade and the Federal Circuit has kept refund pathways open, but the window is time-sensitive. Companies should move quickly to quantify duty exposure, preserve refund claims, and stay current on rapidly shifting court developments.
  • Reviewing and Updating Vendor Contracts
    Tariff clauses in existing supplier and customer agreements are top of mind and may need review and updating.
  • Defending Tariff-Based Consumer Class Actions and Shareholder Suits
    Plaintiffs’ firms are actively targeting retailers and consumer goods companies over the pass-through of tariff surcharges to end consumers. Exposure is concentrated where pricing communications were imprecise, and results at the motion stage are mixed. Public companies may face securities fraud and fiduciary duty claims tied to insufficient disclosure of tariff exposure, particularly where prior forward-looking statements are now in tension with post-ruling realities.
  • Exploring Secondary Market for Refund Claims
    A growing secondary market has emerged for IEEPA-related duty refund claims, with investors acquiring importer rights as a distinct asset class. Valuations remain uncertain and the legal framework governing claim transfers is still developing.

Crowell Speaks

“Section 301 Forced Labor Investigations: UFLPA Overlap and What Companies Should Do Now,” ACI Advanced Forum on U.S. Customs Compliance & Enforcement, Arlington, VA (October 8, 2026). Speaker: John Brew

“EU Forced Labor Regulation & Comparative Analysis with the US & UK Regimes,” ICPA Fall Europe Conference, Glasgow (September 9, 2026). Speaker: Vassilis (Vass) Akritidis

“Building US Innovation and Industrial Ecosystems to Drive Industrial Strategy,” Industry Studies Association Annual Conference, The George Washington University, Washington, DC (June 5, 2026). Moderator: Monica Gorman

ACSS New York Chapter Event “Renewed Focus on Cartels, Transnational Criminal Organizations, and Foreign Terrorist Organizations: Compliance Challenges for Financial Institutions and Multinationals,” New York (June 4, 2026). Panelist: Caroline Brown

“Fireside Chat with Dr. Laura Taylor-Kale and Dr. Monica Gorman: Challenges and opportunities facing America’s industrial base in an era of intensifying geopolitical competition,” Industry Studies Association Annual Conference, The George Washington University, Washington, DC (June 3, 2026). Speaker: Monica Gorman

Recent Trends in U.S. Trade Remedy Measures and Strategic for Korean Exporters: Renewed Anti-Dumping and Countervailing Duty Risks in the New Tariff Environment (Korean). June 1, 2026 - Weekly Customs and Tariff Insights (Korean), vol.2181/ Korea Customs and Trade Development Institute

Contacts

Insights

Client Alert | 3 min read | 07.10.26

Federal Circuit Clarifies Application of Blue & Gold: Proposal Submission Deadline, Not Award, is the Operative Time for Filing

In Utech, Inc. v. United States, No. 24-1586 (Fed. Cir. June 24, 2026), the U.S. Court of Appeals for the Federal Circuit clarified that in most cases, a pre-award protest must be filed before the proposal submission deadline to avoid the Blue & Gold waiver rule.  This decision, while nonprecedential, is in line with U.S. Government Accountability Office (GAO) precedent, which has long held that pre-award protests must be filed before the proposal submission deadline....

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