President Trump Announces 25% Tariff on Trading Partners of Iran
On Monday, Jan. 12, 2026, President Donald Trump announced a new 25% tariff on all countries conducting business with Iran.
Trump shared the directive via Truth Social, stating, “Effective immediately, any Country doing business with the Islamic Republic of Iran will pay a Tariff of 25% on any and all business being done with the United States of America. This Order is final and conclusive.”
As of the morning of Jan. 13, 2026, the White House has yet to release a formal executive order or official directive regarding the new tariffs. Currently, no additional details have been provided beyond the president’s social media post.
Periodic Monthly Statement (PMS) Due Dates for 2026
Please see the attachment for the periodic monthly statement (PMS) due dates for 2026. Switching to PMS allows importers to consolidate duties and fees into a single monthly payment, which can streamline cash flow management and reduce administrative overhead. By deferring payments until the 15th working day of the following month, businesses can maintain better liquidity and gain more flexibility over their working capital.
Reminder: Electronic Refunds Are Mandatory Effective Feb. 6, 2026
Effective Feb. 6, 2026, U.S. Customs and Border Protection (CBP) will issue all refunds electronically via automated clearing house (ACH), subject to limited exceptions. This change is mandated by the electronic refunds interim final rule published in the Federal Register.
- Paper refund checks will no longer be issued. All refunds will be processed electronically through ACH.
- Refund recipients must have active Automated Commercial Environment (ACE) portal access with an importer subaccount.
- ACH banking information must be entered in the ACE portal under the ACH “Refund Authorization” tab to receive refunds.
- The first step to opening an ACE account is to update your company’s CF 5106 form to ensure that the contact email is correct, as after the ACE application is completed, a verification email will be sent to the email CBP has on file via the 5106.
Importers Without US Bank Account
Importers without a U.S. bank account must open a U.S. bank account or designate a customs broker with a U.S. bank account using CBP Form 4811.
Important Compliance Notes
- Once the ACH refund application is approved in ACE, all future refunds will be issued electronically to the designated U.S. bank account.
- Failure to provide the required ACH banking information will result in refund rejection.
- Rejected refunds will not accrue interest.
- To reissue a rejected refund, the importer must complete the ACH “Refund Authorization” tab in ACE and notify CBP’s refunds team at frn-achrefundsupport@cbp.dhs.gov.
Consumer Product Safety Commission E-Filing
If you import any of the Consumer Product Safety Commission (CPSC) product categories of interest listed below, you are strongly recommened to watch this recording of last week’s CPSC webinar on the new e-filing requirement that becomes effective July 8, 2026. CPSC also offers multiple resources that importers and trade partners can view to familiarize themselves with e-filing processes. All resources can be accessed in CPSC’s document library.
Children’s Product Certificate
Under U.S. law, a children’s product is defined as a consumer product designed or intended primarily for children 12 years of age or younger. In making this determination, the Consumer Product Safety Commission considers several factors, including:
- Manufacturer intent, including statements or labeling describing the product’s intended use, provided those statements are reasonable
- Marketing and presentation, including how the product is packaged, displayed, promoted or advertised for children ages 12 and under
- Consumer perception, meaning whether the product is commonly recognized by consumers as intended for use by children 12 years of age or younger
- CPSC Age Determination Guidelines, issued by commission staff in January 2020, and any subsequent updates to those guidelines.
See this list of CPSC FAQs for children’s products to determine if the product you import is subject to a General Certification of Conformity (GCC) Certificate or a Children’s Product Certificate (CPC).
Products that are subject to the Children’s Product Certificate include, but are not limited to:
- Children’s products
- Art sets
- Toys
- Pacifiers and rattles
- Backpacks and school supplies
- Clothing
- Sleepwear
- Outerwear
- Infant articles
- Imitation jewelry
- Cribs
- Other durable furniture
- Infant sleep products
- Safety gates
- Baby carriages
- Stationary activity centers
General Certification of Conformity Products Categories
Below is a list of products and their corresponding product safety rules, which require e-filing certification via a General Certification of Conformity.
| Product or Issue Category | Legal Citation |
| All-terrain vehicles | 16 CFR part 1420 |
| Architectural glazing materials | 16 CFR part 1201 |
| Adult portable bed rail | 16 CFR part 1270 |
| Artificial emberizing materials [1] | 16 CFR part 1305 |
| Bicycle helmets | 16 CFR part 1203 |
| Bicycles | 16 CFR part 1512 |
| Bunk beds | 16 CFR part 1213 |
| Button cell or coin battery | 15 U.S.C. § 2056e
16 CFR § 1263.3 16 CFR § 1263.4 |
| Carpets and rugs (large) | 16 CFR part 1630 |
| Carpets and rugs (small) | 16 CFR part 1631 |
| CB antennas | 16 CFR part 1204 |
| Cellulose insulation | 16 CFR part 1209 |
| Cigarette lighters | 16 CFR part 1210 |
| Clothing storage units | 16 CFR part 1261 |
| Consumer patching compounds [1] | 16 CFR part 1304 |
| Dive sticks and other similar articles | 16 CFR § 1500.86(a)(7)
16 CFR § 1500.86(a)(8) |
| Drywall | 15 U.S.C. § 2056c |
| Fireworks | 16 CFR part 1507 |
| Garage door openers | 16 CFR part 1211 |
| Lawn darts [1] | 16 CFR part 1306 |
| Liquid nicotine packaging (CNPPA) | 15 U.S.C. § 1472a |
| Magnets | 16 CFR part 1262 |
| Matchbooks | 16 CFR part 1202 |
| Mattresses and mattress pads | 16 CFR part 1632 |
| Mattresses and mattress sets | 16 CFR part 1633 |
| Metal-cored candlewicks [1] | 16 CFR § 1500.17(a)(13) |
| Multipurpose lighters | 16 CFR part 1212 |
| Paints and similar surface coatings containing lead [1] | 16 CFR part 1303 |
| Portable fuel containers (flame mitigation device) | 16 CFR part 1461 |
| Portable fuel containers (special packaging) | 16 CFR part 1460 |
| Power lawn mowers (walk-behind) | 16 CFR part 1205 |
| Refrigerator doors [2] | 16 CFR part 1750 |
| Refuse bins [1] | 16 CFR part 1301 |
| Wearing apparel [3] | 16 CFR part 1610 |
| Special packaging (PPPA) | 16 CFR part 1700 |
| Swimming pool slides (freestanding) | 16 CFR part 1207 |
| Toy, look-alike, and imitation firearms | 16 CFR part 1272 |
| Vinyl plastic film | 16 CFR part 1611 |
| Virginia Graeme Baker Pool and Spa Safety Act Regulations | 16 CFR part 1450 |
E-filing certification is required only for finished products that are subject to a CPSC consumer product safety rule and are either imported for consumption or warehousing, or distributed in U.S. commerce. The requirement applies to finished products only, not to component parts. For imported products, the importer is responsible for certifying compliance.
Be Prepared for the Impact on Small Businesses
While more than 270,000 small businesses are expected to be affected, total compliance costs are generally projected to be less than 1% of annual revenue. Small firms are expected to generate approximately 260,000 certificates and may experience impacts related to extended GCC recordkeeping, additional labor time and modest out-of-pocket e-filing costs. The estimated first-year cost to small importers is $272.18 million, or about $1,104 per firm, with ongoing annualized costs of approximately $67 per firm.


