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Compliance calendar

Customs deadlines, September 2026 to February 2027

Twelve dated changes that land on U.S. importers and their brokers over the next six months. Each row says what changes, who it hits, and what to do, and links to the Federal Register document it came from. Last reviewed September 2, 2026.

How this list works

Twelve dates, each one checked

Every row below links to the document it came from: a Federal Register notice, a presidential proclamation, or the CFR. If we could not open the primary source and read the date in it, the item is not on this page. That rules out a few things you may have seen elsewhere, and we say which ones at the foot of the page.

Each row has its own anchor, so a single item can be linked directly. The anchor for the September 18 importer-of-record item, for example, is/deadlines#2026-09-18-ior-voiding. Anchors do not change once published, even if the text of a row is updated.

We re-read the list whenever a source changes or a new dated item publishes. Dates move. When a source changes, the row changes with it and the review date in this section moves when we do.

At a glance

The calendar

DateWhat changesWho it affects
2026Section 232 tariffs on unmanned aircraft systems take effectImporters of drones, drone components, docking stations and thermal-imaging payloads, plus the forwarders who move them.
2026Comments close on CBP's IEEPA refund information collectionAny importer that paid IEEPA duties, and any broker filing on their behalf.
2026CBP begins voiding importer of record numbers for inaccurate 5106 dataEvery importer of record. Most acutely, forwarders and 3PLs that completed a 5106 for a client and put their own office email or address in those fields.
2026Entry Type 13 mail test beginsE-commerce sellers, postal consolidators and 3PLs still moving goods into the U.S. by mail.
2026Section 232 pharmaceutical tariffs reach companies outside Annex IIIImporters of finished pharmaceuticals and pharmaceutical ingredients.
2026FY2027 customs user fees take effectEvery importer filing formal entries, and every broker holding a permit.
2026Postal formal-entry compliance date at 19 CFR 145.12E-commerce brands, postal consolidators and 3PLs whose goods trip a PGA, a Chapter 98 or 99 provision, or an FTA claim.
2026178 China Section 301 exclusions expireImporters of Chinese-origin goods currently claiming one of these exclusions.
2026Executive Order 14411's 180-day regulatory deadline landsForeign entities acting as importer of record, and the brokers and forwarders who file for them.
2026Comments due on CBP's supply-chain disclosure ANPRMImporters, licensed brokers, forwarders and carriers. Anyone whose suppliers would have to hand over foreign export paperwork.
2026Section 232 polysilicon and derivatives take effectSolar importers, module and cell buyers, and anyone importing polysilicon derivatives.
2027Section 232 second tranche: UAS components in Annex IIIDrone assemblers and component importers, including buyers who were unaffected by the September 3 tranche.

Each date is when the item comes due. Some rows are effective dates, some are comment deadlines, and one is a deadline for a rulemaking rather than for importers. Section 232 dates apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time that day.

September 2026

September 2026 in detail

Section 232 tariffs on unmanned aircraft systems take effect

Proclamation 11055 applies a 100 percent duty to unmanned aircraft systems over 25 kg maximum takeoff weight, thermal-imaging UAS, docking stations and critical components (Annex I), and 25 percent to UAS at or under 25 kg (Annex II). It bites on goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on September 3, 2026. Some trading partners have lower negotiated rates, so read the annexes rather than assuming the headline number. Clause 7 carries a delayed implementation: for companies on the Department of War's Blue UAS Cleared List, the Blue UAS Framework, or the FCC's Conditional Approval List on September 2, 2026, the effective date in clause 1 runs 180 days from the date of the proclamation. Read that clause before assuming the September 3 date applies to you.

Who it affects
Importers of drones, drone components, docking stations and thermal-imaging payloads, plus the forwarders who move them.
What to do
Map your part numbers to Annex I and Annex II before the next entry, and confirm which country rate applies to each line. A part that cleared at a low rate in August can carry 100 percent in September.

Primary source: Proclamation 11055, 91 FR 53699 (Aug 19, 2026)

Comments close on CBP's IEEPA refund information collection

CBP's notice for the "Court-Ordered Refunds Under the International Emergency Economic Powers Act Worksheet" is open for public comment until September 8, 2026. The notice describes the refund mechanism: importers submit CSV files of entry summary numbers through the ACE Portal, and CBP processes them in its CAPE tool so multiple entry summaries for one importer produce a single refund. CBP estimates 330,000 respondents for CSV submissions and 33,000 for replacements. The refunds follow the Supreme Court's February 20, 2026 decision in Learning Resources, Inc. v. Trump, which held that tariffs imposed under IEEPA were unlawful.

Who it affects
Any importer that paid IEEPA duties, and any broker filing on their behalf.
What to do
Comment if the process would burden you. More usefully, start pulling your entry summary numbers for the affected period now. CBP's own notice says most small businesses have no ACE account and enlist a licensed customs broker to act for them.

Primary source: 91 FR 42207 (July 8, 2026), FR Doc. 2026-13771

#2026-09-18-ior-voiding

CBP begins voiding importer of record numbers for inaccurate 5106 data

CBP is reviewing the CBP Form 5106 information on file for importers of record. From September 18, 2026, where the data is inaccurate or incomplete, CBP will void the IOR number, "rendering it invalid for any purpose, including entering imported merchandise into the United States." There is no cure period before the void. CBP then sends written notice to the importer's most recently submitted email address explaining the basis and how to request reestablishment. Two fields cause most of the trouble. The email address "must be valid and belong to the IOR", and "customs brokers or third parties may not supply their own email address." The physical address "must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center."

Who it affects
Every importer of record. Most acutely, forwarders and 3PLs that completed a 5106 for a client and put their own office email or address in those fields.
What to do
Pull the 5106 on file for each importer you handle and check the email and physical address against the notice. Correct anything that names your company instead of the importer, and file the update before September 18. If a number is voided, the reestablishment path runs through the written notice CBP sends.

Primary source: 91 FR 53627 (Aug 19, 2026), FR Doc. 2026-16911

Entry Type 13 mail test begins

CBP's test of a new electronic informal entry process for international mail commences on September 22, 2026 and runs until CBP concludes it by a later Federal Register announcement. Entry type 13 covers mail shipments valued at $2,500 or less, filed in ACE with twelve required data elements. The right to make entry is limited to the owner or purchaser of the merchandise, or a licensed customs broker properly appointed by the owner, purchaser or consignee.

Who it affects
E-commerce sellers, postal consolidators and 3PLs still moving goods into the U.S. by mail.
What to do
Decide who files. If you are not the owner or the purchaser of the goods, you need a properly appointed licensed broker to make entry. Get the power of attorney signed before the volume arrives.

Primary source: 91 FR 38007 (June 24, 2026), FR Doc. 2026-12668

Section 232 pharmaceutical tariffs reach companies outside Annex III

Proclamation 11020 took effect on July 31, 2026 for the companies listed in its Annex III, and takes effect on September 29, 2026 for other companies. The proclamation carries company-specific terms, including a reduced rate for companies with approved onshoring plans that rises to 100 percent on April 2, 2030, and a zero rate for companies with most-favored-nation pricing agreements through January 20, 2029.

Who it affects
Importers of finished pharmaceuticals and pharmaceutical ingredients.
What to do
Confirm whether your supplier or manufacturer sits in Annex III, and read the proclamation's own rate table before the next entry. This is an advisory row: the terms are company-specific enough that the proclamation text governs, not a summary of it.

Primary source: Proclamation 11020, 91 FR 18183 (April 9, 2026)

October 2026

October 2026 in detail

FY2027 customs user fees take effect

The merchandise processing fee ad valorem rate stays at 0.3464 percent. Only the dollar limits move: the FY2027 minimum rises to $34.58 and the maximum to $670.86. Informal entry and release fees are $2.77 automated, $8.30 manual, and $12.45 manual prepared by CBP. The annual customs broker permit user fee is $190.88.

Who it affects
Every importer filing formal entries, and every broker holding a permit.
What to do
Update the MPF floor and ceiling in your landed-cost model, quoting sheet or ERP on October 1. Quotes built on the FY2026 ceiling will understate duty on high-value entries.

Primary source: 91 FR 48398 (July 31, 2026), FR Doc. 2026-15530

Postal formal-entry compliance date at 19 CFR 145.12

The interim final rule that suspended the de minimis exemption for mail set a delayed compliance date: "The compliance date for 19 CFR 145.12(a)(2)(v) and (vi) is on October 22, 2026." After that date, mail shipments carrying partner government agency data requirements, duties under Chapter 98 or 99 of the HTSUS, or a claim for duty-free treatment under Chapter 98 or a free trade agreement must use formal entry rather than the informal postal process.

Who it affects
E-commerce brands, postal consolidators and 3PLs whose goods trip a PGA, a Chapter 98 or 99 provision, or an FTA claim.
What to do
Sort your catalogue now. Identify which SKUs fall into those categories, and line up a licensed broker to file the formal entries before October 22. The categories are product attributes, so the answer is stable per SKU once you do the work once.

Primary source: 91 FR 37801 (June 24, 2026), FR Doc. 2026-12669

November 2026

November 2026 in detail

178 China Section 301 exclusions expire

USTR's December 1, 2025 notice extended 178 product exclusions "through 11:59 p.m. eastern daylight time on November 9, 2026." They are claimed under HTSUS subheading 9903.88.69 (U.S. notes 20(vvv)(i) through (iv)) and 9903.88.70 (U.S. note 20(www)). As of September 2, 2026 no further extension has been published in the Federal Register.

Who it affects
Importers of Chinese-origin goods currently claiming one of these exclusions.
What to do
Search your filed entry lines for 9903.88.69 and 9903.88.70. For anything that matches, re-price the landed cost at the unexcluded Section 301 rate for entries after November 9, and watch for a further USTR notice. Do not assume another extension.

Primary source: USTR notice, FR Doc. 2025-21671 (Dec 1, 2025)

Executive Order 14411's 180-day regulatory deadline lands

Executive Order 14411, "Strengthening Customs Enforcement," was signed June 3, 2026. Its 180-day clock runs out on November 30, 2026. By then DHS is directed to issue or amend regulations on importer of record eligibility, minimum assets and bonding levels, and expanded data disclosures. For foreign importers of record, the order directs that they be prohibited from filing informal entry under 19 U.S.C. 1498, that they "may not rely on a continuous bond to meet the bond requirements for entry, except as permitted by CBP", and that they "be validated in CBP's Customs Trade Partnership Against Terrorism (CTPAT), if determined by CBP to be eligible, or use a CTPAT validated and licensed customs broker to file entries."

Who it affects
Foreign entities acting as importer of record, and the brokers and forwarders who file for them.
What to do
Read this as a deadline for the rulemaking, not for importer compliance. Nothing changes for an importer on November 30 by itself. If you import into the U.S. as a foreign entity, use the time to stand up a U.S.-domiciled importer of record. Borderless prefers a U.S.-domiciled IOR and is not CTPAT validated.

Primary source: EO 14411, 91 FR 35125 (June 10, 2026)

December 2026

December 2026 in detail

Comments due on CBP's supply-chain disclosure ANPRM

CBP published "Heightened Import Disclosures for Supply Chain Visibility" on September 2, 2026 at 91 FR 56408, as an advance notice of proposed rulemaking under docket USCBP-2026-1058, RIN 1685-AA47. An ANPRM contains no proposed regulatory text. CBP is asking for input on requiring foreign export documentation, on identifying the parties to an importation through enhanced identifiers, and on supply chain tracing technology. Comments must be received on or before December 1, 2026.

Who it affects
Importers, licensed brokers, forwarders and carriers. Anyone whose suppliers would have to hand over foreign export paperwork.
What to do
Read the questions and file a comment through regulations.gov under docket USCBP-2026-1058. What lands in the eventual rule will change what has to be collected from a supplier before an entry can be filed, so the cost of that collection is worth putting on the record now.

Primary source: 91 FR 56408 (Sept 2, 2026), FR Doc. 2026-17926

Section 232 polysilicon and derivatives take effect

Proclamation 11052 applies to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on December 4, 2026. It sets minimum import prices of $21 per kilogram for polysilicon, $100 per kilogram for polysilicon ingots and wafers, $0.22 per watt for solar cells and $0.38 per watt for solar modules, plus a 15 percent ad valorem duty on polysilicon ingots and derivatives, with exceptions for certain trading partners named in the proclamation.

Who it affects
Solar importers, module and cell buyers, and anyone importing polysilicon derivatives.
What to do
Compare your contract pricing against the minimums now, while there is still time to renegotiate or re-time a shipment. The certification mechanics sit in the proclamation text, so read it with your supplier's contract in hand.

Primary source: Proclamation 11052, 91 FR 51975 (Aug 11, 2026)

February 2027

February 2027 in detail

Section 232 second tranche: UAS components in Annex III

The same drone proclamation carries a delayed second list. Its Annex III components take effect for goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern time on February 9, 2027.

Who it affects
Drone assemblers and component importers, including buyers who were unaffected by the September 3 tranche.
What to do
Map your bill of materials against Annex III now rather than in January. Components that clear cleanly today can carry a Section 232 duty in February, and the sourcing decision takes longer than the classification does.

Primary source: Proclamation 11055, 91 FR 53699 (Aug 19, 2026)

Deliberately left off

A few items circulating in trade coverage are not here because we could not verify a date in a primary source. We could not confirm a September 2026 Court of International Trade conference in a primary source. The court's published calendar currently runs only through September 11, 2026, so we are not listing a date we cannot source. The 14 Section 232 steel, aluminum and copper derivative articles proposed by BIS closed for comment on August 27, 2026 with no determination and no effective date published yet. The Section 301 textile and apparel tariff-rate quotas are promised when USTR "determines that it is feasible", which is not a date. They go on this page the day a document gives them one.

This page is general information about published federal actions, not legal advice or a classification opinion for your goods. Read the linked source before you act on a row, and talk to us about how it lands on your specific entries.

Which of these hits your entries?

Send us your product list and the ports you use. We will tell you which rows apply, what has to change before the date, and what it costs to file with us.